Home Health & Hospice Week

How much of the $1 billion cut would be yours?

If you ran claims through Medicare’s HHGM grouping tool before Aug. 9, you’ll need to rerun them thanks to an error in the program. And if you haven’t run the numbers at all, now’s your chance to see how the major payment reform would affect you.

Reminder: The Centers for Medicare & Medicaid Services proposes sweeping payment reform via the Home Health Groupings Model in its 2018 Home Health Prospective Payment System proposed rule (see Eli’s HCW, Vol. XXVI, No. 27-28).

Among many changes in the drastic revamp, therapy thresholds would be dropped from the case mix system and billing and payment would switch to a 30-day, rather than 60-day, basis.

CMS estimates the transition to HHGM would strip $950 million from Medicare home health spending just in 2019, its implementation year, alone.

In CMS’s Aug. 9 Home Health Open Door Forum, one caller asked CMS officials why they aren’t proposing to implement the payment reform in a budget-neutral manner. A CMS staffer said she couldn’t comment on that due to rulemaking notice and comment requirements, but that the rule’s discussion should give agencies an idea of why CMS is pursuing the non-budget-neutral strategy.

The CMS official did urge the caller to submit comments, which are due Sept. 26, and watch the final rule for a CMS response. Industry experts tell Eli they predict an avalanche of providers’ comments on this perceived injustice.

Meanwhile, CMS posted an Excel grouping tool that aims to “help users understand how the proposed payment grouping parameters, which are part of the proposed HHGM, would be used to determine case-mix assignments that are part of the payment calculation” under HH PPS, according to CMS’s how-to document on using the tool, which utilizes five grouping steps.

The problem: The grouping tool was ignoring answers to M1033 (Risk for Hospitalization), a caller reported in the forum.

The solution: CMS fixed the tool on Aug. 8, so the website refresh Aug. 9 contained the correct version, the CMS official told the caller. Also, keep in mind that responses 8 (Currently reports exhaustion) and 9 (Other risk[s] not listed in 1–8) for M1033 wouldn’t garner points under the HHGM, she added.

Note: See the HHGM grouping tool and other proposed rule materials, including HHGM case-mix weights and LUPA thresholds, at www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html in the “Downloads” section of the first “Spotlight” item.