Last month, the U.S. Centers for Medicare & Medicaid Services (CMS) released its home health proposed payment rule for 2025. Since then, home health providers and industry stakeholders have reacted to the proposal’s cuts, as well as other payment factors that could impact the space moving forward.
Though payment factors are top of mind, there are other areas of the proposal that providers should also be paying attention to as well.
One of these areas is the OASIS updates for the home health quality reporting program (HHQRP), which begin in January 2027.
Though 2027 is down the line, providers should begin preparing now, according to J’non Griffin, senior vice president at the home health consulting firm SimiTree.
“I want you to start thinking about how you’re going to start preparing and how you’re going to collect this information,” she said during a recent webinar hosted by SimiTree. “It’ll be on OASIS, but start thinking about how you’ll train your staff.”
In 2027, there will be four additional questions added. The questions focus on living situation, food security and utilities.
Griffin noted that this was an area where social workers could aid providers.
“I’m going to go ahead and advocate for social workers,” she said. “Social workers have kind of fallen off in the past few years [and] really are a very important part of your organization. They can help with things like this, but you have to know it to even make that referral.”
Another OASIS update will be the slight change to the transportation (A1250) question.
The proposed rule also lifts the suspension of all payer OASIS submissions.
Additionally, CMS has invited public comment and a request for information for several things including composite of vaccinations, depression, pain management, substance use disorders, and rehabilitative therapists conducting the initial and comprehensive assessment.
“I strongly suggest that agencies not only comment on everything, but especially comment on [rehabilitative therapists conducting the initial and comprehensive assessment],” Griffin said. “It’s basically saying, if a nurse is on the referral, they have to do the initial and comprehensive assessment. But what this is saying is, if rehab is also there, rehab can do that. They had that temporarily during COVID, but they’re trying to make this a permanent thing.”
Plus, CMS is looking to integrate concepts of health equity into future value-based purchasing program expansion.
“They’re looking at measures for underserved communities, and measures based on provider differences in performance for underserved communities,” Griffin said. “They are measuring based on the worst performing group.”
Griffin considers this a move towards population management.
The proposed rule also includes proposed changes to the home health conditions of participation. Specifically, changes to 484.105.
“These are fairly big,” Griffin said. “It would require agencies to develop, implement and maintain an acceptance to service policy that is applied consistently to each prospective patient referred for home health care. CMS has recognized that agencies are having a hard time because of staffing, trying to maintain that 48 hour period.”
Ultimately, Brian Harris, vice president of financial consulting at SimiTree, pointed out that the proposed rule lines up with recent payment proposals for the industry.
“There is nothing earth shattering, I would say about the general structure of what we’re looking at,” he said during the webinar. “That’s not to say everything’s good. It’s not to say everything’s bad — but it’s following a lot of the same format and building off of a lot of the past rules.”
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