Key Issues from the CY 2025 HH PPS Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) published the CY 2025 Home Health PPS proposed rule in the Federal Register on July 3, 2024. The proposal will affect occupational therapy practitioners who work for home health agencies, as it includes payment updates, changes to quality measures in the Home Health (HH) Quality Reporting Program (QRP) and HH Value-Based Purchasing Program (HHVBP), and changes to the Conditions of Participation (CoPs). The CoPs are the minimum health and safety standards that home health agencies must comply with to qualify for reimbursement under the Medicare program. After several years of AOTA advocacy regarding the need for safeguards to protect patient access to medically necessary OT services based on individual characteristics, we believe that CMS is trying to better understand and address the challenges that OT practitioners and their patients face.