Home Health & Hospice Week

Industry Notes:

Reps To CMS: Correct Past Home Health Underfunding In 2024 Rule

Home health industry representatives are making a pitch for Medicare to rectify past reimbursement rate wrongs, in hopes of safeguarding and even boosting access to the benefit.

In a letter sent to Centers for Medicare & Medicaid Services Deputy Administrator Jonathan Blum last month, the National Association for Home Care & Hospice and the Partnership for Quality Home Healthcare note the severe staffing challenges home health agencies face and ask CMS to implement a rate-boosting solution.

When it comes to rate-setting, “the actual price inflation experience in the market was not reflected in the forecasts of the market basket updates applied for home health payments in [calendar years] 2021 and 2022,” NAHC and PQHH maintain. “Historically, the market basket forecasts used by CMS to update home health payments have been relatively accurate over time, however, the more recent volatility in the economy and unprecedented surge in labor costs during 2021 and 2022 was beyond what CMS’ forecast methodology could accurately account for,” they say.

The result: “The forecast error in the home health market basket for CYs 2021 and 2022 resulted in a shortfall in the annual payment rate updates for those years of 5 percent,” the trade groups argue.

The ask: “We believe the unprecedented magnitude of the forecast error over these two years warrants special consideration to avoid significant long-term underfunding of the home health benefit and to help address current workforce challenges,” PQHH CEO Joanne Cunningham and NAHC President William Dombi say in the letter. They ask “that CMS use its authority to implement a one-time forecast error correction for 2021 and 2022 to account for the significant shortfall in those years. This correction would be applied to CY 2024 payment rates based on the best data available at the time of the proposed rule.”

CMS did the same thing for skilled nursing facilities back in 2004, the letter points out.

Watch for the upcoming proposed rule, expected in late June or early July, to see whether CMS heeds the industry’s call for help.

Links to the letter and a PQHH brief are at https:// pqhh.org/home-health-leaders-offer-medicare-solution-to-address-increased-labor-costs.

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