Medicare Program Updates Payment Policies for Home Health Agencies for 2024

Home health agencies will see a modest 0.8% payment update in calendar year (CY) 2024 for services provided to Medicare patients under the final rule [PDF] issued November 1, 2023. The provisions of this final rule go into effect January 1, 2024. This small update is a result of a nearly 2.6% payment reduction the Centers for Medicare & Medicaid Services (CMS) is imposing because payments to the industry exceeded the costs to provide care by nearly 45%. CMS updates payment policies for home health agencies annually as required under federal law.

One of the ways the industry seems to have decreased their overall costs is through a decrease in the delivery of therapy services, including speech-language pathology services, since the implementation of the patient driven groupings model (PDGM). ASHA continues to monitor this trend, including its correlating impact on speech-language pathologists’ employment in the sector and patient access to and quality of care.

CMS has imposed payment reductions for the last several years to account for increased program spending since implementation of PDGM in 2020 and will likely continue to apply such reductions until spending aligns more accurately with cost.

Quality and Value Program Updates

CMS made several tweaks to the measure sets for the home health quality reporting program (HHQRP) and value-based purchasing (HHVBP) program. ASHA has consistently recommended to CMS that measures adopted by these programs should be reflective of a broader definition of function to include communication and cognition. To date, however, many of the measures selected do not reflect ASHA’s recommendation.

HHQRP Updates

CMS adopted two new measures for the CY 2025 HHQRP:

1. COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date (Patient/Resident COVID-19 Vaccine) measure to the HH QRP beginning with the CY 2025 HH QRP.
2. Functional Discharge Score (DC Function) measure to the HH QRP beginning with the CY 2025 HH QRP.

It also removed one measure effective for the CY 2025 HHQRP:

1. Application of Percent of Long-Term Care Hospital (LTCH) Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function (Application of Functional Assessment/Care Plan) measure.

CMS will also start publicly reporting data associated with the following HHQRP measures:

1. Discharge Function;
2. Transfer of Health (TOH) Information to the Provider—Post-Acute Care (PAC) Measure (TOH-Provider);
3. Transfer of Health (TOH) Information to the Patient—Post-Acute Care (PAC) Measure (TOH-Patient); and
4. COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date.

HHVBP Updates

CMS is making the following changes to the HHVBP measure set:

1. Replace the two Total Normalized Composite Measures (for Self-Care and Mobility) with the Discharge Function Score measure effective January 1, 2025;
2. Replace the OASIS-based Discharge to Community (DTC) measure with the claims-based Discharge to Community-Post Acute Care (PAC) Measure for Home Health Agencies, effective January 1, 2025;
3. Replace the claims-based Acute Care Hospitalization During the First 60 Days of Home Health Use and the Emergency Department Use without Hospitalization During the First 60 Days of Home Health measures with the claims-based Potentially Preventable Hospitalization measure, effective January 1, 2025.

Removal of Outcome and Assessment Information Set (OASIS) Items Associated with Therapy Data Collection

Over the strong objection of ASHA [PDF] and other stakeholders, CMS finalized its proposal to remove Items M0110: Episode Timing and M2220: Therapy Needs. ASHA maintains that while therapy service delivery data is captured via claims, maintenance of this data on OASIS is critical to efforts to monitor changes in the intensity of therapy service delivery that may indicate problematic or even fraudulent billing patterns by some home health agencies.

Medicare Enrollment (Credentialing) Updates

Finally, CMS finalized a change that would allow it to “deactivate” a provider or supplier’s enrollment if a claim has not been submitted to Medicare within the last 6 calendar months. This change applies to facilities such as skilled nursing facilities, home health agencies, and individual clinicians such as audiologists and SLPs. Deactivation is not the same as termination of billing privileges and deactivated providers and suppliers are still considered enrolled. However, this policy is designed to prevent the inappropriate use of enrollment to submit fraudulent claims. Reactivation of enrollment after the 6-month period has elapsed is designed to be less time and resource intensive than initial Medicare enrollment.

Questions?

Email ASHA’s health care and education policy team at reimbursement@asha.org.