Compliance Monitor (02/04/2025)

Compliance Monitor (02/04/2025)

Your source for federal updates 

Effective February 1, 2025 Revised Home Health Change of Care Notice Form  CMS improved the Home Health Change of Care Notice (HHCCN) form’s readability and design. Starting February 1, 2025, you must use the revised form to notify Medicare Fee-for-Service patients getting home health care benefits of the plan of care changes.  The revised HHCCN is now available in Chinese, Vietnamese, and Korean, in addition to English and Spanish. Home Health Change of Care Notice (HHCCN)   
February 2025 Refresh Medicare Care Compare Refresh Hospice quality scores are publicly reported on the Care Compare website and updated every quarter.  CAHPS star ratings are updated in this quarterly refresh Medicare Care Compare https://www.medicare.gov/care- compare/  
The completed form must be posted for three months, from February 1 until April 30  The completed form must be submitted to OSHA by early March  OSHA Form 300-A form Form 300-A is the Summary of Work-Related Injuries and illnesses At the end of each calendar year, Form 300- A must be completed and certified by a company executive as correct and complete and posted in the workplace annually, where notices to workers are usually posted. Establishments under Federal OSHA jurisdiction can use the ITA Coverage Application to determine if they are required to electronically report their injury and illness information to OSHA. Establishments under State Plan jurisdiction should contact  their State Plan. https://www.osha.gov/news/newsreleases/tr ade/01092023 Form 300-A https://www.osha.gov/recordkeeping/forms 
March 1, 2025, if any breaches in 2024 HIPAA Breach Reporting HIPAA-covered entities and their business associates are required annually to notify the Office for Civil Rights (OCR) of breaches of unsecured protected health information (PHI) that affect under 500 individuals. Report breaches of unsecured protected health information that affect fewer than 500 individuals utilizing the web portal in the link.  Submitting a notice of breach to the HHS secretary https://www.hhs.gov/hipaa/for- professionals/breach- notification/breach- reporting/index.html 

What to know 

  • As of January 31, 2025, the amount of acute respiratory illness causing people to seek healthcare is at a high level.
  • Seasonal influenza activity remains elevated and continues to increase across the country.
  • COVID-19 activity is elevated in many areas of the country.

https://www.cdc.gov/respiratory-viruses/data/index.html


Post-Acute Care Quality Programs – Reporting Exception Granted Due to California Wildfires and Straight-line Winds 

The Centers for Medicare & Medicaid Services (CMS) is granting exceptions1 under certain Medicare quality reporting and value-based purchasing programs to providers and facilities located in areas affected by the California Wildfires and Straight-line Winds as identified by both Department of Health and Human Services (HHS) Public Health Emergency (PHE) declarations HHS.GOV.PHE.CA Wildfires_January 2025, and the Federal Emergency Management Agency (FEMA) disaster declarations DR-4856-CA to assist these providers and facilities while they direct their resources toward caring for their patients and addressing potential infrastructure challenges affecting their healthcare operations. 

Affected areas covered by these exceptions are detailed on the Designated Areas: Disaster 4856  pages, under the section Public Assistance, designations PA-A and PA-B, of the FEMA website. If FEMA expands the emergency disaster declaration to include additional affected areas at a later date, CMS will likewise extend reporting requirement exceptions to accommodate these areas but will not necessarily publish updated communications. 

At the time of this communication, the exceptions being granted are for the reporting requirements and deadlines as detailed in the table below. 

1 The terminology “exception” is used as a general term intended for ease of reference, to collectively refer to policies established under separate programs, and may not be consistent with the specific terminology established under each individual program 

Post-Acute Care Quality Programs – Extension of Reporting Exception Granted Due to Hurricanes Helene for the States of Georgia, North Carolina, and Tennessee 

The Centers for Medicare & Medicaid Services (CMS) is extending the exceptions1previously granted under certain Medicare quality reporting and value-based purchasing programs to providers and facilities located in areas affected in the states of Georgia, North Carolina, and Tennessee by Hurricanes Helene, as identified by both Department of Health and Human Services (HHS) Public Health Emergency (PHE) renewal declarations (https://aspr.hhs.gov/legal/PHE/Pages/Helene-Renewal-27Dec24.aspx) and the Federal Emergency Management Agency (FEMA) disaster declarations (DR-4830-GA, DR-4827-NC, DR-4832- TN) to assist these providers and facilities while they direct their resources toward caring for their patients and addressing potential infrastructural challenges affecting their healthcare operations. 

Affected areas covered by these exceptions are detailed on the Designated Areas: Disaster 4830; Disaster 4827; and Disaster 4832 pages, under the section Public Assistance, designations PA-A and PA-B, of the FEMA website. If FEMA expands the emergency disaster declaration to include additional affected areas at a later date, CMS will likewise extend reporting requirement exceptions to accommodate these areas but will not necessarily publish updated communications. 

At the time of this communication, the exceptions being granted are for the reporting requirements and deadlines as detailed in the table below. 

1 The terminology “exception” is used as a general term intended for ease of reference, to collectively refer to policies established under separate programs, and may not be consistent with the specific terminology established under each individual program. 


Preliminary January 2025 Interim Performance Reports (IPRs) are Available on iQIES 

The Preliminary January 2025 IPRs for the expanded HHVBP Model have been published on the Internet Quality Improvement and Evaluation System (iQIES). The quarterly IPRs provide home health agencies (HHAs) with the cohort assignment, performance year measure data for the 12 most recent months, and the interim Total Performance Score (TPS). Using the IPRs, an HHA can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year. 

The January 2025 IPRs include a new worksheet (“CY 2025 Baseline”) that reports on your HHA’s preliminary Improvement Thresholds for the CY 2025 applicable measure set. Note that Improvement Thresholds are based on CY 2023 data for all measures in the CY 2025 measure set other than the DTC-PAC measure. For the DTC-PAC measure, CY 2022 and CY 2023 data are used.   

An HHA receives a January 2025 IPR if the HHA: 

  • Was Medicare certified prior to January 1, 2023, and 
  • Meets the minimum threshold of data for at least one (1) quality measure in the quarterly reporting period for the performance year shown in Exhibit 1.  

Exhibit 1: January 2025 IPR quality measure performance scores time periods for each measure category 

Measure Category Time Period Minimum Threshold 
OASIS-based Oct 1, 2023 – Sep 30, 2024          20 home health quality episodes  
Claims-based Jul 1, 2023 – Jun 30, 2024 20 home health stays 
HHCAHPS Survey-based          Jul 1, 2023 – Jun 30, 2024 40 completed surveys 

Note: IPRs are only available to HHAs through iQIES. IPRs are not available to the public. 

https://www.cms.gov/priorities/innovation/files/hhvbp-newsletter-dec-2024.pdf