CMS Home Health Final Rule Eliminates Face-to-Face Narrative for Physicians, Allows More Time for Therapy Reassessments

From the Pennsylvania Homecare Association

Late yesterday, CMS released the 2015 home health final rule, which eliminates the narrative requirement for physician face-to-face visits and requires therapy reassessments every 30 calendar days, rather than every 14 calendar days as proposed in July.

Face-to-Face Narrative
After receiving 337 comments from agencies, associations and healthcare professionals, CMS finalized that physicians no longer need to provide a narrative in their own words explaining why the patient is eligible for home health. The certifying physician still would be required to certify that a face-to-face patient encounter occurred and to document the date of the encounter.

Therapy Reassessments
CMS eliminated 13th and 19th visit professional therapist evaluations and replaced that requirement with assessments every 30 days, rather than the 14 days outlined in the proposed rule.

Other highlights:

  • CMS maintained its proposed across-the-board recalibration of case mix weights. Agencies must include this change in any evaluation of the payment rate reductions as the weights are dramatically different than 2014.
  • Rate rebasing continues with an $80.95 base episode rate reduction offset by a 2.1% inflation update (2.6 MI minus 0.5 productivity adjustment) along with the second-year adjustments to LUPA and NRS rates. The productivity adjustment is 0.1% greater than proposed leading to a slightly lower inflation update: 2.1 vs. 2.2 proposed.
  • CMS established a minimum submission threshold for the number of OASIS assessments that each agency must submit. Beginning in 2015, the initial compliance threshold would be 70% and will increase by 10% increments over the next two years to reach a maximum threshold of 90%.
  • The proposed new wage index that is a 50/50 blend of the new CBSA designations is included for 2015. CMS limits the rural add-on to counties that are “rural” under the new CBSA geographic area designations only. Over 100 counties will lose the add-on as a result.
  • The home health value-based purchasing model being considered would include a 5-8% adjustment in payment made after each planned performance period in the projected five to eight states selected to participate in the model.