If home health providers have the collective power to change the mind (or will) of the Centers for Medicare & Medicaid Services, they put forth their best efforts this week.

In more than 900 separate comment letters and hundreds of pages submitted to the Centers for Medicare & Medicaid Services this week, they pointed out the damage CMS would inflict if it goes forward with a proposed 2.2% Medicare payment cut on participating Medicare home health agencies.

Katie Smith Sloan, president and CEO of LeadingAge, said if the planned reductions go through, CMS would have permanently reduced home health payments by 10% the last two years. She called that reduction “devastating” in a media announcement about the comments.

“We will be the last ones there serving the poorest and most underserved in our communities … but each year of cuts makes it harder for us to continue to do that and remain in business,” she said.

Among the effects of the proposed rule, providers such as LeadingAge wrote, would be the erosion of home care access as a result of inadequate staff. They also talked about the general destabilization of the industry as a result of repeated payment cuts over the years. Such parsimony has led to home health agency closures, reduced service areas, reduced admissions and reduced scope of services.

Providers also reminded CMS of the existing dysfunction in the payment structure. Medicare helps subsidize other payment sources, namely Medicaid and Medicare Advantage. Hurt Medicare and you have upset the entire system.

One of the most damning arguments against the proposed cuts? It could force some 52.7% of freestanding home health agencies into negative overall margins — below 0%, according to the National Association for Home Care & Hospice.

CMS has a lot of reading to do. If it does its homework, it will learn one essential point: A lot of providers are working earnestly to help their clients. They simply need the necessary funding to fulfill this vital mission. 

Liza Berger is editor of McKnight’s Home Care. Email her at [email protected].