In The News

New PDGM Adjustments Make It Tougher to Reach ‘Medium’ or ‘High’ Functional-Impairment Levels

Home Health Care News | By Joyce Famakinwa
Home health operators have to navigate numerous regulatory and policy changes to stay in business.
Two major ones surfaced within days of each other last week. The U.S. Centers for Medicare & Medicaid Services (CMS) released the home health final payment rule on Nov. 2, then the federal government announced COVID-19 vaccination requirements for health care workers on Nov. 4.
Mary Carr, vice president for regulatory affairs at the National Association for Home Care & Hospice (NAHC), offered insight into both during a Monday webinar.
Among its provisions, the final rule made an adjustment to the Patient-Driven Groupings Model (PDGM), established a 3.2% increase to the home health Medicare rate for next year and finalized the nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) Model.
The base payment rate for 2022 is going to be increased by a net market basket
index of 2.6%. The overall 3.2% rate increase is a substantial bump from the 1.8% CMS originally proposed in June.
“This was a nice surprise,” Carr said. “This is a reflection of an annual inflation update of 3.1%, reduced by 0.5% of productivity adjustment. And that’s where we get our net of 2.6%.”
Carr noted that this means the base 30-day payment rate under PDGM is increased from $1,901.12 to $2,031. 64.
“Now, if you calculate [it out], that’s going to be a little more than 2.6%,” she said. “The reason for that is there are some budget-neutrality gestures that get thrown back into the base rate. CMS has done some recalibration of the case-mix weights … and the wage-index budget neutrality. CMS always recalibrates the wage index annually.”
CMS’ recalibration of the case-mix weights was based on 2020 data, which raises some concerns, according to Carr.
“As I’ve noted, 2020 data was a little skewed with a public health emergency, but CMS insisted that this was appropriate and accurate,” she said.
Although there were changes to case-mix weights, low-utilization payment adjustment (LUPA) thresholds under PDGM remained the same.
CMS did make updates to functional-level points thresholds. This includes decreasing points on several of the OASIS scores and decreasing the threshold level for level of impairment.
“What this means is the same patient in 2021 that had a certain functioning level probably will have a lower score in 2022,” Carr said. “It’s going to take more functional disability to get to a ‘medium’ or ‘high’ using these new adjustments.”
Another change in the final rule was an update to the comorbidity subgroups. The “low” comorbidity group now has 20 categories total, an increase from 10 last year. The “high” comorbidity group is up to 85 interactive subgroups.

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Star Rating Coming for Hospices and Other CAHPS Updates

From the National Association for Home Care & Hospice (NAHC)

The Centers for Medicare and Medicaid Services (CMS) finalized the addition of a CAHPS hospice survey star rating for the hospice quality reporting program in the FY2022 hospice final rule, and the star rating will be publicly reported on Care Compare in August 2022. CMS is calling this star rating the “Family Caregiver Survey Rating Summary star” and hospices with 75 or more completed surveys over the reporting period will have their star rating publicly reported. The rating is the weighted average of the star ratings for each of the eight CAHPS hospice survey quality measures for a hospice.

Hospices will have the opportunity to see their CAHPS Hospice Survey Star Ratings in their official CMS Preview Report during the provider preview period prior to each update of Care Compare. Hospices will first see their Star Ratings in their Preview Reports during the preview periods for the February 2022 and May 2022 updates of Care Compare, which will be a “dry run.” CAHPS Hospice Survey Star Ratings will not be publicly reported in February or May 2022. The reporting period for the dry run is October 1, 2018 – December 31, 2019; July 1, 2020 – March 31, 2021.

The Star Rating for hospices is similar to Star Ratings in other provider types in that it consists of five stars with a range of the lowest score of one star to the highest score of five stars. According to the state and national distribution data posted on the CAHPS hospice survey website for the “dry run” period, the majority of hospices received a rating of 3-stars or 4-stars with 35% and 39% respectively.

