Important Correction to the CY 2025 Final Rule: Neoplasm Subgroup Update
A critical correction notice has been issued regarding the CY 2025 Home Health Prospective Payment System Final Rule. Initially published on November 1, 2024, and subsequently corrected, the rule had an error in the low comorbidity subgroup list. Specifically, the 14th row, referencing “Neoplasms 20 (Non-Hodgkin’s Lymphoma),” was incorrect and has been removed in a further update to the correction notice.
What this means for coding companies: While the official Federal Register document initially contained inaccuracies, it’s vital to note that the Home Health Grouper Software (HHGS) has been updated with the correct subgroups. This ensures that claims are currently being grouped accurately despite the initial publication error. Coding professionals should verify they are utilizing the most up-to-date HHGS software to avoid claim errors related to comorbidity subgroups, particularly concerning neoplasms and Non-Hodgkin’s Lymphoma. Referencing the corrected CY 2025 Final Low Comorbidity and High Comorbidity Adjustment Interactions file available for download is also recommended to ensure coding practices align with the latest CMS guidelines. These policies are effective starting January 1, 2025, making immediate attention to these corrections essential for compliant coding in the upcoming year.
CY 2023 Behavior Change Recap, 60-Day Episode Construction, and Payment Rate Development: Key Takeaways for Coding
In March 2023, CMS hosted a webinar providing a comprehensive overview of several critical aspects of the CY 2023 HH PPS final rule. This session focused on behavior changes observed under the new payment model, the intricacies of 60-day episode construction, and the methodologies behind payment rate development for CY 2023.
Relevance for coding companies: Understanding the nuances of 60-day episode construction is paramount for accurate claim submission. The webinar, detailed further here, likely provided valuable insights into how patient characteristics and care needs are translated into appropriate coding for each 60-day episode. For coding companies, reviewing materials from this webinar can enhance their understanding of the payment model’s mechanics and ensure they are capturing all necessary data points for proper episode grouping and reimbursement. This knowledge is crucial for optimizing revenue cycle management and minimizing claim denials.
2023 Rural Add-on Policy Extension: Implications for Coding in Low Population Density Areas
The Consolidated Appropriations Act, 2023, included a provision extending the 1% rural add-on payment for home health services delivered in counties classified as “low population density.” This extension applies to home health periods and visits concluding in CY 2023. CMS implemented this by increasing the 30-day base payment rates by the 1% rural add-on before applying any case-mix and wage index adjustments.
Coding considerations: For home health care coding companies operating in or servicing rural areas, this policy has direct implications. Coders need to be aware of the counties that qualify as “low population density” to correctly apply the rural add-on when coding and billing for eligible services in CY 2023. While the base payment rates are adjusted, it’s important to note that there are no changes to the fixed-dollar loss ratio, budget neutrality factors, or final base payment rates themselves, aside from the rural add-on application. Accurate geographic coding is essential to capture this additional payment for services provided in qualifying rural locations.
Unified Payment for Medicare-Covered Post-Acute Care: Long-Term Vision and Coding Adaptability
A significant report to Congress was mandated by the IMPACT Act of 2014, focusing on the concept of unified payment for Medicare post-acute care (PAC). This report available in PDF format explores a potential future direction for Medicare PAC payments, aiming to base reimbursement on patient characteristics rather than the care setting itself. Currently, Medicare PAC services, including home health, skilled nursing facilities, inpatient rehabilitation facilities, and long-term care hospitals, operate under separate prospective payment systems.
Strategic perspective for coding companies: While the report doesn’t propose immediate legislative changes, it signals a long-term trend towards potentially unified PAC payment models. For home health care coding companies, this underscores the importance of staying informed about broader healthcare payment reform discussions. A shift towards unified PAC payment could eventually necessitate coding adaptations to accommodate standardized patient assessment data across different PAC settings. Although immediate coding changes are not required, understanding this direction allows companies to strategically prepare for potential future evolutions in PAC payment and coding practices. The appendices to this report offer further detailed information and can be accessed here.
Staying Informed: Home Health Payment Policy Inquiries
For ongoing questions and clarifications regarding home health payment policy, CMS provides a dedicated email address for inquiries: HomehealthPolicy@cms.hhs.gov.
Actionable step for coding companies: Home health care coding companies should utilize this resource to seek direct clarification from CMS on any ambiguities or complex scenarios encountered in interpreting and implementing HH PPS guidelines. Proactive communication with CMS ensures accurate understanding and compliant application of payment policies.
Conclusion: Proactive Adaptation for Home Health Coding Success
The CY 2025 Home Health PPS Final Rule and related updates necessitate continuous learning and adaptation for home health care coding companies. Staying abreast of corrections, understanding the nuances of episode construction and rural add-ons, and monitoring the trajectory of PAC payment models are all critical for sustained success. By proactively incorporating these insights into their practices, coding companies can ensure accuracy, compliance, and optimal reimbursement for the vital services they support in the home health sector.
