Home Health & Hospice Week

Under PAC PPS, home health stays would see downward adjustment.

While home care providers may have more pressing matters to deal with, they shouldn't lose sight of the Medicare Payment Advisory Commission's efforts at Congress' behest to work on a payment system spanning four post-acute settings.

A unified Post-Acute Care Prospective Payment System "could use readily available data to pay for a stay based on a patient's characteristics, not the site of service or the amount of therapy furnished," MedPAC maintains in its March report to Congress. "The design would correct current distortions in the SNF and HHA PPSs that encourage providers to furnish services of questionable value and advantage providers that avoid medically complex patients."

Before beginning the switch to the new PAC PPS in 2021, Congress should direct the Centers for Medicare & Medicaid Services to "begin blending the relative weights of the setting-specific payment systems and the unified PAC PPS in 2019," the commission urges. "Under this blend, each PAC setting's total payments would be kept at the recommended level while payments would be redistributed within each setting based on a provider's mix of patients, costs, and therapy practices."

In its March meeting, MedPAC staffer Carol Carter noted that "sequential stays" for home health patients differed from those in the other three settings (skilled nursing facility, inpatient rehab facility, and long-term care hospital). Costs were lower for HHAs than for the other provider types.

"Without an adjustment, profitability under a PAC PPS would be higher for later home health stays," Carter noted in the presentation.

The unified PPS already would have a large adjustment for home health agencies, note Daniel Kim and Olivia Seraphim with law firm Epstein Becker Green in analysis published on its website. Sequential stays would require a further adjustment.

MedPAC has been working on a PAC PPS since 2014, when it was mandated by the IMPACT Act, notes the National Association for Home Care & Hospice.