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November 2021 CMS Open Door Forum Recap

November 2021 CMS Open Door Forum Recap

Courtesy of the National Association for Home Care & Hospice

During the latest Centers for Medicare & Medicaid Services (CMS) Home Health, Hospice, and Durable Medicare Equipment Open Door Forum (ODF) on November 10, the following information and updates were provided for home health providers.

Home health providers should note that CMS has resumed the provider enrollment revalidation process along with some other provider enrollment processes that were temporarily suspended during a portion of the COVID-19 Public Health Emergency (PHE). Click here for more information.

CMS provided a brief overview of the provisions of the CY 2022 home health final rule, including the transition to the national Value-Based Purchasing (VBP) model. There were several questions from participants about the transition to VBP, to which CMS responded that it will make learning resources available to providers in 2022.

Home health agencies should note that OASIS-E will be implemented on January 1, 2023. There have been some questions about this due to the extension of the PHE, but January 1, 2023, is the implementation date regardless of how long the PHE is extended.

CMS discussed Change Request (CR) 12315, which makes changes to original Medicare systems to allow for Low Utilization Payment Adjustment (LUPA) add-on payments to apply if an occupational therapy (OT) visit is the first visit in a period of care. Beginning January 1, 2022, OTs will be permitted to conduct the initial and comprehensive assessments for home health patients, and therefore, are eligible for the LUPA add-on payment. OTs will receive the national per-visit amount for that visit multiplied by 1.6700 for the LUPA add-on amount.

CMS reminded participants of the Notice of Admission (NOA) that home health agencies will be required to submit beginning January 1, 2022. Change Request 12424 updates chapter 10 of the Medicare Claims Processing Manual to include additional instructions for submitting home health NOAs.

CR 12424 includes instructions for the NOA when a beneficiary receives home health services in 2021 that will continue services in 2022, the home health agency shall submit an NOA with a one-time, artificial ‘admission’ date corresponding to the “from” date of the first period of continuing care in 2022. For example, if a period of care begins in 2021 and ends on January 10, 2022, the home health agency is to submit an NOA with an admission date of January 11, 2022, and then submit a claim when the 30-day period of care is over. The home health agency should submit the January 11, 2022, admission date on all subsequent claims until the beneficiary is discharged and another NOA is required.

The CR also addresses situations where a home health agency provides care in a 30-day period of care and then discharges the beneficiary in the next 30-day period of care but does not provide any billable visits in the next 30-day period. Special handling of the patient status code may be needed in these situations.

CMS reminded home health providers that it identified a problem with receiving emails related to the Home Health Quality Reporting Program (HHQRP) annual payment update penalty via the reconsideration email address ( on October 18. The problem was resolved soon thereafter on October 22, 2021. However, CMS is extending the deadline for home health agencies to file a reconsideration to November 17, 2021, at 11:59 PM ET (which represents an additional week).

Home health agencies will see public reporting with the January 2022 Care Compare refresh. For the refresh the home health measures scores will be based on three quarters due to the PHE exemption; claims-based quality measures within this preview report have not been updated as CMS has decided to continue with the data freeze for claims-based measures for an additional six months. This decision will allow CMS more time to analyze the calculation of these measures, given the required comprehensive exclusion of claims data that occurred during Q1 2020 and Q2 2020, and the effect of that missing data on such aspects of measure calculation (e.g., lookback periods and risk adjustment). For the January 2022 Care Compare refresh, CMS will use the November 2020 refresh scores. The provider preview report for this refresh is planned to be released in November 2021.

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