Fall 2024 Compliance Update: Essential CMS Changes for Hospice and Home Health

As we enter the fall season, it's the perfect opportunity to reassess and prepare for the latest updates from the Centers for Medicare & Medicaid Services (CMS). These regulatory changes will impact both hospice and home health agencies in significant ways. To keep your agency compliant and well-positioned for success, here’s a rundown of the critical updates you need to know for 2024.

Final Rules for Hospice Care

1. Payment Rate Increase: CMS has updated the hospice payment rate by 3.1% for FY 2024, resulting in an estimated increase of $780 million across the board. However, the stakes are higher for agencies that fall short on quality reporting—those not meeting the requirements will face a 4% reduction in their payment updates. This makes it essential to review your reporting processes and ensure compliance(Centers for Medicare & Medicaid Services).

2. Physician Enrollment Requirement: Starting May 1, 2024, any physician certifying hospice eligibility must be enrolled in Medicare or validly opted out. This new requirement is part of CMS's broader strategy to combat fraud and improve quality standards. Ensure that your certifying physicians meet these requirements to avoid any disruptions in payment(Centers for Medicare & Medicaid Services).

3. Extension of Telehealth Services: CMS has extended the use of telehealth services for hospice recertifications through December 31, 2024. This provides agencies with continued flexibility in providing care but also requires adherence to updated telehealth regulations to ensure compliance(Centers for Medicare & Medicaid Services).

Final and Proposed Rules for Home Health

1. PDGM Recalibration (Final Rule): CMS has finalized the recalibration of the Patient-Driven Groupings Model (PDGM) using 2022 data. This affects payment structures, including case-mix weights and Low Utilization Payment Adjustment (LUPA) thresholds. Agencies need to review these changes to ensure their billing practices align with the updated model(Centers for Medicare & Medicaid Services).

2. Quality Reporting Program Changes (Proposed Rule): CMS has proposed several changes to the Home Health Quality Reporting Program (HH QRP) for 2025. New measures include tracking the percentage of patients up-to-date with COVID-19 vaccinations and implementing the Functional Discharge Score. CMS also proposes removing outdated measures to streamline the program. These proposed changes aim to enhance patient care quality and align with public health priorities(Centers for Medicare & Medicaid Services).

3. Value-Based Purchasing Model Enhancements (Proposed Rule): CMS has proposed updates to the Home Health Value-Based Purchasing (HHVBP) Model, set to take effect in January 2025. These changes focus on rewarding agencies based on the quality of care provided, emphasizing improved patient outcomes. The proposed rule also includes changes to individual measure weights and the baseline year for the model(Centers for Medicare & Medicaid Services).

Health Equity Focus (Final and Proposed Updates)

CMS is actively working to advance health equity in both hospice and home health settings. This includes finalized rules that emphasize health equity in quality reporting and proposed rules aiming to incorporate these principles into the HHVBP Model. Agencies are encouraged to integrate health equity considerations into their care delivery to meet CMS's broader goals(Centers for Medicare & Medicaid Services)(Centers for Medicare & Medicaid Services).

Action Steps for Your Agency

• Ensure all certifying physicians are enrolled in Medicare .
• Reassess your quality reporting practices to avoid potential penalties.
• Update your telehealth protocols to align with the extended services for hospice recertification.
• Prepare for changes to case-mix weights and quality measures in home health services to maintain optimal reimbursement levels.
• Incorporate health equity measures into your agency’s care delivery to align with CMS's growing focus on fairness and accessibility.

My name is Irene Soirassot-Joseph MSN, RN , and I bring over 20 years of experience in home health and hospice care to the table. I understand the challenges of managing patient care while maintaining precise and compliant documentation. My goal is to assist agencies in optimizing their documentation processes, minimizing billing issues, and ensuring that they can focus on delivering high-quality care. Let’s work together to make your documentation a strength, not a burden.

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