CMS Releases Final Home Health Rule, Adds Discharge Planning Proposal

CMS published the Final Rule for Medicare Home Health PPS and VBP for CY 2016 to its website yesterday.  The official notice will be published in the Federal Register on November 5.

CMS also announced a “Discharge Planning Proposed Rule,” that is estimated to cost home health agencies nationwide about $283 million. The proposal, which the Home Care Alliance will fully analyze, will revise discharge planning processes for hospitals, long-term care hospitals, inpatient rehabilitation facilities, and critical access hospitals in addition to home health.

In terms of changes made to the Home Health Final Rule, CMS pulled back slightly regarding both payment and in the Value Based Purchasing Program. Below is an analysis from HCA staff:

Value Based Purchasing:

The final rule makes minor changes to the VBP system from the proposed rule.  The same nine states (including MA) are selected, with all agencies in the state included in the VBP system.  VBP will begin January 1, 2016, with a 2015 baseline year on performance, with all agencies within each selected state competing against each other for payment adjustments tied to quality performance measures.

CMS made a small concession to industry concerns that the proposed risk corridor was too broad, and reduced the maximum payment reduction in the first year of the VBP from the proposed 5 percent to 3 percent. The payment adjustments will be increased incrementally over the course of the model with: 

  • a maximum payment adjustment of  3-percent (upward or downward) in 2018,
  • a maximum payment adjustment of 5-percent (upward or downward) in 2019,
  • a maximum payment adjustment of 6-percent (upward or downward) in 2020,
  • a maximum payment adjustment of 7-percent (upward or downward) in2021, and
  • a maximum payment adjustment of 8-percent (upward or downward) in 2022.

CMS dropped 4 process measures and 1 of the new reporting measures. The final set of 24 measures includes 10 outcome measures, 6 process measures, 5 HHCAHPS, and 3 New Measures.

Outcome Measures

  • Improvement in Pain Interfering with Activity-M1242
  • Improvement in Dyspnea- M1400
  • Improvement in Bathing-M1830
  • Improvement in Bed Transferring-M1850
  • Improvement in Ambulation-Locomotion M1860
  • Prior Functioning ADL/IADL-M1900
  • Improvement in Management of Oral Medications-M2020
  • Discharged to Community-M2420
  • Acute Care Hospitalization: Unplanned Hospitalization during first 60 days of Home Health- (Claims)
  • Emergency Department Use without Hospitalization- (Claims)

Process Measures

  • Influenza Vaccine Data Collection Period: Does this episode of care include any dates on or between October 1 and March 31?-M1041
  • Influenza Immunization Received for Current Flu Season-M1046
  • Pneumococcal Polysaccharide Vaccine Ever Received-M1051
  • Reason Pneumococcal vaccine not received-M1056
  • Drug Education on All Medications Provided to Patient/Caregiver during all Episodes of Care-M2015
  • Care Management: Types and Sources of Assistance-M2102

Home Health CAHPS: Satisfaction Survey Measures

  • Care of Patients
  • Communications between Providers and Patients
  • Specific Care Issues
  • Overall rating of home health care
  • Willingness to recommend the agency

New Measures

  • Influenza Vaccination Coverage for Home Health Care Personnel
  • Herpes zoster (Shingles) vaccination: Has the patient ever received the shingles vaccination?
  • Advance Care Plan

CMS has modified the reporting of the New Measures; HHAs will be required to begin reporting data (through a web portal) no later than October 7, 2016, for the period July, 2016, through September, 2016, and quarterly thereafter. As a result, the first quarterly performance report in July, 2016, will not account for any of the New Measures.

CY2016 PPS Rates

Case Mix Weights:  CMS made additional minor changes to the case mix weights based on additional analysis.

Case Mix Adjustment:  In a slight concession to industry comments, CMS is phasing in their proposed 2.88% case mix adjustment over three years instead of the two years they initially proposed.  So the final rule decreases the national, standardized 60-day episode payment amount by 0.97% each year in CY 2016, CY 2017, and CY 2018, instead of 1.44% for just 2016 and 2017. 

Market Basket Update:  The final CY 2016 home health market basket (2.3 percent) combined with the multifactor productivity adjustment (0.4 percentage points) results in a 1.9 percent home health payment update percentage.

Wage Index:  CMS made additional small adjustments to the Wage Index because they used an updated database of hospital wage data.  The final wage index is slightly lower than the proposed index for every geographic region in MA except Berkshire County.

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HCA to Launch Education Offering: Building a Behavioral Health Program

Behavioral Health Brochure header

In response to community need and member interest, HCA will launch in January 2016 a twelve-month training program for home health agencies interested in creating and sustaining a program to provide behavioral health services under the Medicare home health benefit. Based on work originally piloted at the VNS of New York, this project will provide learning and tools to put in place both the clinical competencies and administrative infrastructure. The project will feature onsite clinical training for at least five nurses per participant agency as well as diagnosis specific care guide and implementation manuals.

The objectives of this training are as follows:
• Learn how to provide Behavioral Health Home Care and get staff trained.
• Allow your agency to provide Behavioral Health Home Care during the year of the project
• Improve patients care for clients with mental health conditions
• Improve overall patient outcomes, including re-hospitalization, ER utilization and compliance.
• Enhance your position in your service area, provide a new Niche of care and grow revenue.

For additional information, see the Behavioral Health Brochure, or view this recorded webinar*. Agencies interested in participating in the project should contact Megan Fournier at for contracting information.

*View webinar handouts here 

CMS Sends Brief Response on Congressional HHPPS Letter

A letter to CMS voicing deep concerns about the Home Health proposed rule with 133 signatures from members of Congress, including all nine US Representatives from Massachusetts, was sent in mid September.

