CMS Issues CY 2014 Proposed Home Health Agency Rule


The Centers for Medicare & Medicaid Services (CMS) released a final rule for the Home Health Prospective Payment System (HH PPS) for calendar year (CY) 2014. The final rule will be published in the Federal Register on December 2, 2013. See CMS’ Press Release and Fact Sheet for additional information on the final rule.

The proposed HH PPS rule for CY 2014 was published in the Federal Register on July 3, 2013. CMS estimated that Medicare payments to home health agencies (HHAs) in CY 2014 would be reduced by 1.5%, or $290 million based on proposed policies including: HH PPS Grouper refinements and ICD-10-CM conversion, rebasing the 60-day episode rate, rebasing per-visit amounts and other components of the HH PPS, quality reporting, and cost allocations for home health agency surveys. See CMS’ Fact Sheet for additional information on the proposal.

CMS accepted comments on the proposed rule until August 26. AOTA submitted comments to CMS. We advocated for the role of occupational therapy as an important part of HHA patient care and inquired whether CMS has evaluated the impact of the therapy assessment schedule that was implemented April 1, 2011. We also reminded CMS that occupational therapists must be allowed to open ‘therapy only’ cases is occupational therapy is in the physician’s order. We asked CMS to encourage the Center for Medicare and Medicaid Innovation to test options in the use of occupational therapy to open particular classes of patients to determine is use of other services is thus reduced. In addition, we requested that CMS include specific examples of the occupational therapy policy in the Preamble to the Final Rule and in Chapter 7, Section 30.4 of the Medicare Benefit Policy Manual.

AOTA is currently analyzing the final HH PPS rule and its implications for occupational therapy. Check back soon for further details. We welcome your thoughts at