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The National Association for Home Care & Hospice (NAHC) wants the Centers for Medicare and Medicaid Services to go back to the drawing board on proposed changes to home health reforms for the coming year.

In a letter Friday to CMS Administrator Chiquita Brooks-LaSure, NAHC leaders and state association chapters said they appreciated the effort CMS has made at modernizing the Medicare home health payment model and the transparency provided in the development of the Patient-Driven Groupings Mode (PDGM)l. But they were quick to point out that the COVID-19 pandemic has dramatically changed the healthcare environment since CMS finalized the PDGM rule in 2019.

“COVID-19 has brought extensive changes in patient mix, significant alteration of the home health patient census, practice changes in all sectors of health care, and a response from patients and prospective patients that is unprecedented in terms of willingness to accept needed health care,” NAHC said.

NAHC made a number of suggestions to CMS regarding PDGM. It  asked it to withdraw its proposal to recalibrate case-mix weights based on 2020 care utilization data and apply a PDGM-related budget neutrality adjustment methodology focused on PDGM-triggered behavioral changes. 

In other issues, NAHC requested an expert technical panel be established to evaluate the Home Healthcare Value-Based Care Purchasing measure and ensure that it fully considers the population covered by the home health benefit, particularly those not likely to improve. It also asked that the start date of Jan. 1, 2022 be delayed for all states. Value-based purchasing has been a pilot program in nine states since 2016.

Here are a few other NAHC recommendations to CMS: 

-The association said CMS should treat all provider types equally in the transition to an updated wage index by extending the 5% ceiling on negative changes in wage index values, as it has done with in-patient hospitals.

-CMS rate setting should account for costs related to the public health emergency. CMS proposed a 1.7% rate adjustment for 2022 based on 2.4% Market Basket Index (MBI) and a 0.6% Productivity Adjustment (PA). Neither of those account for the increased costs of care in 2021 that are likely to continue to 2022, NAHC said.

-CMS should not assess the late submission penalty for the Notice of Admission (NOA) until issues that negatively impact home health agencies are resolved. Beginning Jan. 1, 2022, CMS will replace submission of the No Pay RAP with an NOA.