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Home Health payments proposed to decrease by 2.2%

The decrease is due in part to a permanent behavior assumption adjustment.

Susan Morse, Executive Editor

Photo: Luis Alvarez/Getty Images

Home Health Agencies get a 2.2% payment decrease compared to 2023, due in part to a permanent behavior assumption adjustment.

CMS issued a 2.7% payment increase for 2024, but by statute that amount was offset by a 5.1% decrease of permanent behavior assumption adjustment and by another 0.2% decrease due to the fixed-dollar loss ratio, according to the 2024 Home Health Prospective Payment System Rate Update proposed rule released on June 30.
 
For 2024, using updated 2022 claims and the methodology finalized in the 2023 final rule, CMS determined that Medicare paid more under the new system than it would have under the old system. 

CMS is proposing an additional permanent adjustment percentage of -5.653% in 2024 to address the differences in the aggregate expenditures.

WHY THIS MATTERS

This rule proposes a permanent, prospective adjustment to the CY 2024 home health payment rate to account for the impact of the implementation of the Patient-Driven Groupings Model (PDGM). This adjustment accounts for differences between assumed behavior changes and actual behavior changes on estimated aggregate expenditures due to the implementation of the model and 30-day unit of payment as required by the Bipartisan Budget Act of 2018. 

CMS previously finalized, for CY 2023, a permanent adjustment that was half of the estimated required permanent adjustment.
 
In addition, CMS is also proposing to rebase and revise the home health market basket; revise the labor-related share; recalibrate the PDGM case-mix weights; update the low utilization payment adjustment thresholds, functional impairment levels and comorbidity adjustment subgroups for 2024; codify statutory requirements for disposable negative pressure wound therapy; and establish regulations to implement payment for items and services under two new benefits: lymphedema compression treatment items and home intravenous immune globulin. 

These actions, CMS said, would help improve patient care and also protect the Medicare program's sustainability for future generations. In addition, the proposed rule includes several hospice-related enrollment provisions that more closely scrutinize hospice owners to ensure they do not pose program integrity risks.
 
THE LARGER TREND
 
On Jan. 1, 2020, CMS implemented the home health PDGM and a 30-day unit of payment, as required and amended by the Bipartisan Budget Act of 2018. 

The PDGM aligns payments with patient care needs, especially for clinically complex beneficiaries. The law required CMS to make assumptions about behavior changes that could occur because of the implementation of the 30-day unit of payment and the model.
 
In the CY 2019 final rule, CMS finalized three behavior assumptions (clinical group coding, comorbidity coding and low utilization adjustment threshold). 

The law also requires CMS to annually determine the impact of differences between assumed behavior changes and actual behavior changes on estimated aggregate expenditures, beginning with 2020 and ending with 2026, and to make temporary and permanent increases or decreases, as needed, to the 30-day payment amount to offset such increases or decreases. 

CMS has released more information on the Home Health Prospective Payment System, the Home Health Patient-Driven Groupings Model and the expanded Home Health Value-Based Purchasing Model on its website.

Twitter: @SusanJMorse
Email the writer: SMorse@himss.org