Home Health & Hospice Week

Providers want rebasing year moved to 2011.

The feds are gearing up for PPS rebasing, but home care providers don't like the machinery of the methodology.

Background: The Affordable Care Act requires home health prospective payment system rebasing starting in 2014. Groups such as the Medicare Payment Advisory Commission have advocated starting the rebasing process, which will presumably lower payment rates, even sooner. One reason rates are expected to drop is because visit utilization has decreased significantly since PPS began in 2000.

In the 2013 home health PPS proposed rule, the Centers for Medicare & Medicaid Services wants "to rebase and revise the home health market basket to reflect CY 2010 Medicare cost report (MCR) data, the latest available and most complete data on the actual structure of HHA costs."

Commenters on the rule are not fond of that idea. "Any rebasing of home health services should be based on 2011 cost reports," says the Michigan Home Health Association in its comment letter. "The face-to-face and therapy reassessment requirements have added significant administrative expenses to all home health agencies. We believe that using 2010 cost reports (which was prior to implementation of these costly home health regulations) will result in flawed payment calculations and inaccurate reimbursement to providers."

CMS has begun auditing a small number of cost reports in preparation for the rebasing (see Eli's HCW, Vol. XXI, No. 22). But the quality of the data in the reports is still a major problems for the rebasing project, worries the Illinois Home Care Council. "IHHC ... often finds that the statistics and cost data that are submitted to CMS are not of sufficient quality to support the important role they play in CMS' calculations," the trade group tells the agency. "It is IHHC's hope that the recent audits of cost reports that CMS has initiated will improve the quality of the cost report data that is submitted by agencies."

IHHC would actually like to see CMS ramp up its cost report audits, if it wants to use data from them for rebasing, it says.

Other problems: The market basket changes proposed may not go far enough to recognize providers' significant transportation and travel costs, particularly with gas prices fluctuating so drastically at times, IHHC adds. And even if CMS won't include all of the data from facility-based agencies in its rebasing database, it should include direct costs like wages, salaries and benefits, the trade group argues.