The Centers for Medicare and Medicaid Services (CMS) released the 2025 Home Health Proposed Rule (CMS-1803-P) on June 26, 2024. The comment period for the rule is currently set to expire on 08,26,2024. Homecare Homebase has compiled a brief summary of the information found in the proposed rule, along with links and helpful tools.
CMS 2025 Home Health Proposed Rule Resources
CMS 2025 Home Health Proposed Rule – At a Glance
The HCHB team has pulled together some quick highlights from the rule. Take a look at this summary and dive into the rule itself to learn more. Homecare Homebase encourages all home health agencies to write comment letters and add their voice to those advocating for the industry.
- Estimates the overall economic impact to be -$280 million (-1.63%) due to the effects of the following: the CY 2025 proposed home health payment update percentage of 2.5% ($415 million increase), an estimated 3.6% decrease that reflects the effects of the permanent behavior assumption adjustment ($595 million decrease), and an estimated 0.6% decrease that reflects the effects of an updated FDL ($100 million decrease).
- The estimated 3.6% decrease related to the proposed behavior assumption adjustment includes all payments, while the proposed -4.067% BA adjustment only applies to the national, standardized 30-day period payments and does not impact payments for 30-day periods which are LUPAs.
- Proposes updates to:
- LUPA thresholds
- Case-mix weights
- Functional impairment levels
- Comorbidity adjustment subgroups
- Wage index
- FDL Ratio
- 30-Day period payment rates
- Per-visit payment rates
- dNPWT device payment rate
- Intravenous immune globulin (IVIG) items and services payment rate
- Proposes updates to the OT, PT, SLP, and SN LUPA Add-On Factors.
- Proposes to collect four new items and modify the Transportation item in the standardized patient assessment data elements in the social determinants of health (SDOH) category.
- Proposes to change all-payer data collection to begin with the start of care OASIS data collection timepoint instead of the discharge timepoint.
- Requests feedback on future HHVBP performance measure concepts including:
- Composite measures for vaccinations
- Health equity approaches
- Integrating related performance measures
- Proposes to require HHAs to develop, implement, and maintain an acceptance to service policy that is applied consistently to each prospective patient referred for home health care.
- Requests feedback on whether CMS should permit rehabilitative therapists to conduct the initial and comprehensive assessment for cases that have both therapy and nursing services ordered as part of the plan of care.
- Requests feedback on other factors that influence the patient referral and intake processes.
HCHB is committed to helping our clients successfully navigate the complexities associated with regulatory and industry changes. Every year, the proposed and final rules for Hospice and Home Health are analyzed by The HCHB Product Management team to plan for needed changes to the software. In addition, HCHB Analytics users receive access to the Home Health Revenue Impact Model. This dashboard reflects the potential affects the proposed rule may have on a user’s organization.
Ready to learn more about how the proposed rule could affect the industry as a whole? Join our webinar with Pennant Group’s President and Chief Operating Officer, John Gochnour and Chief Strategy Officer for Homecare Homebase Scott Pattillo to dive into the impacts of Medicare Advantage and the proposed rule.
