Courtesy of the National Association for Home Care & Hospice

On April 13, 2021, the Centers for Medicare & Medicaid Services (CMS) held the Home Health, Hospice, and Durable Medical Equipment Open Door Forum. The majority of information shared with the participants pertained to hospice providers. However, several issues impacting home health agencies were also discussed. A summary of the forum follows.

Home Health Quality Reporting Program (HH QRP)

CMS announced that five measures will be removed from the HH QRP with the July 2021 refresh. Those measures are:

• Depression Assessment Conducted;
• Multifactor Fall Risk Assessment Conducted for All Patients Who Can Ambulate;
• Diabetic Foot Care and Patient/Caregiver Education Implemented During All Episodes of Care;
• Pneumococcal Polysaccharide Vaccine Ever Received; and
• Improvement in Surgical Wounds.

Sometime this summer, CMS plans to provide interim guidance for home health agencies regarding the delay of the Outcome and Assessment Information Set (OASIS) E.

Two new on-demand OASIS training modules have been posted on the website: Section M: Skin Conditions and Section N: Medications – Drug Regimen Review Web-Based Training.

In the fiscal year (FY) 2022 Medicare hospice rate update proposed rule, CMS included a proposal to use only three-quarters of data (Q3-2020, Q4-2020, and Q1-2021) beginning with the January 2022 HH QRP refresh on Care Compare. This proposal impacts OASIS and claims-based measure reporting beginning in January 2020 through July 2024. The proposal will prevent CMS from having to freeze home health quality reporting data beyond 2021 on the Care Compare website.

Claims Processing Issues

Three claims processing issues discussed in the January 26 Open Door Forum have been resolved. Since then CMS has identified three additional claims processing issues that are now resolved as well:

• Home health claims spanning 2020-2021 were applying the incorrect 2021 payment amount;
• Late Request for Anticipated Payment (RAP) penalties were not being applied to outlier claims; and
• Applying the late RAP penalty incorrectly to Home Health Value-Based Purchasing (HH VBP) claims.

CMS shared information on two ongoing claims processing issues:

• Low Utilization Payment Adjustment (LUPA) visits that fall between the "from" date and RAP receipt date are being paid at zero whether the RAP was late or not. CMS will be instructing the Medicare Administrative Contractors (MACs) on a workaround and should correct claims paid in error.
• RAP payments for 2020 claims are not paying correctly. Only the labor portion is being applied. However, the final claim is paying correctly.

CMS announced that the Notice of Admission (NOA) Companion Guide for the 837I has been released and is accessible on CMS' website. A transmittal with the business requirements for the NOA is planned to be released May 3, 2021. A transmittal with updates to Chapter 10 of the Medicare Claims Processing Manual will also be released on or before that date.

Home Health Consumer Assessment of Healthcare Providers and Systems (HH CAHPS)

The data collection dates for the calendar year (CY) 2023 annual payment update are April 1, 2021, through March 31, 2022. CMS encourages all home health agencies to participate in the HH CAHPS data collection. Instructions for participation and to submit an exemption from participation for CY 2023 can be located on the HH CAHPS website.