Home Health Proposed Rule: What Agencies Need to Know

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule for home health agencies (HHAs) that would go into effect on January 1, 2024. The rule includes a number of changes, including a 2.2% spending driven by the application of a permanent behavioral adjustment, notable wage index changes to several CBSAs, proposed revisions to Value-Based Purchasing (VBP) measures beginning in CY2025, and changes to the OASIS functional point scoring. Recently, SimiTree experts hosted a complimentary webinar on what these proposed changes would mean for home health agencies, which can be accessed here, and addressed many pressing questions from attendees.


What Does the CMS HHA Proposed Rule Mean? Proposed Rule FAQs

During our webinar on the proposed rule, attendees asked several important questions. Some of the most common questions included:


Is the 2.7% market-basket update in addition to the 2% increase that was applied in 2023?

Yes, the proposed 2024 payment updates are exclusive of any payment updates applied for 2023.


Where can we find the home health wage index for 2024?

Proposed changes to the wage index, LUPA thresholds, and case mix weights can be found on CMS’ website at the link below:



How much have the minimum LUPA visits changed in the case mix recalibration?

While the LUPA thresholds remained relatively stable in the proposed case-mix recalibration. there were 28 LUPA thresholds increased by 1 visit and 12 decreased by 1 visit. Read more about LUPA here.


Is CMS recognizing that decreased utilization is due to staffing constraints and that therapy-only cases reflect the nursing shortage?

CMS references the industry-wide staffing constraints throughout the rule. However, the proposed rule does not include any specific provisions to address these issues.


Is there anything about allowing therapists to do SOC even when an RN is referred?

There is no specific provision in the proposed rule that would allow therapists to do SOC even when an RN is referred. However, CMS is considering this issue and may make a change in the future.


Is it good if the CMW index is increasing or bad?

The case-mix weight increase is a good thing, as a higher case-mix weight is associated with higher average reimbursement for a 30-day period.


Do we anticipate any changes to the star rating OASIS items to bring them in line with VBP measures?

It is possible that the star rating OASIS items will be changed to bring them in line with VBP measures. However, this is not yet certain. CMS has introduced a new measure of discharge function, which is based on the GG items at discharge to replace the current TNC measures. In addition, they are changing the DC to a community OASIS measure, to a claims-based measure. SimiTree is anxious to see how this may affect star ratings in general.


Can you explain exactly what the discharge to community claim measure is looking at?

The discharge to community claim measure looks at whether a patient is discharged to the community after their home health episode. If a patient is discharged to a nursing home or other facility, the agency will take a hit on this measure.


Why do most HHAs avoid Medicare Part B outpatient therapy?

There are a number of reasons why HHAs may avoid Medicare Part B outpatient therapy. These reasons include the lower reimbursement rates, the administrative burden of managing a new service line, and differences in regulatory requirements, specifically relating to therapy assistants.

SimiTree has seen, however, more agencies begin to explore this and other revenue diversification opportunities as mitigation strategies to continuing reimbursement cuts under the Home Health Medicare benefit.


Do you have stats for those productivity measures?

SimiTree has developed a repository of productivity benchmarks based on its industry experience and work with industry providers.  Reach out to our team if you are looking for guidance in a particular area!

Read the full CMS proposed rule.


FREE DEMO – SimiTree Compass: Home Health Visit Utilization and Resource Management Platform

Simitree Compass

Effective approaches to visit utilization and episode management continue to grow more vital for agencies due to the reimbursement changes being levied by CMS.  Agencies should leverage available technology and data to support their teams in this process.  Looking for a free demo of SimiTree Compass, our new home health visit utilization and resource management platform?

Click here for your FREE COMPASS DEMO.


Final Thoughts - What the CMS Proposed Rule Means for HH Agencies

The proposed rule for home health agencies includes several changes that will have a significant impact on the industry. Agencies will need to carefully review the rule and make sure that they are prepared for the changes.

SimiTree will help agencies with the information they need to understand the proposed rule and to prepare for the changes. Watch the recording of this webinar here.


How SimiTree Can Help

SimiTree’s team of experts can serve as partners in the strategic planning and organizational assessment efforts that are needed to successfully prepare for the challenges that the proposed rule presents.  SimiTree has the resources, expertise, and multi-faceted solutions to raise performance levels for our clients and position them to realize revenue potential.  In addition to consulting support, we offer a range of post-acute care services, including home health billing and claims management, executive recruiting services, clinical compliance programs, coding & OASIS management, and merger and acquisition support.

When you succeed, your patients succeed. Let’s work together to make your post-acute Home Health and Hospice agency thrive. Call us today at 1.800.949.0388 or submit a contact form below to get in touch.


Related Insights 

Read SimiTree's breakdown of the 2024 CMS Proposed Rule.

Learn more about our outsourced services. 

Learn more about our compliance and regulatory risk services

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Let's work together to improve the health of your organization. At SimiTree, we balance financial expertise and clinical excellence to help our clients grow. How can we help you? Call us at 866.839.5471 or complete the form below.