Full analysis of the proposed CY2025 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Requirements Proposed Rule, released on the Federal Register public inspection site on June 26^th and scheduled for publication in the Federal Register on July 1st, can be found in this article.

As the Centers for Medicare and Medicaid Services (CMS) has done in the past, the agency slipped reporting requirements impacting nursing homes into the Calendar Year (CY) 2025 Home Health Prospective Payment System (PPS) proposed rule. The proposals to extend weekly National Healthcare Safety Network (NHSN) reporting for nursing homes would, if included in the final rule, extend nursing homes’ reporting requirements indefinitely. The proposed rule contains a modification of reporting requirements that would expand required elements to include data on influenza and respiratory syncytial virus (RSV). It also contains provisions that would allow CMS to require additional reporting in the future without notice and comment rulemaking should it be determined that an acute respiratory illness public health emergency is occurring or a significant threat of one exists. This action is in direct contradiction of LeadingAge’s May 31 advocacy which “urges CMS to allow reporting requirements to expire on December 31, 2024, without modification or further requirements for nursing home COVID data reporting through the NHSN system” and to significantly modify NHSN reporting.

Read more on CMS’ proposal here. As part of the CY 25 Home Health proposed rule, these provisions have a 60-day comment period during which LeadingAge will be submitting comments.

In a June 26 statement, LeadingAge President and CEO Katie Smith Sloan pointed out that the CY2025 Home Health Proposed Payment Rule, which includes a proposed cut of 1.7% to home health providers, puts older adults and their families at risk of losing access to needed care and services.

“Put today’s action from the Centers for Medicare and Medicaid Services (CMS) into context: Registered nurses (RNs) are a core component of home health care,” Sloan said. “Our mission-driven and nonprofit members battle daily in a very competitive labor market to recruit and retain RNs, which are in short supply. Coupled with the Biden administration’s nursing home staffing rule’s nurse-onsite 24/7 component, already stiff competition for RNs will only grow.”

Read the entire statement here.

Please make sure to register for the Home Health Member Network. Our next meeting will be Tuesday, July 2, at 2 p.m. ET and we will be discussing the proposed rule.

The Office of Management and Budget (OMB) completed its review of the CY2025 Home Health Proposed rule on Monday, June 24. LeadingAge anticipates the rule will be published for public inspection on June 26 and we will notify members as soon as it becomes available.

Please make sure to register for the Home Health Member Network. Our next meeting will be Tuesday, July 2, at 2 p.m. ET and we will be discussing the proposed rule.

The Centers for Medicare and Medicaid Services submitted CY 2025 Home Health Prospective Payment System Rate Update and Home Infusion Therapy and Home IVIG Services Payment Update (CMS-1803) proposed rule to the Office of Management and Budget (OMB) for review on April 26.

OMB’s review is the final step before approval and publication of any proposed or final rules. It is likely the home health proposed rule will be published by the Juneteenth or the July 4 holiday.