CMS Posts Final Rule for 2012 PPS Rates

CMS this week posted the final rule for Medicare home health PPS rates for calendar year 2012.  The finalized rates are slightly better than the proposed rates that CMS released in July, due to the fact that CMS has accepted industry recommendations to phase-in the case mix creep adjustment over two years, applying a 3.79% adjustment in 2012 and reserving 1.32% for 2013. Still, the 2012 national standard episodic rate of $2138.52 is a reduction from the 2011 rate of $2192.07.

The final 2012 rate is represents a 2.4% reduction from the 2011 rate, the result of a combined 2.4% market basket index inflation update, a 1% reduction in the inflation update required by the health care reform law, and a 3.79% case mix creep adjustment.
The final rule also adjusts the case mix weight for every HHRG to adjust for budget neutrality after removing eliminating hypertension as a factor in the calculation.  The rule also reduces the weights on high-therapy episodes and increasing weights on non-therapy episodes.

See this spreadsheet listing the updated rates for all HHRG’s in each MA geographic region.

In addition to setting forth updates to PPS, the final rule included some minor changes regarding face-to-face (F2F) encounters.  CMS is removing the modifier “attending” from the regulatory language to describe physicians who qualify as the physician who cared for the patient in an acute or post-acute facility. Most people considered the word ‘attending” to mean a community physician and not the in-patient physician.

Acknowledging that the Affordable Care Act did not preclude a patients’ acute or post-acute care physician from informing the certifying physician (physician who signs the 485) regarding their experience with the patient for the purpose of the F2F encounter requirement as an NPP can, CMS is also amending the F2F language to allow the acute or post-acute care physician to inform the certifying physician regarding the F2F.  The “community physician” could then complete the necessary documentation.

CMS believes these modifications allow additional flexibility in the process, making it easier for providers. Members with questions about the F2F changes can contact Helen Siegel at the Alliance office.

This finalized regulation will be the subject of an in-depth review by representatives of Blacktree Healthcare Consulting during the Alliance’s 2011 Financial Management Conference November 30 in Waltham.  Be sure to register today!

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