CMS Takes Action to Modernize Medicare Home Health with the FY 2019 Proposed Rule

On July 2nd, the Centers for Medicare and Medicaid Services (CMS) released the highly anticipated Proposed Rule set to significantly change the Home Health Prospective Payment System (HH PPS). Within this rule, CMS is proposing changes with the intent to improve access to solutions via remote patient monitoring technology, and to update the overall payment model for home health care.

Two large notable concerns from our beginning stages of review include CMS’ proposal that would change the unit of payment under the HH PPS from 60 day episodes of care to 30 day periods of care, to be implemented in a budget neutral manner on January 1, 2020, and the proposed Patient Driven Groupings Model (PDGM) for home health payments. Also for 2020, Congress mandated that Medicare stop using the number of therapy visits provided to determine payment. In a prior proposed rule, AOTA advocated heavily against an earlier iteration of the PDGM, called the Home Health Groupings Model, that presented a potentially harmful impact on patient access to occupational therapy services as it shifted incentives away from utilizing therapy services and increased the possibility that medically necessary therapy would not be provided to patients for purely financial reasons.

The PDGM is presented by CMS as a model that relies heavily on clinical characteristics and other patient information to allow payments to more closely coincide with patients’ needs.

Stay tuned to Regulatory Affairs updates on this proposed rule, and direct any questions to regulatory@aota.org.

CMS Proposed Changes to HH PPS Fact Sheet

HH Proposed Rule FY 19



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