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CMS proposes 1.3% pay increase for home health but is ending prepayment of services

While CMS says it is now allowing therapist assistants to perform services, Premier says the agency's definition requires a skilled professional.

Susan Morse, Managing Editor

The Centers for Medicare and Medicaid Services is proposing to give home health agencies a $250 million, or 1.3 percent, Medicare payment increase.

In "significant changes" to the Home Health Prospective Payment System released on Thursday, CMS is also proposing to phase out pre-payments for home health services, have a new home infusion benefit and allow therapist assistants to perform maintenance therapy.

Request for anticipated payment, or RAP, would be phased out over the next year and eliminated completely for 2021.

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The reason is CMS and law enforcement have seen a marked increase in RAP fraud schemes perpetuated by existing home health agencies that receive significant upfront payments, never submit final claims and then close for business. 

CMS said it believes that phasing out RAPs over one year would help mitigate home health agencies' cash flow concerns.

The proposed rule also implements the permanent home infusion therapy benefit in 2021, as required under the 21st Century Cures Act. This will give beneficiaries the option to receive infusion drug therapies at home, such as anti-infectives, chemotherapy or treatment for immune deficiencies, instead of in a hospital or doctor's office.

Home infusion therapy -- the administration of certain types of medication using a durable medical equipment pump -- includes professional services, patient education and training and monitoring of patient care.

Also, in response to public feedback through its Patients Over Paperwork Initiative, CMS is proposing to allow therapist assistants to perform maintenance therapy, rather than only therapists, which would allow them to practice at the top of their state licensure, give flexibility to home health providers and improve beneficiary access to these services.

However, the healthcare company Premier said CMS continues to stipulate that the services be done by a skilled professional. CMS continues to define "infusion drug administration calendar day" for the home infusion therapy services temporary transitional payment to mean payment "for the day on which home infusion therapy services are furnished by skilled professional(s) in the individual's home on the day of infusion drug administration." This is limiting payment for both the transitional and permanent benefit to those scenarios in which there is a skilled professional present. Premier said. 


The rule aims to reduce fraud, reduce cost through home infusion and improve care.

It continues CMS efforts to implement a new case-mix payment methodology, the Patient-Driven Groupings Model, which puts the focus on patient needs by relying more heavily on patient characteristics rather than volume of care to pay for home health services. 


"We are proud to announce the new permanent home infusion therapy benefit that will give patients the freedom to safely access critical treatments, such as chemotherapy, at home instead of traveling to the hospital or doctor's office, improving their quality of life," CMS Administrator Seema Verma said.

"Premier has long advocated for comprehensive home infusion reform to provide high quality patient care in the most clinically appropriate and cost-effective care settings," said Blair Childs, senior vice president of Public Affairs, for Premier. "However, CMS continues to misconstrue how home infusion services are provided by restricting payment to when a skilled professional is in the patient's home. CMS' policy runs counter to Congressional intent clearly articulated in the 21st Century Cures Act and Bipartisan Budget Act of 2018 and is contrary to the Administration's goals of decreasing healthcare spending."

Twitter: @SusanJMorse
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