CMS will provide more information on the star rating in its Home Health, Hospice & DME Open Door Forum (ODF) on November 10 (see previous NAHC Report coverage here). Until then, some information has been posted to the CMS CAHPS Hospice Survey website including:

NAHC is reviewing these documents and will provide a summary over the coming days.

In CAHPS Hospice Survey related updates, CMS recently posted the survey national percentiles for the measures for the Quarter 4 2018 – Quarter 4 2019; Quarter 3 2020 – Quarter 1 2021 public reporting period.  The average measure scores for each state for this same period are available as is the case-mix adjustment methods for CAHPS hospice survey measures document and the most recent CAHPS hospice survey response rate.


New CMS Resources Available: Job Aids 

The Centers for Medicare & Medicaid Services (CMS) is offering companion job aids to assist providers in the assessment and coding of Job Aids – GG0130A. Eating, GG0130B. Oral Hygiene, GG0130C. Toileting Hygiene, GG0130E. Shower/Bathe Self, GG0130F. Upper Body Dressing, GG0130G. Lower Body Dressing, and GG0130H. Putting On/Taking Off Footwear. The job aids provide clinically relevant information to assist providers in understanding specific guidelines and clinical considerations that should be applied to coding GG0130. Self-Care items. These training assets are intended for the following post-acute care (PAC) settings: Home Health Agencies (HHAs), Inpatient Rehabilitation Facilities (IRFs), Long-Term Care Facilities (LTCHs), and Skilled Nursing Facilities (SNFs). The training materials are available under the Downloads section of the Quality Reporting Program (QRP) Training page for each setting:

If you have questions about accessing the resources or feedback regarding the trainings, please email the PAC Training mailbox ([email protected]). Content-related questions should be submitted to the setting specific help desk:


Alerts on Aromatherapy Spray, Probiotic Products, and Supplements

Federal agencies have recently issued important alerts or advisories about the safety or deceptive marketing of several complementary health products.



About one in five health-care workers has left medicine since the pandemic started. This is their story—and the story of those left behind.

The Atlantic / By Ed Yong

The moment that broke Cassie Alexander came nine months into the pandemic. As an intensive-care-unit nurse of 14 years, Alexander had seen plenty of “Hellraiser stuff,” she told me. But when COVID-19 hit her Bay Area hospital, she witnessed “death on a scale I had never seen before.”

Last December, at the height of the winter surge, she cared for a patient who had caught the coronavirus after being pressured into a Thanksgiving dinner. Their lungs were so ruined that only a hand-pumped ventilation bag could supply enough oxygen. Alexander squeezed the bag every two seconds for 40 minutes straight to give the family time to say goodbye. Her hands cramped and blistered as the family screamed and prayed. When one of them said that a miracle might happen, Alexander found herself thinking, I am the miracleI’m the only person keeping your loved one alive. (Cassie Alexander is a pseudonym that she has used when writing a book about these experiences. I agreed to use that pseudonym here.)

The senselessness of the death, and her guilt over her own resentment, messed her up. Weeks later, when the same family called to ask if the staff had really done everything they could, “it was like being punched in the gut,” she told me. She had given everything—to that patient, and to the stream of others who had died in the same room. She felt like a stranger to herself, a commodity to her hospital, and an outsider to her own relatives, who downplayed the pandemic despite everything she told them. In April, she texted her friends: “Nothing like feeling strongly suicidal at a job where you’re supposed to be keeping people alive.” Shortly after, she was diagnosed with post-traumatic stress disorder, and she left her job.

Since COVID-19 first pummeled the U.S., Americans have been told to flatten the curve lest hospitals be overwhelmed. But hospitals have been overwhelmed. The nation has avoided the most apocalyptic scenarios, such as ventilators running out by the thousands, but it’s still sleepwalked into repeated surges that have overrun the capacity of many hospitals, killed more than 762,000 people, and traumatized countless health-care workers. “It’s like it takes a piece of you every time you walk in,” says Ashley Harlow, a Virginia-based nurse practitioner who left her ICU after watching her grandmother Nellie die there in December. She and others have gotten through the surges on adrenaline and camaraderie, only to realize, once the ICUs are empty, that so too are they.

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