How the Home Health 2016 Proposed Rule Will Impact Home Health Agencies in the Future
The Centers for Medicare and Medicaid Services (CMS) on April 20, 2015, released a proposed rule updating Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2016, which projects an increase in overall payments to SNFs by $500 million, or 1.4%, compared to FY 2015 levels. The proposed home health guidelines would be attributed to a 2.6% market basket increase that would be reduced by a 0.6 percentage point forecast error adjustment and a 0.6 percentage point multifactor productivity adjustment.
The update would also implement a provision of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act), which reduces the annual update to SNFs that fail to submit required quality data to CMS under the SNF Quality Reporting Program (QRP), beginning in 2018.
Also, CMS is proposing three measures SNFs would be required to report beginning with the FY 2018 SNF QRP that address three quality domains identified in the IMPACT Act:
(1) Skin integrity and changes in skin integrity.
(2) Incidence of major falls.
(3) Functional status, cognitive function, and changes in function and cognitive function.
The above measures address the IMPACT Act requirement of standardized post-acute care data reporting across home health and SNFs.
In FY 2019, CMS also plans on establishing a 30-day all-cause, all-condition hospital readmission quality measure that will be used in a new SNF Value-Based Purchasing (VBP) Program, as required by the Protecting Access to Medicare Act of 2014 (PAMA). Plus, CMS also acknowledges issues associated with the SNF VBP Program, which will be addressed in the FY 2017 SNF PPS proposed and final rules. The proposed rule would establish new regulatory reporting requirements for SNFs and nursing facilities to electronically submit staffing information based on payroll data, as mandated by the Affordable Care Act (ACA).
If the complexities of the CMS’s home health proposed rule is confusing you, join our expert speaker Robert Markette in this audio session, where he will go through the proposed rule to identify any compliance issues for the coming year that home health agencies need to be prepared for, and review proposed rate changes and related issues.