Home Health & Hospice Week

Rehospitalizations may climb if reimbursement reductions go through.

Medicare needs to look at the big picture when finalizing its home health payment rule for 2016, or it may end up with reduced access and increased program costs.

Many commenters on the home health prospective payment system proposed rule were quick to point out the calculation and other flaws with the Centers for Medicare & Medicaid Ser-vices’ methodology for the case mix creep reduction (see story, p. 290). But they also offered a bleak picture of what will transpire if CMS forges ahead with the cuts. Agencies and their reps brought these negative consequences to CMS’s attention:

• Access problems. CMS’s rebasing and case mix creep cuts will strip $350 million from home health spending next year. “Payment reductions of this magnitude — if finalized — will jeopardize access to care, particularly for our nation’s most vulnerable Medicare beneficiaries,” warnedBayCare HomeCare in Florida in its letter.

“This round of payment cuts, in conjunction with other payment reductions, will reduce beneficiary access,” cautioned health system Trinity Health in Livonia, Mich., in its comment letter.

“A significant number of closings of agencies” may be “just around the corner,” Main Line Health HomeCare & Hospice in Radnor, Penn., told CMS.

Areas that have a sole home health provider may see that agency close under these cuts, warned the Visiting Nurse Associations of America. “Closures in these communities will further challenge beneficiaries’ access to care.”

• Rehospitalizations. Home care providers have been working hand-in-hand with hospitals to keep patients from unnecessarily reentering the hospital — and saving Medicare money overall. The cuts in the proposed rule “go beyond the Congressional mandate and ultimately threaten the ability of community-based services to serve as a tool to reduce rehospitalization,” said Margaret Franckhauser, CEO of the Central New Hampshire VNA & Hospice in her letter.
• Disproportionate impact. The agencies that face significant service reductions or even closures under the rule are those that aren’t part of the “upcoding” problem, Franckhauser insisted. For example, her VNA’s “case mix remains well below the national average of 1.0, and it has been below the national average in every year since the PPS system went into effect,” she related. “Our data reveals that the entire state of New Hampshire demonstrates a lower case mix than the national average; consequently the proposed reduction of an additional 1.72 percent will have a disproportionately negative impact on agencies that do not contribute to the problem you identify.”

CMS’s proposed cuts “are only sustainable by large change agencies who have the ability to spread IT and other costs across numerous agencies, and will eliminate many free-standing and hospitalbased agencies,” cautioned Catherine Gill of Missouri in her comment letter.

The proposed cuts “will be devastating to home health agencies, particularly those that serve as the safety-net providers for their communities,” VNAA said.

Rural providers are at risk under the proposal, commenters said.

Bottom line: “With this latest annual update proposal, CMS continues to penalize home health agencies for doing a good job,” Main Line lamented.