Home Health & Hospice Week

Give CMS your two cents by Sept. 25.

Medicare’s proposal to reform the Home Health Prospective Payment System could wipe out a huge portion of the industry if it’s not seriously revised, warn home health agencies and their representatives.

Reminder: Under the Home Health Groupings Model proposal in the 2018 HH PPS proposed rule, the Centers for Medicare & Medicaid Services calls for drastic changes to the payment system that would strip nearly $1 billion in HHGM’s first year alone. Among other changes, HHGM would replace 60-day billing episodes with 30-day episodes and remove therapy from the case mix system altogether (see Eli’s HCW, Vol. XXVI, No. 27-28).

Even worse: The National Association for Home Care & Hospice estimates the payment cut would be more like $3 billion in 2019, it says.

“The HHGM proposal to establish a wholly new, non-budget neutral payment amount without authorization by Congress violates … the Social Security Act,” NAHC told CMS Administrator Seema Verma in a Sept. 1 letter. “Further, the proposal to replace the 60-day ‘episode’ unit of payment with a 30-day payment ‘period’ violates Section 1895(b)(2) of the Social Security Act,” NAHC added in the letter.

The Visiting Nurse Associations of America’s ElevatingHOME advocacy unit is urging providers to tell CMS how detrimental the proposal was to home health patients and the providers serving them in their public comments on the proposed rule. The deadline for submitting comments is Sept. 25.

Crucial: The industry trade groups are exhorting home care providers to get their elected representatives as allies in the fight to bring down HHGM. “The time is now to urge our elected officials to intervene on behalf of the home health industry to stop unprecedented cuts to home health that have been proposed by CMS,” said Warren Hebert with the HomeCare Association of Louisiana in a message to members.

“Under HHGM, Medicare would redistribute payments away from medically-necessary home health services that are currently producing Medicare savings, such as physical and occupational therapy at home, and send them to more expensive hospital- and office-based care,” the Council of State Home Care Associations said in a letter published in The Hill newspaper. “We know from past experience that non-budget neutral reforms can be disastrous,” said the letter, referring to the Interim Payment System that closed the doors of about onethird of the nation’s HHAs in the late 1990s.

The letter was published in conjunction with an industry lobbying effort in Washington, D.C., against the detrimental payment system change earlier this month.

HHAs and their reps have found some success getting elected officials on their side in the case of Florida senators Bill Nelson (D) and Marco Rubio (R), according to NAHC.

“We have heard from a number of stakeholders who are concerned that the proposed rule lacks sufficient information and data points to allow home health agencies to accurately estimate the impact of the proposed HHGM prior to the September 25, 2017 comment deadline,” the influential senators’ letter to Verma says. “It is important that those most affected by the proposed rule have the opportunity, as well as the necessary information, to evaluate any consequences prior to the Centers for Medicare and Medicaid Services’ (CMS) finalizing the proposed reforms.”

HHAs also are gathering elected officials’ support for HHGM revision by taking to their local newspapers’ editorial pages. “CMS neglected to consult the home health community” when proposing HHGM, notes a letter from Cheryl Kelly in the Dothan Eagle newspaper in Alabama. “It doesn’t have to be this way. CMS can and should take the time to work with stakeholders to create policies that ensure Medicare home health beneficiaries can continue to access care. I’m calling on our representatives in Congress to urge CMS to withdraw the proposed HHGM and work with the home health community to fix the proposed payment model.”

Similar letters from local residents ran in the Wyoming Tribune Eagle and Ocala Star Banner in Florida.

Short window: The span of time between the comment period closing and the issuance of the new 2018 HH PPS final rule is critical for influencing HHGM’s fate, experts stress. Once CMS has finalized the HHGM implementation plan, it will be much harder to secure program changes.

HHGM “would cause enormous stress on the home health system, very possibly placing agencies in jeopardy and causing damage to beneficiaries, providers, and the post-acute care system,” according to a new analysis from consulting firm Dobson DaVanzo & Associates, NAHC says in its member newsletter. “Historically, when changes of this magnitude were implemented, the field experienced extreme financial distress,” the new report notes.

“NAHC urges CMS to withdraw the HHGM policy and instead work with stakeholders to develop a fully budget-neutral policy that does not limit access to beneficiaries or diminish provider resources,” the trade group says. “Without your support and advocacy, this rule cannot be stopped.”

“We believe that CMS must work with the home health community in order to properly address and solve the issues within the HHGM,” says lobbying group The Partnership for Quality Home Healthcare on its website. “We welcome engagement with CMS, but need more data and information to be able to offer in-depth policy recommendations,” it says.

“ElevatingHOME urges every Medicare certified home health agency to oppose the proposed HHGM and to tell CMS that they cannot implement this unprecedented and untested model,” the advocacy group urges.

Timeline: HHAs can expect CMS to issue the final rule by late October or early November.