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Volume 22.03

The Centers for Medicare & Medicaid Services (“CMS”) has released the Proposed Rule, “Medicare Program; Calendar Year (CY) 2023 Home Health Prospective Payment Rate Update; Home Health Quality Reporting Requirements; Home Health Value-Based Purchasing Expanded Model Requirements; and Home Infusion Therapy Services Requirements” 2022-13376 (federalregister.gov).

The Proposed Rule would effectively reduce the CY2022 National Standardized 30-Day Period Payment from $2,1031.64 to $1,904.76 for CY2023.  The rate is most significantly impacted by a permanent reduction of 7.69% which is allegedly the result of home health agency behavioral changes with the implementation of PDGM.  Additionally, the rate change includes one 2.9% inflation update, which is comprised of a 3.3% market basket index increase less a .4% productivity adjustment.

As with other rate changes proposed and finalized, no consideration is being given to the rapidly increasing costs being experienced both in employee compensation and other costs.

Amazingly, while CMS has proposed to decrease payments, many believe that home health agencies have been underpaid as a result of the implementation of PDGM.

The Proposed Rules also includes, but is not limited to the following:

  • A proposal to codify by regulation the factors adopted in the CY2019 Final Rule those factors to be considered when determining if measures should be removed from the HH QRP measure set.
  • Ending the suspension of the collection of OASIS data on non-Medicare and non-Medicaid patients.
  • Establishing three new G-codes to capture claims information regarding home health services delivered through telecommunications.

The National Association for Home Care & Hospice (“NAHC”) will be offering a webinar on Thursday, June 23, 2022 at 2:00 P.M., “What the CY2023 Home Health Proposed Payment Rule Means for Your Agency”.  You can register at Online Store (avectra.com).  NAHC members can attend the webinar for free, others will be charged $99 for participation.  The faculty are Mary Carr, VP of Regulatory Affairs and Bill Dombi, President.

The webinar will cover:

  • Rate updates and revisions to components of the PDGM model,
  • Payment updates to the home infusion therapy services,
  • Changes to the expanded HHVBP demonstration and HHQRP programs,
  • Collection of telecommunications data,
  • Request for information on health equity in the HHQRP and the future approach for health equity in the expanded HHVBP model, and
  • More.