Beyond The Cuts: What Else Home Health Providers Need To Know About CMS’ Proposed Rule

This article is a part of your HHCN+ Membership

When the U.S. Centers for Medicare & Medicaid Services (CMS) published its FY 2024 home health proposed payment rule, the 2.2% cut immediately became the focus.

But the nearly 300-page rule included dozens of other notable, proposed changes to home health care.

From Home Health Value-Based Purchasing (HHVBP) Model tweaks to a more focused approach on health equity, there are a number of developments that home health providers and stakeholders are keeping an eye on.



One of the major changes CMS included in the proposed rule deals with HHVBP.

Most notably, CMS is proposing to remove five quality measures and add three to the applicable measure set starting in 2025.

The three additions are around discharge function scores, discharges to the community and potentially preventable hospitalizations during home health care coverage.


“There are some significant updates to the VBP, not the least of which is the highest measure, which is currently acute care hospitalizations,” Nick Seabrook, managing principal and SVP of consulting at SimiTree, told Home Health Care News. “CMS is changing that now to potentially preventable hospitalizations. This may be the way to help offset that dynamic where, if you’re an agency that is hospital-based, you may have a higher rehospitalization rate because of the nature of the patients you take and their acuity.”

The new potentially preventable hospitalizations benchmark, Seabrook said, is CMS’ way of introducing a new algorithm that will try to level the playing field across the industry.

Another reason why that change is critical for home health providers to pay attention to is the weight of that measure in the overall VBP calculation.

“It’s still being proposed that 26% of your VBP score is weighted towards that one specific measure,” Seabrook said. “If you’re going to focus on any measure on your value-based purchasing measures, it’s going to be that one.”

Another change includes replacing the OASIS-based discharge-to-community measure with the claims-based discharge community post-acute care measure.

“That’s actually not a bad thing for home health agencies,” Joseph Brence, head of clinical strategy for MedBridge, told HHCN. “I think it aligns with how other discharge function measures are being applied to LTACs, SNFs and it essentially aligns home health to that.”

The proposed rule also includes the replacement of the two total normalized composite measures for self care and mobility. What that will do, Brence said, is place more importance on progress in mobility and self-care ability. It will put more emphasis on the patients as opposed to the appropriate care planning methods used by agencies.

Case mix rates

The rebasing of the case mix rates are also something providers should be aware of.

“There’s some pretty significant movement for some of the clinical groupings,” Seabrook said. “MS rehab: the average case mix went down almost 2%, neurological rehab went down 1.2% and surgical aftercare went down 1%. I would say those three clinical groupings specifically are traditionally the three highest therapy utilizers. I thought it was interesting that they decreased the average case mix rates for those.”

Those decreases should be an ‘ah-ha’ moment for providers that typically have a higher percentage of patients in higher therapy utilizing clinical groupings, Seabrook said.

“They should also expect another cut just from that,” he said. “For the low functional impairment score, the average case mix went up about 1%. Medium went down 0.3%. High went down 0.5%. There’s not a huge movement there, but when you compound the fact that MS rehab, neuro rehab and surgical all went down, you’re looking at another 0.5% on top of the 2.2% cut. So, if I’m a high therapy agency, that’s something that sticks out to me on top of the rate cuts that are already proposed.”

On the flip side, CMS proposed increases to case mix rates for behavioral (1.6%), cardiac (1.6%) and endocrine (1.4%).

Home health aide services

As the industry continues to deal with staffing issues, CMS is starting to solicit comments and more information on how home health aide services are being leveraged under the home health benefit.

“They’re looking to collect more information around barriers or obstacles on things like recruitment of home health aides and retention of home health aides,” Brence said. “We know it’s a highly volatile position, so they’re really trying to understand how we can better equip agencies to leverage home health aides and service delivery.”

CMS data shows there is a decline in home health aide utilization per episode from 2018 until now, Brence said.

“We know that home health aides is a highly challenging position to fill and I think that’s why CMS is getting involved here,” he added. “I suspect that CMS is going to propose some type of solution, whether that be a payment multiplier or something else, to really ensure that home health agencies have what they need and have the most adequate interdisciplinary team that they could have in place, to focus on health equity.”

Companies featured in this article:

, ,