CY 2025 Home Health Prospective Payment System Proposed Rule Summary

On June 26, 2024, CMS placed the calendar year 2025 Home Health Prospective Payment System proposed rule on public display. The proposed rule was published in the Federal Register on July 3, 2024. The proposed rule updates the payment rates for home health agencies (HHAs), disposable negative pressure wound therapy devices, and intravenous immune globulin items and services for 2025. In addition, this proposed rule provides information on home health utilization trends to monitor the effect of the Patient-Driven Groupings Model (PDGM). CMS also proposes a permanent prospective behavior adjustment to the 2025 home health payment rate to account for the impact of the implementation of the PDGM. This adjustment accounts for any changes in aggregate expenditures resulting from the difference between assumed behavior changes and actual behavior changes, due to implementation of the PDGM and 30-day unit of payment.

For the Home Health Quality Reporting Program (HH QRP), CMS proposes to adopt four new OASIS items and a modification to an existing OASIS item, as well as an update to the removal of the suspension of OASIS all-payer data collection. CMS also seeks information on future HH QRP quality measure concepts. For the Expanded Home Health Value-Based Purchasing (HHVBP) Model, CMS includes a Request for Information related to the future measure concepts for the expanded HHVBP Model and provides an update on potential future approaches for integrating health equity in the Model.

CMS estimates that the net impact of the proposed policies would decrease Medicare payments to HHAs in 2025 by -1.7 percent (-$280 million). This decrease reflects the effects of the proposed +2.5 percent home health payment update, an estimated 3.6 percent decrease from the proposed permanent adjustment of -4.067 percent, and an estimated 0.6 percent decrease from the proposed update to the fixed-dollar loss ratio used in determining outlier payments. The deadline for public comment is August 26, 2024.