Proposed 2014 Medicare rules for home health agencies would
reduce the 60-day episode rate, increase the per-visit rate for fewer than five
visits, remove two categories of diagnostic codes, and add two claims-based
The Centers for Medicare and Medicaid Services released the
120-page proposed rule in July. After the public
comment period, CMS will review feedback and announce a final rule before the
end of 2013.
Home health agency payment rates include speech-language
pathology services during renewable 60-day episodes under Medicare Part A. Audiology services, which are not a core home
health service, are billable separately under Part B.
If a patient requires fewer than five total home health
agency visits in an episode of care, the episode payment is replaced by a fixed
per-visit payment that is based on historic cost data for each discipline. The
proposed 2014 per-visit rate for speech-language pathology is $144.03; the rate
is $132.56 for physical therapy and $133.46 for occupational therapy
(geographically adjusted). The proposed figures represent a 6 percent increase
for each discipline, a much higher increase than in recent years.
In contrast, the proposal calls for an overall 1.5 percent
reduction in the payment rate for 60-day episodes, to $2,860. The proposed base
episode rate factors in a 2014 wage index and inflationary adjustments, but no
longer includes non-routine medical supplies. The Affordable Care Act allows a
reduction of up to 3.5 percent in the episodic rate every year from 2014 to
2017. CMS is implementing the maximum reduction for 2014 because of recent
nationwide audits that revealed significantly over-reported costs, but other
cost adjustments for inflation result in the average 1.5 percent reduction
In preparation for the Oct. 1, 2014, implementation of the
10th edition of International Classification of Diseases, CMS reviewed current
ICD-9 codes assigned to home health services, and grouped the codes into three
categories: those to keep as a recognized condition for home health services,
conditions that are too acute for home health treatment, and conditions that
would not required home health intervention. CMS also eliminated codes for
non-specific conditions and codes for "initial encounters" when the first encounter should have occurred in the hospital. None of the code changes is directly related to communication, speech or swallowing disorders that would affect SLPs performing home health services.
Home health agencies must continue to complete quality
assessments to participate in Medicare. These tools include the Outcome
Assessment Information Set Outcome and Assessment Information Set (OASIS, a
tool that measures patient outcomes), claims data and patient experience care data.
CMS is proposing the continued use of the OASIS and the addition of two
claims-based measures: rehospitalization during the first 30 days of home care
and emergency department use without hospital readmission during the first 30
days of home care. CMS would publish data from these measures on the Home
Health Compare website. Finally, CMS proposes to report measures for the entire
episode of care, instead of by the current reporting by length of episode.
In addition to these changes, the proposed rule summarizes
an ongoing payment reform study. The study, required by the Affordable Care
Act, is in response to concerns that some Medicare beneficiaries have no access
to home health services and that the prospective payment system, which is based
on per-episode reimbursement, may encourage home health agencies to adopt
selective admission policies.
By law, the study must include a review of costs related to
the provision of home health services to low-income beneficiaries and
beneficiaries in medically underserved areas. An optional area of study is a
review of the home health agency prospective payment system and the
relationship between the patients' health condition severity and access to care. Analysis of data collected from surveys sent to agencies and physicians earlier this year will be included in the study.
ASHA will continue to inform members of Medicare and other
health care policy changes through Headlines, Leader articles and webpage updates.