The Centers for Medicare and Medicaid Services (CMS) have issued a proposed rule regarding payment changes as well as revisions to the physician face-to-face and therapy assessment rules.
Below is a summary of the most noteworthy aspects of the proposed rule provided by the National Association for Home Care & Hospice (NAHC):
1. Proposed 2012 payment base episode rates are reduced to $2112.37 from the current $2192.07. This is a reduction of approximately 3.56%.
2. The rate changes are due to a proposed 2.5% market basket index inflation update, a 1 point reduction in the MBI under the health care reform law, and a 5.06% case mix creep adjustment.
3. The increase in the case mix creep adjustment is due to the evaluation of 2009 coding weight changes. CMS found that ¾ of the coding increases was a result of increases in therapy visits above the 14 and 20 visit thresholds.
4. The 3.56% rate reduction will impact individual providers unevenly. CMS proposes to make significant changes in coding weights by eliminating hypertension as a factor in the calculation, reducing the weights on therapy episodes, and increasing weights on non-therapy episodes. Providers with high volumes of therapy cases could see greater net rate reductions. A provider-specific analysis using the provider’s particular case mix is the only reliable way to assess impact.
5. CMS proposes to change the face-to-face rule and allow one physician to do the encounter and report the information to another physician who completes the certification and plan of treatment documentation. This should help in circumstances where a patient is under the care of a hospitalist who transfers the patient to a community physician.
6. CMS proposes to clarify the therapy assessment standard where more than one discipline is involved.
The proposed rule on rates is in line with what had been expected. Nevertheless, that does not turn a lemon into lemonade. The change on the face-to-face rule is appreciated, but will only make a slight improvement as the documentation requirements remain a problem.
CMS also posted the proposed rule on the Medicaid face-to-face encounter requirements. The proposal aligns the Medicaid time frames with the Medicare time frames while providing some flexibility to states to determine other aspects such as the content and form of documentation. The proposal also reaffirms CMS’s position that a homebound requirement in Medicaid home health is not permitted and that services can be provided outside the home. Finally, the proposal offers clarifications on the coverage of medical supplies and equipment.
Another summary is available in a press release issued by CMS with a few more specifics on payment. The Home Care Alliance is working on a specific analysis regarding the payment changes based on the northeast’s wage index and will have that available soon.
See links to the specific proposed rules in the Federal Register below:
- Medicaid Face-to-Face Proposed Rule
- Home Health Prospective Payment System Rate Update for Calendar Year 2012
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