CMS issued their response, which was more brief than usual and only served to thank the signers for sharing those concerns. CMS is obviously not sharing much as the finalized regulation is set to be released on November 1st.

The original congressional letter to CMS made a few major points. Concerns about the case mix cuts centered on the data CMS relied upon to make those adjustments, which were flagged as “outdated” and illogical. CMS essentially ignored the past five years of data and instead used a decade of data in the prior time period to make projections going forward.

The letter also raised concerns about the proposed Value-Based Purchasing Program (VBP) that will take place in nine states, including Massachusetts. Specifically, the five-to-eight percent penalty/reward window was put forth as much too severe and dramatic as was the immense list of quality measures that CMS proposed that agencies would track as part of the VBP.

Among those leading on the letter were Massachusetts Congressman and home health care champion Jim McGovern. The Alliance thanks Congressman McGovern and all in the state’s congressional delegation that signed on. More information will be announced following the release of the final rule.

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Applications for Home Care NOI to Open on Nov. 2

According to the Executive Office of Elder Affairs (EOEA), the Notice of Intent (NOI) Application will open on Monday, November 2nd and will remain opened until necessary in order to conduct system and/or document updates.

The Homemaker NOI is the process Home Care agencies must complete if they are interested in contracting with the State’s network of 26 Aging Services Access Points (ASAPs) to provide Homemaker and Personal Care services through the “State Home Care program.”

The posting for approved providers will be completed within 4-6 weeks of the submitted Application.

This link brings you to an update found on the NOI Announcements page:

Existing providers will need to confirm/update corporate data within their approved Application if any data has changed.  If a Provider’s information is staying the same, no action needs to be taken. The EOEA will keep rejected NOI Applications available for 90 days from the rejection date for purposes of re-submission. Otherwise, a new application will need to be created and submitted.

For any providers that were previously rejected in FY 15 and did not re-submit a rejected NOI Application within the 90-day period, they must create/submit a new FY 16 Application.

Please note the NOI Announcements page includes a link to the MassHealth FEW Provider Enrollment documents, including an overview document.

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2016 NEHCC Call for Speakers Now Open!

The Call for Speakers for the New England Home Care and Hospice Conference and Trade Show is now open with new opportunities to speak! The grid below provides detailed information about the different options available to potential presenters.

The NEHHC welcomes Speaker Presentation applications from a diverse audience of home health and healthcare experts.



All proposals can be submitted by clicking below and must be entered by December 18th, 2015 for consideration.Call-Button-Rollover

For more information click HERE.

Home Health Interoperability and You!

The October 28th deadline to complete our Home Health HIT Adoption  survey is fast approaching.

The HCA Board of Directors and all of us involved in guiding this project do so with the belief that HIT represents the future of health care and home care.  So the question, you need to ask yourself is:  am I home care agency of the past – or am I positioning my agency for the future?

Completion of the survey itself can be part of an internal self assessment process to see where your agency is in terms of interconnectivity.  Completing the survey will assure that you will get a copy of a report with a roadmap to move your agency forward.

The survey can be completed here:  If you would like we can also send you a printed copy as many of those who have already completed it are finding it easier to print out – share with members of their team and then have a single person collate and input the responses. Contact to have this printable copy emailed to you.

To be sure you understand the questions and the survey’s value to you , we have scheduled an additional webinar for Wednesday October 21st from 10-11AM. You can register here.

Additionally, we have arranged for LIVE!!!  support for questions you may have while completing the survey please. You can contact project managers Jessica Hatch ( or Jennifer Monahan ( via email or can call them directly at the times below.

Be the future and get connected!



Date Time Contact Person Contact Number
October 20 – Tuesday 9:00 – 10:00 am Jessica 339-222-6126
October 20 – Tuesday 2:00 – 3:00 pm Jessica 339-222-6126
October22 – Thursday 9:00 – 10:00 am Jennifer 603-717-5420
October 22 – Thursday 2:00 – 3:00 pm Jennifer 603-717-5420
October 23 – Friday 12:00 – 1:00 pm Jessica 339-222-6126
October 26 – Monday 12:00 – 1:00 pm Jessica 339-222-6126
October 27 – Tuesday 9:00 – 10:00 am Jennifer 603-717-5420
October 27 – Tuesday 12:00 – 1:00 pm Jennifer 603-717-5420

HCA is Coming to Western MA!

The Home Care Alliance will hold two member events in the western part of the state in November.  Check out details below:

  1. Wednesday, November 4th 2:00 – 5:00PM : Western MA Membership Forum
    • Meeting being held at Cooley-Dickinson VNA & Hospice in Northampton, MA
    • Join the staff of HCA for a networking meeting to discuss products, programs, policy positions and more for the home care industry!
    • To register for this FREE meeting click HERE.
  2. Thursday, November 5th 9:00AM – 1:00PM : Home Health 101
    • Meeting being held at the Lord Jefferey’s Inn in Amherst, MA
    • Home Health 101 is a 4 hour session presented by Colleen Bayard, HCA’s Director of Clinical and Regulatory Affairs, that will review the  Conditions of Participation, Medicare and Medicaid requirements for home health care, as well as, an update on Face to Face, components needed for physician orders, Medicare’s undated definition of homebound, differentiating Medicare as an health insurance vs. quality oversight, therapy re-assessment update and more.
    • To register for this meeting click HERE.

For more information on all of our upcoming events be sure to go to our calendar on our website at

Hope to see you there!

For any questions contact Megan Fournier at or by phone at 617-482-8830.