Home Health & Hospice Week

How do readmission payment penalties for HHAs sound?

The Medicare Payment Advisory Commission continues to hammer away at a Post Acute Care Prospective Payment System methodology.

In its Sept. 6 meeting, MedPAC staffer Evan Christman presented ideas on how a PAC PPS might be structured into two tiers. “The first tier setting general requirements for the services needed to serve the majority of Medicare PAC patients, and the second tier setting requirements for patients that require more specialized care,” Christman explained.

One idea would be to structure a PAC PPS into separate categories for institutional and noninstitutional providers. “The new requirements could establish separate categories to acknowledge that delivering care in the institution has some responsibilities that care in the home does not have, such as room and board and other ancillary services,” Christman noted in the meeting.

Another potential idea is readmission penalties for home health agencies under the system, Christman suggested.

There was some acknowledgement in the meeting that home health may not be very well suited for PAC PPS. “Home health doesn’t really fit very well,” said Commissioner Kathy Buto, a consultant and former deputy executive secretary for health at the Department of Health and Human Services.

But “I don’t know that we want to take home health out,” Buto added. Instead, a payment reduction for home health services may be a consideration, she suggested.

“Home health … is a little bit of an outlier,” agreed Commissioner Karen DeSalvo, a physician and professor at Dell Medical School at the University of Texas at Austin.

Statistic: “In a continuum from LTCH to IRF to SNF to home health, 20 to 40 percent of patients probably could have been discharged to a lower level of care,” offered Commissioner Jonathan Perlin, a physician and president of Clinical Services and Chief Medical Officer of HCA Healthcare in Nashville, Tennessee. Perlin was referring to analysis HCA did of its own system for Accountable Care Organization preparation.

HHAs should keep an eye on this developing issue. “The National Association for Home Care & Hospice acknowledges the disrupting effect these changes could have on home health patients and the provision of care,” the trade group warns in its member newsletter.