Gas might be the flashiest of cost monsters, but there are plenty of others. Medicare’s methodology for calculating home health agencies’ costs needs some serious work, and in the meantime agencies are suffering with a suppressed payment update — which is actually a cut in 2023. Staffing tops HHAs’ list of skyrocketing expenses (see story, p. 230). But that’s far from the end of the list, according to commenters on the home health 2023 proposed payment rule. Hundreds of HHAs point out these top costs in their letters to the Centers for Medicare & Medicaid Services. “Gas prices have increased over 53 percent in the past year,” exclaims Michelle Neyrey, the director of nursing for a small home health agency in the greater New Orleans area. (At press time, the year-over-year increase was at 23 percent after gas prices have come down from an all-time high of $5.01 per gallon on June 14.) Plus: “Gas prices … are huge factors in home health staffing and a decrease in applicants for multiple open positions,” reports Samantha Lineberry in Tennessee in her comment letter. “Since the COVID pandemic, we have seen an increase of over 200 percent or more for needed supplies to treat wounds, PPE, lab supplies,” Dina Ossa in California tells CMS. “A box of non-sterile vinyl gloves was $2.17/box prior to COVID, same box today is over $25.00,” Ossa relates. There is a “high cost of fragmentation by the Medicare Advantage plans that have gone rogue,” says Bara Alsalaheen in Michigan in his comment letter. Medicaid has the same problem of low reimbursement, multiple agencies note. “We are already seeing that patients who need charity care or who are on Medicaid are nearly impossible to place, as we have had some that we have served who moved out of our service area, and when we tried to help them establish care in their new home, no agencies would take them due to the low reimbursement,” Kay Findlay in Kansas says in her letter. “This is only going to get worse with your proposed reductions in payment,” Findlay tells CMS.
“Unless CMS is willing to mandate that Medicare Advantage and Medicaid programs pay for the actual cost of care and comparable rates to Medicare, access to appropriate levels of care is going to be materially limited,” says Mary Haynor in Wisconsin in her comment letter. The sequestration cut is one of many items that “will have negative effects on home health agency operating margins,” notes Andrew Wheeler with the Missouri Hospital Association in the organization’s comment letter. “Over the years there has been a push from insurance to get people out of the hospital and into the home with home health care,” explains Kristy Barrett in Ohio. “We are seeing such sicker patients than before in the home. We are expected to provide much more care to the patient in the home [than] before. Patients are leaving the hospitals much sooner with the expectation that a home health nurse will continue to care in the home vs keeping them in the hospital which is more money for the insurance to pay,” Barrett tells CMS. “It will take time and money to train our clinicians to properly navigate OASIS-E,” says an anonymous commenter from Oregon. “This version is also longer than the current version and therefore will cost agencies more money to perform start of care visits as they navigate this new form. “Between OASIS-E and the rollout of Value-Based Purchasing, there are already so many changes happening in home health for 2023,” the commenter observes. “This would add an additional challenge and will no doubt result in having to lay employees off and then have less ability to serve the community,” they warn. Bottom line: “The proposed payment model for 2023 does not adequately take into account inflation and our increased costs to continue operation,” Findlay tells the policymakers at CMS.