Page 1 - 2018HomeHealthHighlights

HOME HEALTH

2018

Highlights

Long-Awaited NEW Conditions of Participation Took Effect in January

After years of uncertainty following the 2014 proposal by CMS to completely
revise the Conditions of Participation (CoPs) for Medicare-certified home
health providers, the new rules finally became effective on January 13, 2018.

Many of the revisions simply implemented current provider practice, but
others presented a challenge for agency compliance. PHA hosted several

member education events and distributed tools and resources to help

agencies with this adjustment. Since implementation, some hot button issues
for surveyor scrutiny have included:

• Infection control, particularly in how nursing staff handle supplies and supply bags while in the patient’s home
• Deliver y of verbal patient rights information no later than the second skilled visit and securing signatures on written
patient rights notices from the patient or legal representative within four business days

• Home health aide training, which requires in-person competency demonstration of bathing technique on actual
patients rather than mannequins or simulated patients

PHA also worked with the Department of Health (DOH) as the new CoPs were being implemented to understand the

requirements that apply to providers when state licensing regulations conflict with the CoPs. There are 10 areas in the

state regulations that differ from the new CoPs. Providers must comply with the strictest rule, whether state or federal,
when this inconsistency exists. PHA is advocating for DOH to revise state regulations to mirror the federal rules.

Payment Reform Finalized with Patient-Driven Groupings Model (PDGM)

On October 31, CMS released the 2019 Home Health Payment Update rule finalizing the Patient-Driven Groupings
Model (PDGM) to begin in 2020. While PHA and many other state and national level advocates opposed the new

model, CMS has decided to move forward with little adjustment. Unlike today’s home health prospective payment
system, PD GM does not rely on a patient’s use of therapy services as a factor for determining payment. It also
changes payment to a 30-day rather than a 60-day period. Both of these aspects of the model were mandated by

Congress in the Bipartisan Budget Act of 2018. Reimbursement will fall into one of 432 categories, according to the
following factors:

1 Timing: First (early) or subsequent (late) 30-day period in the patient’s care
2 Admission Source: Patient admitted from an institution (in the last 14 days) or the community
3 Clinical Grouping: Where the patient’s primary diagnosis falls within 11 clinical categories

4 Functional Impairment Level: Low, medium or high functional needs according to OASIS
5 Comorbidity Adjustment: Secondary diagnoses that warrant additional funding

While the full effect of PDGM is still unclear, agencies can expect additional administrative work for billing staff with the
shortened timeframe for submitting RAPs and final claims. The 30-day payment period will not impact clinical staff
performing OASIS assessments or recertifications, which will continue on a 60-day timeline. PHA will continue to
provide members with new tools and information to help providers successfully navigate these changes.