An important deadline passed this week: the date to submit comments to the Centers for Medicare & Medicaid Services regarding the home health proposed payment rule.
Providers have spoken. Loudly. The National Association for Home Care & Hospice, Partnership for Quality Home Healthcare and LeadingAge (among other organizations) insisted that CMS erred in its analysis that resulted in a proposed permanent behavioral assumption adjustment of 7.69% related to the Patient-Driven Groupings Model system.
This budget neutrality adjustment is inconsistent with the concept of budget neutrality, NAHC argued in comments submitted by the Tuesday deadline. CMS actually underpaid providers by 3.22% in 2020, according to NAHC; CMS says it overpaid home health providers by 6.25% for the same year.
“This radical difference is explained in the fatally flawed methodology employed by CMS that applies the HHRG-HHPSS payment system to the PDGM-induced 2020 home healthcare delivery, a universe that would not exist in the absence of PDGM,” NAHC said.
The largest association of home health providers also argued that providers simply would not be able to withstand such funding reductions. Some 26 states and territories are projected to have more than half of their home health agencies with overall margins below zero with the reduction.
And there would be other consequences. As an example, the highly touted Home Health Value-Based Purchasing program also would be at risk with the 7.69% cut, NAHC said.
“It is unfathomable that HHAs provide the same level of patient support and operational performance with a $1.3 billion revenue reduction,” NAHC said in its comments.
PQHH and LeadingAge used equally strong language in their comments to CMS.
“CMS’ proposed approach results in an unstable and adverse reimbursement environment for the next decade that will undermine CMS’ own efforts to advance health equity and quality through value-based purchasing, post-acute payment reform, and other initiatives,” according to the letter from PQHH.
LeadingAge also took CMS to task. With the various home health behavioral adjustments, CMS took “an unnecessarily cynical view of home health agencies,” LeadingAge wrote. “It also paints all agencies with a broad brush, despite many nonprofit and mission-driven agencies which made no change to their clinical practice and patient care philosophy to adapt to the new payment environment.”
With this type of pushback, it certainly will be hard for CMS to go forward with the proposed rule in its current state. And in rethinking the hospice and skilled nursing facility proposed rules, it’s clear that CMS takes providers’ comments into account.
Now, its homework done, home health can set its sights on the two major bills pending in Congress that would postpone any Medicare funding cuts until 2026. And then it waits. The final rule is close at hand.
Liza Berger is editor of McKnight’s Home Care. Email her at [email protected].
