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Rule changes affecting home health agencies in 2023

Dec 11, 2022

The calendar year (CY) 2023 home health final rule is out. Although it’s not exactly what home health agencies hoped for, there are some positive takeaways.

The bottom line is a 0.7% increase in the standardized payment — a reprieve from the proposed 7.69% permanent adjustment.

Here is a brief overview of the other changes:

  • A CY 2023 rate reduction at 3.925%
  • A net inflation update of 4%
  • An increase in the standard national payment rate from $2,031.64 to $2,010.69
  • Recalibration of the 432 case-mix weights
  • Implementation of a 5% cap on negative changes in the area-specific wage index
  • All-payer OASIS data for the Home Health Quality Reporting Program for CY 2025
  • A Home Health Value-Based Purchasing change in baseline year to CY 2022, starting in CY 2023 and applying to agencies that were certified prior to January 1, 2022
  • Three new G-codes to capture telecommunication visits on claims
  • An update of the Home Infusion Therapy Rates for CY 2023

We encourage clients to read the whole rule by following the link here. A copy of the fact sheet which accompanied the rule is available here.

Temporary retrospective and permanent prospective adjustment

The final aggregate adjustment to home health payments in CY 2023 will be 0.7% — a $125 million increase compared to the previous year. This number reflects the inflation updates, rate reduction, behavioral adjustment and proposed update to the fixed-dollar loss ratio.

CMS intends to phase in these cuts over the course of two years, implementing 3.5% in CY 2023.

The inclusion of the adjustment to all payments of seven percentage points is not without controversy. The industry still has concerns regarding the continued reliance on the flawed budget neutrality methodology.

New G-codes will capture telecommunication visits

Starting on or after January 1, 2023, CMS will require reports on the use of telecommunications technology in providing home health services on home health claims. (Agencies may begin voluntarily reporting starting January 1, 2023.)

To submit the information, use the following three G-codes:

  • G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
  • G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
  • G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)

You can only report the above three G-codes on Type of Bill 032x. You should only report these codes with revenue codes 042x, 043x, 044x, 055x, 056x and 057x.

Each service is to be reported as a separate dated line under the appropriate revenue code for each discipline providing the service.

For remote patient monitoring, reports require a single line item showing the start date and the number of days monitoring in the units field. Services provided via telecommunications technology will be reported in line-item detail.

Agencies should document how telecommunications technology helps to achieve the goals outlined in the plan of care in the medical record.

Updates on home office cost reports filing

If your agency is required to file a home office cost report, be aware that CMS has posted transmittal 1, which introduces Chapter 48, Home Office Cost Statement, Form CMS-287-22, in the Medicare Provider Reimbursement Manual, Part 2. This implements an electronic reporting requirement for the home office cost statement.

It is effective for cost reporting periods beginning on or after October 1, 2022.

OASIS-E changes

OASIS is a group of standard data elements that can be integrated into comprehensive assessment to collect and report quality data to CMS. Currently, OASIS data is collected for skilled Medicare and Medicaid patients 18 or older, except those receiving prenatal or postnatal care. This will be expanded to all payers in 2025.

Additionally, OASIS will play a key role with patient outcomes in the upcoming value-based purchasing environment. OASIS information will serve as a primary data source in calculating up to a 5% bonus or 5% reduction in reimbursements.

The OASIS-E instrument was revised to increase standardization across post-acute care settings. Revisions include a standardized quality measure that can be used across different settings. It also uniformly collects social determinants of health data.

The use of OASIS-E is required, beginning January 1, 2023. Therefore, exceptional OASIS skills must be a priority for every clinician. Providing professional staff members with a high level of OASIS-E education and assessment strategies will significantly boost patient outcome levels.

How can Wipfli help?

Wipfli advisors are prepared to help you navigate the complex rules and polices that affect your agency’s resource management and delivery of services. Learn more about the upcoming changes related to the implementation of OASIS-E by viewing our recent webcast OASIS E: What you Need to Know Now.

At Wipfli, we are ready to help you address these challenges and drive your agency to excellence. Contact a member of our dedicated healthcare team today to get started.

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Brian Lebanion, MBA, CPC, RNC
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