SimiTree Webinar Recap: Navigating the 2025 Home Health Final Rule Changes

The Centers for Medicare & Medicaid Services (CMS) recently released the 2025 Home Health Final Rule, bringing significant changes affecting agencies nationwide. SimiTree’s expert consultants broke down these critical updates in their recent webinar.

In case you missed SimiTree’s recent webinar on the CMS Home Health Final Rule by Brian Harris, VP of Financial Consulting and John Rabbia, Director of Operations Consulting, you can access the recording anytime on our webinars page. To schedule a meeting for help with these changes in any capacity, contact us today.

Key Updates from the Home Health Final Rule 2025:

Financial Impact

Medicare spending increase of 0.5% ($85M across industry)
National base rate increases 0.9% from $2,038.13 to $2,057.35
Permanent behavioral adjustment reduced to -1.975% (from proposed -4.067%)
Wage index changes: Urban +1.10%, Rural +0.44% average

PDGM Clinical Grouping Changes

Increases: Wounds (+0.7%), MMTA-Endocrine (+0.3%)
Largest decreases: MS Rehab (-2.3%), Neuro (-2.7%)
MS Rehab represents largest patient group at 21.2%

All-Payer OASIS Implementation

Voluntary start: January 1, 2025
Mandatory: July 1, 2025
Begins with Start of Care assessments

Value-Based Purchasing

Payment adjustments begin January 2025 (based on 2023 performance)
New measures include discharge function score and potentially preventable hospitalizations

New CoP Requirement Agencies must implement acceptance to service policy addressing:

Anticipated patient needs
Agency caseload and case mix
Current staffing levels
Staff skills/competencies
Annual review required

FAQs: Questions You Asked During the Webinar

Q: Should we discharge patients and readmit with a start of care OASIS by mandatory July 1?

A: No definitive answer yet – awaiting CMS OASIS Q&A guidance.

Q: Will OASIS collection be needed for self-pay clients?

A: Yes, when they say “all payers” it includes self-pay.

Q: Are claims-based measures with discharge to community with or without formal support?

A: It measures discharge to institution versus facility.

Q: Is there a best way to track potentially preventable hospitalizations compared to the ACH traditionally tracked?

A: Currently limited baseline data. Recommendation is to:

Look at highest hospitalization rates by primary diagnosis
Prioritize addressing top cases
Take data-driven approach focusing on top 3 rehospitalization diagnoses
Wait for ability to stratify by clinical grouping

Q: Do agencies need to publicly report availability?

A: Not currently required to publicly report capacity. Need to:

Have an acceptance policy
Publicly report specialty programs offered or eliminated

Q: Will OASIS collection be needed for self-pay clients?

A: Yes

Q: Are claims-based discharge to community measures with or without formal support?

A: Both

Q. What’s the best way to track potentially preventable hospitalizations vs. traditional ACH?

A: We’re awaiting guidance on this. The best approach since this is a risk adjusted measure is to ensure that OASIS data is accurately capturing the patient’s acuity. Prioritize the primary diagnoses or clinical groupings that are driving the greatest proportion of rehospitalizations and focus improvement efforts to those targeted populations.

Q: How should we publicly report availability?

A: We are awaiting interpretive guidance on how to publicly report information regarding the services offered by agencies and any limitations related to the types of specialty services, duration or frequency that the agency offers. The more important action is to begin developing an acceptance to service policy that can be consistently applied to every patient referred for home health care. When developing the policy, consider the agency’s capacity, the needs of each patient, the agency’s caseload and case mix, staffing levels and the skills and competencies of the agency’s staff.

Q: What’s the reporting mechanism for the new CoP?