Is your Home Health Agency ready for PDGM?
Change is coming. Is your home health agency (HHA) ready? The Centers for Medicare and Medicaid (CMS) recently announced a change coming in 2020 to the payment rate structure for home health agencies. The proposed rule brings other changes as well, changes you and your team need to be ready to implement. Its all part of the Patient-Driven Groupings Model (PDGM) that CMS says will drive better patient care based on patient needs and not the volume of care. In this article we’ll summarize the proposed changes. We’ll also offer up a short suggested to do list for any home health agency wondering where to start.
First, a look at some of the key changes for HHAs that take effect in January of 2020:
-Change the way episodic payments to home health agencies are made from a 60-day time frame to 30 days.
-Change in-home infusion therapy payment rates: temporary transitional payment rates for 2020, new permanent home infusion therapy rates to take effect in calendar year 2021.
-Home infusion therapy proposed payment changes:
-Three payment categories for home infusion drugs
-Payment rates to factor in geographic location (Geographic Adjustment Factor (GAF))
-Higher payments for first home infusion therapy visit, small decrease in payment for each visit after that
-Phase out Requests for Anticipated Payment (RAP) in an attempt to curb any potential program integrity possibilities.
-In an effort to improve access to care, allow therapy assistants to provide maintenance therapy. The change would be consistent with regulations for skilled nursing facilities.
-Adopt new quality measures to evaluate the effective transfer of home health information with the goal of improved patient safety and accurate medication lists.
-Adopt new patient assessment data including:
- Cognitive function
- Mental status
- Special services
- Treatments and interventions
- Medical conditions and comorbidities
- Social determinants of health
-Remove pain-related quality measures in an attempt to avoid over-prescription of opioids.
-Public report of Total Performance Scores (TPS) for home health agencies which could lead to better, more objective comparisons of caregivers and incentives for improved performance of HHAs.
“Most larger home health organizations are likely already well on their way to compliance ahead of the January 2020 adoption of the proposed rule,” says Gilmore Jasion Mahler Healthcare Specialist Jamie Dixon, CPA. “I’m already talking with my clients about this, they know it’s happening and are already preparing. It’s the smaller home health agencies with fewer resources that I am worried about.”
Jamie’s worked in the healthcare space for many years. A member of the Gilmore Jasion Mahler Healthcare Specialist Team, his focus areas include home health, hospice and skilled nursing. His experience includes Medicaid and Medicare reimbursement consulting, cost report preparation and review as well as specialized accounting issues related to healthcare entities.
He suggests three priorities for any HHA that doesn’t know where to start in preparing for the new regulations.
- Talk to your vendors. Make sure they’re aware of the changes.
- Make sure your billers are trained on the new system.
- Rely on trusted resources to learn more.
“In my mind, #3 is especially important,” says Dixon. “Your agency’s accounting firm should definitely be one of those trusted resources. I’m having a lot of conversations right now with my home health clients. Sometimes they just need to run something by me to get my take. Other times I’m more involved in driving decisions. This is a big change that involves some serious planning. Now is the time to prepare, so that when year-end comes, you’re ready for PDGM.”
You can learn more about the home health Patient-Driven Groupings Model (PDGM) on the CMS website where you’ll find several resources for home health agencies.
Established in 1996, Gilmore Jasion Mahler, LTD (GJM) is the largest public accounting firm in Northwest Ohio, with offices in Maumee and Findlay. Locally owned, GJM offers cloud-based accounting and provides comprehensive services including assurance, business advisory, tax, risk advisory, healthcare management and outsourced accounting. The Firm’s professionals specialize in industries including construction & real estate, healthcare, manufacturing & distribution and utilities.