National Association for Home Care & Hospice President William Dombi is optimistic there is wiggle room with the Centers for Medicare and Medicaid Services on the final home healthcare rule. Dombi made his comments during a webinar Friday about the final 2022 home health care rule CMS announced last Tuesday.
“We do believe the door is open for continued constructive discussions with CMS,” Dombi said.
Pay increase offset
The new rule taking effect Jan. 1, 2022, provides agencies a Medicare increase of 3.2%, or $570 million dollars, for calendar year 2022. But it also continues a 4.3% behavioral rate cut adjustment that went into effect in 2020 under the new Patient-Driven Groupings Model.
PDGM was intended to be budget-neutral, but CMS claimed payments to home health agencies were 6% higher that first year than under the previous payment model due to an increase in the weighted case mix. NAHC has questioned the methodology due to the impact from the COVID-19 pandemic.
“We conclude that CMS is open-minded about the methodology to assess budget neutrality, which means that 6-point risk that they threw out there in the proposed rule really shouldn’t be considered to be a given,” Dombi said. “We’ve actually concluded from the analysis that we’ve done that CMS might owe home health agencies close to 2%, rather than home health agencies owing Medicare 6%. Time will tell how far we go with this.”
HHVBP start delay
The delay of the Home Health Value-Based Purchasing Model on a national scale until 2023 could also indicate CMS is open to adjusting that program. Value-based purchasing rewards home healthcare agencies based on quality of care, rather than volume. The program, which has been tested as a model in nine states since 2016, was expected to go nationwide in January. Instead, it will be launched in 2023, giving agencies an opportunity to prepare for the change.
The model has already saved Medicare an estimated $140 million, but it scores agencies on a bell curve. Even if an agency saves money under the program, it can be penalized if it underperforms compared to its peers. Dombi thinks there is a chance CMS could change that rule.
“We just think that if money incentivizes performance, then they should use some of that money to continue to incentivize performance rather than penalize providers of services,” he said.