Home care providers had a mixed reaction to the home health final rule for calendar year 2022 issued Tuesday by the Centers for Medicare & Medicaid Services. While the rule gives home health providers a pay boost of 3.2% and expands the Home Health Value-Based Purchasing Demonstration, it also includes a 4.36% behavioral rate cut related to the Payment-Driven Groupings Model.
“All told, the final rule is a combination of standard adjustments, reasonable policy actions during a continued Public Health Emergency, sensible postponements in policy reforms, and unfortunate rejections of some recommendations, such as a consistent wage index policy, that would protect access to care,” said William Dombi, president of the National Association for Home Care & Hospice.
The Partnership for Quality Home Healthcare also expressed a lukewarm response to the rule.
“While we continue to have concerns over the implementation of the behavioral adjustment cuts, the slight uptick in the payment rate for 2022 takes a modest step in recognizing the increased labor costs home health providers are continuing to experience,” said Joanne Cunningham, executive director of the Partnership. “We note CMS’ commitment in the final rule to consider all alternative approaches to the budget neutrality methodology and we look forward on working with them to properly address this in future rulemaking.”
Providers expressed their dismay when the 4.36% behavioral rate cut appeared in the proposed rule in June. CMS first initiated the cut with the implementation of PDGM in 2020. CMS reduced the home health payment rate based on the assumption that home health agencies would upcode and increase patient visits under the new payment model. Providers now want the cut to go away.
Despite the disagreements over some issues, NAHC on Tuesday praised CMS for its cautious approach to the rule.
“NAHC agrees that CMS needed to be cautious at this unsettled time, and we recommended CMS avoid taking premature steps that could disrupt a fragile healthcare system based on a myriad of assumptions and limited data from a chaotic period,” Dombi said. “In that respect, NAHC appreciates that CMS is avoiding taking potential actions without reliance on comprehensive data.”
