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LeadingAge

Overview

The rule proposes a payment update of 1.5% mandated by the Bipartisan Budget Act of 2018 but the effects of that can be severely impacted by the design of the behavior assumption adjustment in the Patient-Driven Groupings Model (PDGM) which reduces the proposed rates by just over 8%. Additionally, the proposal includes provisions related to requests for anticipated payments (RAP), therapist assistants providing maintenance therapy, and quality measures and reporting. CMS estimates a $250 million increase in payments to home health agencies in 2020.

CMS will be issuing corrected FY2020 Performance Score Reports no later than August 31. SNFs’ performance scores and value-based incentive payment (VBIP) modifiers may differ from the initial report impacting a SNF's Medicare payments beginning October 1, 2019. SNFs do not need to take any additional action once the corrected reports are available in a SNF’s CASPER folder.  CMS anticipates that rate adjustments using the corrected VBIP modifier will still take effect as previously scheduled on October 1, 2019.

This rule applies prospectively to determine the eligibility of persons wishing to immigrate to the US, obtain a green card to authorize employment or to obtain certain visas. Note that this rule will not be applied to immigrants currently in the country unless or until they seek to change or extend their immigration status.

Payment Update

With updated data, the payment update has changed slightly from the estimates in the proposed rule. Medicare hospice services will receive a 2.6% update based on an estimated inpatient hospital market basket update of 3.0% reduced by a required multifactor productivity adjustment of 0.4%. CMS estimates this to be an aggregate increase of $520 million in FY 2020. After the payment update the hospice cap amount increases to $29,964.78.

SNF QRP

Skilled Nursing Facilities (SNFs) and hospice providers who received a letter of noncompliance for the Quality Reporting Program (QRP) and who wish to have this status reconsidered by CMS to avoid a 2% rate cut must submit their request for reconsideration and related documentation to CMS by 11:59 p.m. PST on August 15, 2019. 

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