November 3, 2022
CMS proposed for the CY 2025 HH QRP, the expanded reporting would be required for patients discharged between January 1, 2024, and June 30, 2024. Beginning with the CY 2026 HH QRP, HHAs would be required to report assessment-based quality measure data and standardized patient assessment data on all patients, regardless of payer, for the applicable 12-month performance period (which for the CY 2026 program, would be patients discharged between July 1, 2024, and June 30, 2025).
In response to concerns raised by commenters on the burden associated with the proposed new data collection, CMS is finalizing that the new OASIS data reporting for the HH QRP will begin with the CY 2027 program year, with two quarters of data required for that program year. A phase-in period is in place for January 1, 2025 through June 30, 2025 in which failure to submit the data will not result in a penalty. CMS is finalizing as proposed regulatory text change that consolidates the statutory references to data submission. CMS is also finalizing as proposed the codification of the measure removal factors adopted in the CY 2019 HH PPS final rule.
CMS also provided a summary of the comments received in response to their Request for Information regarding health equity in the HH QRP
Expanded Home Health Value Based Purchasing (HHVBP) Model
CMS is finalizing as proposed changes the HHA baseline year to CY 2022 for all HHAs that were certified prior to January 1, 2022 starting in the CY 2023 performance year. CMS is also making conforming regulation text changes at §484.350(b) and (c). CMS is finalizing the proposed amendments to the Model baseline year from CY 2019 to CY 2022 starting in the CY 2023 performance year to enable CMS to measure competing HHAs performance on benchmarks and achievement thresholds that are more current.
CMS also summarized the comments received on the request for comment on a potential future approach to health equity in the expanded HHVBP Model included in the proposed rule.
CMS proposed and finalized to establish three new G-codes for use on home health claims to capture home health services delivered via telecommunications. CMS reiterates that the collection of information on the use of telecommunications technology does not mean that such services are considered “visits” for purposes of eligibility or payment, such data will not be used or factored into case-mix weights, or count towards outlier payments or the LUPA threshold per payment period.
CMS will establish G-codes for identifying when home health services are furnished using
- synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system;
- synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system; and
- the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (remote patient monitoring).
Data collection using the G-codes would begin voluntarily by January 1, 2023 and become mandatory on claims by July of 2023.
CMS will issue program instructions outlining the use of new codes for the purposes of tracking the use of telecommunications technology under the home health benefit with sufficient notice to enable HHAs to make the necessary changes in their electronic health records and billing systems.
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