Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2025 Home Health Prospective Payment System (HH PPS) proposed rule. In our comments, we urge CMS to:
- Advance a final rule that results in significant home health payment increases for CY 2025;
- Revise its existing definition of infusion drug administration calendar day to allow for reimbursement of home infusion professional services each day that an infusion drug physically enters the patient’s body, irrespective of whether a skilled professional is in the individual’s home;
- Address persistent issues that may limit the ability of providers to report social determinants of health (SDOH) data elements and ultimately the accuracy of this data;
- Expand value-based purchasing measures through the Universal Foundation initiative that uses quality measures that apply to as many CMS quality-rating and value-based care programs as possible;
- Reward home health agencies with a health equity adjustment through a methodology that sets a 70 percent payback percentage each year under the value-based purchasing model; and
- Work with Congress to advance incentives for interoperable electronic health information technology to support efficient reporting for long-term care facilities, including the acute respiratory illness data reporting proposal.