Public feedback amount fluctuates significantly. Just how much Medicare officials will listen to home health providers’ pleas may rest, at least in part, on the number of folks who are speaking up. This year, the Centers for Medicare & Medicaid Services received 943 comment letters on the 2024 home health proposed rule by the time the comment period closed on Aug. 29, according to regulations.gov. That figure compares to about 900 letters submitted on last year’s rule, which in turn was significantly up from just 207 letters in 2021.
However, this year’s number is well shy of the 1,350 comment letters submitted in 2017 when PDGM’s predecessor, HHGM, was introduced. In comparison, agencies and other interested parties submitted 364 letters in 2014, 120 letters in 2015, 89 letters in 2016, 1,345 letters in 2018 (when PDGM was proposed), 587 in 2019, and 166 in 2020. Take note: This year, however, a healthy portion of the comment letters address only the lymphedema provisions in the rule. Many of those are from Medicare beneficiaries advocating for more coverage of compression garments.