CMS releases proposed 2020 Rule

Final Rule for 2020 would affirm PDGM for next year, eliminate RAPs by 2021

Home care providers can expect a 1.3 percent increase in reimbursement next year, totaling some $250 million, along with the implementation of a complex new payment system based on patient characteristics. A proposed version of the Final Rule for 2020 was made public Thursday afternoon by The Centers for Medicare and Medicaid Services (CMS), and is available for viewing here. One of the biggest changes outlined in the document would not actually take place until 2021, when agencies would no longer receive partial payments up front for an episode of care.

Currently, home care providers receive a percentage of the total episode payment at the beginning of an episode of care and submit a claim for the remainder at its completion. The Final Rule proposes for, these Requests for Anticipated Payment, known as RAPs, to be phased out in 2020.

“RAPS are completely going away by 2021,” said J’non Griffin, owner and president of Home Health Solutions Inc. “But this isn’t exactly a surprise, as CMS has already been moving in this direction.”

Much of the content in the 2020 Final Rule centers around the Patient-Driven Groupings Model (PDGM) which will replace the current payment system on Jan. 1, 2020, ushering in 30-day billing periods and a new case mix methodology based on patient characteristics such as primary diagnoses, admission source, co-morbidities and functional status.

“We’re still reviewing the meat of the proposed rule right now to determine whether there are any surprises,” J’non said. "It will take a little bit to review it in its entirety, but we'll make available our findings."


Here are some of the highlights in the Final Rule, based on a quick perusal:

Physical therapy assistants would be allowed to furnish maintenance therapy

Changes would be made to performance data which must be reported by the nine states in the Home Health Value-Based Purchasing Model

A home infusion therapy benefit would be implemented in 2021, allowing home care providers to administer some treatment in the home that now requires patients to travel to clinics or doctor’s offices

The Final Rule document is is scheduled to be published in the Federal Register on 07/18/2019.