CMS Announces Medicare Home Health Proposed Payment Rates and Policies for 2025

July 3, 2024

The Centers for Medicare & Medicaid Services (CMS) has issued a proposed rule for 2025 that would continue payment reductions to the home health sector. These payment cuts are a result of the imbalance between the cost of delivering care and Medicare payments. CMS data indicates that payments to home health agencies are, on average, 32% higher than the cost of delivering care. As a result, if finalized, payment rates to the industry will be decreased by approximately 4% in 2025. However, given the annual inflationary update provided to the sector, the overall negative impact is estimated to be a 1.7% payment reduction. CMS also noted that its data continues to show a decrease in therapy provision since the new payment methodology, the Patient-Driven Groupings Model (PDGM), was implemented on January 1, 2020.

CMS noted that the national average speech-language pathology payment rate for 2025 will be $204.86. The physical and occupational therapy per visit payment rate is projected to be $188.46 and $189.75, respectively. Preliminary data collection on the use of home health telehealth also indicates that its use is relatively limited for speech-language pathology, particularly compared with physical therapy. But this is not especially surprising given that Medicare does not pay for services provided via telehealth in this setting.

CMS also proposes a new condition of participation that would require home health agencies (HHAs) to develop a "patient acceptance service policy" that is applied to each prospective patient referred for home health care. The policy must address, at a minimum, the HHA's capacity to provide patient care-including the anticipated needs of the referred prospective patient-the HHA's caseload and case mix, the HHA's staffing levels, and the skills and competencies of the HHA staff.

ASHA is reviewing the proposal and working to determine the impact of this policy. Ensuring the policy does not impose an undue administrative burden on agencies and their clinical staff is an important consideration. However, ASHA regularly hears from its members working in home health care that speech-language pathology services are not always provided consistent with a plan of care. We also hear from patients who have trouble accessing speech-language pathology services through home health due to staffing shortages and other factors such as the HHA failing to provide them despite the recommendation of their multidisciplinary care team. ASHA is invested in ensuring HHAs are held accountable for providing all the services a Medicare patient needs as required under federal law and regulation.

CMS is also seeking feedback on a request for information regarding whether physical and occupational therapists and speech-language pathologists should be allowed to open therapy and nursing cases. At this time, therapists are only allowed to open "therapy-only" home health cases.

Finally, CMS proposes to require HHAs to report data associated with COVID-19, the flu, and respiratory syncytial virus to the Centers for Disease Control. CMS also proposes to add four new and one updated social determinants of health (SDOH) items associated with living situation, food security, ability to pay utilities, and access to transportation. ASHA understands the importance of collecting SDOH data to support optimal health outcomes and advocates to ensure that policymakers understand and support the critical role clinicians play in identifying SDOH factors that impact patient care.

What's Next?

ASHA will submit comments to CMS on the proposed rule by August 26, 2024. CMS is expected to release the final rule in early November for implementation on January 1, 2025.

Resources

• Review the CMS fact sheet on the 2025 proposed rule.
• Learn more about the Medicare home health prospective payment system.
• Questions? Contact ASHA's health care and education policy team at [email protected].