REGULATORY UPDATES
By Cheri Whalen, Regulatory Strategist
CY2020 Home Health Prospective Payment System Final Rule
In the October 31 display copy of the CY2020 Home Health PPS Final rule, CMS adopted most of the proposed regulatory updates with the exception of the following:
- Reduction of the Behavioral adjustment from 8.01% to 4.36%; giving an overall 1.3% increase in HH PPS payment rate from 2019
- 30-day payment rate increases from $1,792.73 to $1,864.03
- Additional updates to the points scoring for the PDGM case-mix
- Update to the Fixed Dollar Loss (FDL) from 0.63 to 0.56
- Split-Percentage payment update was modified from the proposed rule invoking a "good cause" waiver from CMS to vary a final rule significantly from the proposed rule:
- Retained the 20% RAP payment beginning CY2020
- Retained full elimination of split-percentage payments in CY2021, but requires a "no-pay" RAP submission within 5 days of the start of each 30-day period. This includes penalties for untimely submission (just as the Notice of Admission proposal)
- Delays Notice of Admission requirement until CY2022 to allow CMS time to update their systems to disconnect RAP and final claim matching.
- Retains Question 10 of the CAHPS questions ("In the last 2 months of care, did you and a home health provider from this agency talk about pain")
While the update requiring the "no-pay" RAP for CY2021 is a significant change from the proposed rule, CMS provides some burden reduction to documentation requirements. HHAs will only need to provide minimum documentation in order to submit the “no-pay” RAP for each 30-day period.
Further, CMS is allowing HHAs to submit both the RAP for the first 30-day period and the RAP for the second 30-day period (for a 60-day certification) at the same time to reduce provider burden.
We encourage you to take advantage of the upcoming education sessions and virtual training events for PDGM. Contact your client alignment representative for more information and details.