CMS Proposed Home Health Payment Rule for CY 2023: What you Should Know
The Center for Medicare and Medicaid Services (CMS) released its proposed home health payment rule for Calendar Year (CY) 2023 on June 17, 2022. We’ve outlined the must-know details for home health providers to stay informed. The comment period is open until Aug. 16, 2022, at 5 pm ET.
What’s proposed for CY 2023?
CMS estimates that Medicare payments to home health agencies for CY 2023 will decrease by -4.2%. This significant decrease reflects a 2.9% payment update, estimated -6.9% permanent behavioral adjustment, and the effect of a -0.2% decrease with the updated Fixed Dollar Los (FDL). CY 2023 will have a national, standardized payment of $1904.76 per 30-day period for those agencies that submit the required quality data. This ensures aggregate expenditures remain budget neutral.
The rule proposes a permanent 5% cap on negative wage index changes regardless of the underlying reason for the decrease. This is stated to improve predictability in home health payments.
It is proposed that CY 2021 data will be utilized to update LUPA thresholds, as well as an update to the functional points and functional impairment levels by clinical group. As in CY 2022, functional points that are assigned by response trend lower. We will also see a decrease in the thresholds by clinical group.
Proposed Comorbidity adjustment changes are also based on CY 2021 data and show an increase from 10 subgroups to 23 subgroups for the Low Comorbidity Adjustment. The Low Comorbidity table includes an addition of five new subgroups and removal of two subgroups. The High Comorbidity adjustment changes include an increase from 85 interactions to 94. The table changes are being updated to reflect the proposed coding changes.
Value-Based Purchasing Highlights
Changes in definitions and terms associated with VBP are proposed. Baseline year will be updated to HHA baseline year. This will determine the improvement threshold for each measure. Model baseline year will be the calendar year used to determine benchmark and achievement threshold for each measure.
A change for baseline, performance, and payment years for VBP is proposed. This table that is included in the proposed rule reflects the changes.
It is believed that these changes will allow all eligible HHAs, starting with the CY 2023 performance year, to compete on a level playing field with all HHA baseline data being after the peak of the pandemic.
CMS is proposing to end the suspension of collecting OASIS on non-Medicare/non-Medicaid HHA patients. HHAs would be required to submit all-payer OASIS data for purposes of the HH Quality Reporting Program (QRP), beginning with the CY 2025 program year. The submission of OASIS data on home health patients regardless of payor source will ensure that CMS can appropriately assess the quality of care provided to all patients receiving skilled care by all Medicare-certified HHAs that participate in the HH QRP.
This increase in OASIS collection associated with all payors is expected to cost each agency approximately $23529.82 annually. It is noted that any collection requirements must be reviewed and approved by the Office of Management and Budget (OMB) before it will be effective.
OASIS-E will be implemented January 1, 2023. This is a major change from the current data set and will require significant preparation to ensure accurate assessment of the new items.
As new regulatory updates are released, it is important to ensure your organization is well-equipped to adapt. McBee is dedicated to providing resources to help organizations nationwide deliver continuous quality care.