Home Health: LeadingAge Submits Comments on 2015 Proposed Rule

Members | August 24, 2014

LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the CY 2015 home health proposed rule.

LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the CY 2015 home health proposed rule that address:

  • Changes to the Face to Face Documentation Requirements.
  • Implementation of the Pay-for- Reporting performance requirement for the Home Health Quality Reporting Program.
  • Updates to HH QRP Measures Which Are Made as a Result of Review by the NQF Process.
  • Medicare Coverage of Insulin Injections Under the HH PPS.
  • Change to the Therapy Reassessment Timeframes.
  • Value-based purchasing model for Home Health Agencies that CMS plans to test in certain states beginning in CY 2016.

Changes to the Face-to-Face Encounter Documentation Requirements

LeadingAge recommends that CMS:

  • Allow the home health record or care plan to be integrated with the medical record to facilitate the ability of the Medicare contractor to accurately determine if the documentation shows that the individual was eligible for home health services.
  • Use the form CMS-485, Home Health Certification and Plan of Care  as the standardized form that is used by all Medicare home health providers to document the face to face encounter.
  • Include a checklist in the standardized form to document homebound status.
  • Develop a standardized face to face encounter electronic template based on the CMS-485, Home Health Certification and Plan of Care that includes a drop down for homebound status. 
  • Eliminate the need for the physician to include a brief narrative that describes the clinical justification of ordering skilled nursing visits for management and evaluation of the patient's care plan as part of the certification/recertification of eligibility as outlined in §424.22(a)(1)(i) and §424.22(b)(2).

Implementation of the Pay-for- Reporting performance requirement for the Home Health Quality Reporting Program

LeadingAge agrees with the timeframes and the minimum scores proposed by CMS, but we believe that there should be an exceptional circumstance policy to address situations beyond the control of the home health agency that would result in not submitting Home Health Quality Report in a timely manner. 

Updates to HH QRP Measures Which Are Made as a Result of Review by the NQF Process

LeadingAge recommends that CMS:

  • Notify home health providers when NQF in their Consensus Development Process is asking for input on NQF measures that are being used by HHA in order to give home health providers an opportunity to comment on a change in the measure. 
  • Develop a more comprehensive list and definition of what changes constitute a substantive and non- substantive change in a measure, and stakeholders should be given the opportunity to submit comments on the list for CMS to consider. 

Medicare Coverage of Insulin Injections Under the HH PPS

LeadingAge recommends the following codes for conditions that would indicate the patient is unable to self- inject insulin be added to TABLE 28:

  • DM with peripheral polyneuropathy (numbness) – this numbness can be in the hands and makes for self-injection difficult (357.2). 
  • DM with autonomic neuropathy (their blood pressure drops when standing and they are at high risk for complications related to hypoglycemia) (337.1).
  • Psychiatric disorders that would precipitate the inability of the patient to understand and comply with the regiment for self-injection of insulin. 
  • Neurodegenerative diseases (332.0), such as ALS (335.2), MS (340.0) and Essential tremor (333.1).

Change to the Therapy Reassessment Timeframes

LeadingAge proposes that CMS monitor therapy utilization, changes in hospital re-admission and admission rates for home health patients receiving therapy under the proposed reassessment regulation that requires a reassessment at least every 14 calendar days per discipline.

Value-based purchasing model for Home Health Agencies in the pilot program

LeadingAge recommends that CMS:

  • Provide a large enough incentive to encourage home health agencies to invest in technology, staff training and improved clinical and operational systems.
  • Ensure that the risk adjustment is both at the home health agency level, and at the beneficiary level.
  • Consider choosing two states from each of the four Medicare Administrative Contractor (MAC) Jurisdictions, and at least one rural state and one frontier state should be included.
  • Not include states where CMS has imposed a moratorium on certain regions for new home health agencies.
  • Not use the home health five star rating system as a determinant of payment.
  • Use measures that relate to the quality of the care for the treatment of the condition that required skilled intermittent care and /or rehabilitation under the Medicare benefit.