The National Association for Home Care & Hospice (NAHC) has zeroed in on disagreements with the Centers for Medicare and Medicaid Services’ (CMS’) proposed home health rules for next year and plans to push back on the agency regarding them.

William Dombi headhot
William Dombi

“Are we satisfied with what we’ve seen so far and willing to embrace every part of it? The short answer is no,” NAHC President William Dombi said during a webinar with members last week. “We think CMS has some work to do on this.”

The most contentious issue for NAHC in the 367-page 2022 Home Health Prospective Payment System (HH PPS) rules CMS published last week is the continuation of the 4.36% behavioral rate cut adjustment that went into effect under the new Patient-Driven Groupings Model (PDGM) in 2020. Home healthcare coalition Partnership for Quality Home Healthcare (PQHH) says CMS cut the home health payment rate based on the assumption that home health agencies would upcode and increase patient visits under the new payment model.

PDGM was intended to be budget-neutral, meaning it wouldn’t cost any more money than the previous payment model. But in 2020, CMS said payments under PDGM were 6% higher than under the previous payment model due to an increase in the weighted case mix. NAHC is questioning the agency’s methodology given the impact of the COVID-19 pandemic.

“Did it adequately take into account that 2020 was an extraordinarily unique year that is probably not going to be repeated?” Dombi asked. 

Other providers also aim to make their case to CMS to end the cut. Last week, PQHH argued an analysis it commissioned found that home health spending was actually 1.3% lower in 2020 under PDGM.

Dombi pointed out CMS wants another year of data and may consider other methodologies before acting on payment rates.

“It’s a warning that somewhere ahead of us may be a reduction in base payment rates, and will it be 6% or even more? If similar behavior continued in 2021, then CMS would have two years of excess spending to recover,” Dombi said.

Another proposed rule in the 2022 HH PPS is the expansion of the Home Health Value-Based Purchasing Model that pays home health agencies based on the quality of care versus volume. Next year that model would be extended nationwide. 

“The Medicare program has seen significant savings related to the value-based purchasing program. So, we are going to recommend that agencies share in those savings. They have averaged $141 million each year,” Mary Carr, NAHC regulatory affairs vice president, said. 

CMS is providing a 60-day comment period on HH PPS. A final decision on the rules is expected to be made by November.

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