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 Volume 24.03

The two largest organizations representing home care providers, the National Association for Home Care & Hospice (“NAHC”) and the National Hospice and Palliative Care Organization (“NHPCO”), on June 10, 2024, signed an affiliation agreement.

Beginning July 1, 2024, the organizations will begin integrating operations. The integration will operate under the name of NAHC-NHPCO Alliance until the future name of the organization is determined.

Additional information is available at https://nahc.org/.


This proposed rule provides proposed updates to the Medicare home health payment rates; the payment rate for the disposable negative pressure wound therapy (“dNPWT”) devices; and the intravenous immune globulin (IVIG) items and services payment rate for CY 2025 in accordance with existing statutory and regulatory requirements. In addition, it proposes changes to the Home Health Quality Reporting Program (HH QRP) requirements and provides an update on potential approaches for integrating health equity in the Expanded Health Value Based Purchasing (“HHVBP”) Model. It also proposes a new standard for acceptance to service policy in the HH conditions of participation (“CoPs”) and includes requests for information soliciting input on permitting rehabilitative therapists to conduct the initial and comprehensive assessment and the factors that may influence the patient referral and intake processes. Lastly, it proposes updates to provider and supplier enrollment requirements and changes to the long-term care reporting requirements for acute respiratory illnesses.

While operating expenses continue to rise, the Proposed Rule, everything considered, reduces the base PDGM 30-day payment rate from $2,038.15 in 2024 to $2,008.12 for 2025. While the focus is to provide more in-home care and more individuals become Medicare-eligible, the proposed rule changes would result in a net reduction in expected Medicare expenditures in 2025 of $280 million.

According to NAHC President William Dombi, “Congress must step in immediately to put an end to this dismantling of the Medicare home health benefit. The value of home health services is not only undeniable; it has been proven by CMS in its analysis and expansion of the highly successful Home Health Value Purchasing demonstration project. We call on Congress to correct what CMS has done and prevent the growing harm to the millions of highly vulnerable home health patients that depend and will depend in the future on this essential Medicare benefit.”

Of course, payment rate decreases are attracting significant attention; however, other issues are addressed by the Proposed Rule.

Home health conditions of participation are proposed to incorporate a new standard relating to the development of a policy to be consistently applied to each prospective patient referred to the agency.  The policy would need to include:

  •        Criteria related to the agency’s capacity,
  •        Anticipated needs of the prospective patient,
  •        The agency’s caseload and case mix,
  •        The agency’s staffing levels, and
  •        The skills and competencies of the agency’s staff.

Additionally, Medicare enrollment requirements are proposed to expand the definition of a “new provider or supplier”, solely for purposes of applying a provisional period of enhanced oversight, to include providers and suppliers that are reactivating their Medicare enrollment and billing privileges.

Additional details will be provided as the Proposed Rule is further reviewed.

The Proposed Rule is available at 2024-14254.pdf (federalregister.gov).