Home Health & Hospice Week

Plus: Next Compare refresh may not look so fresh.

The number-one question on many home health agencies’ minds about Medicare’s proposed payment reform is not going to be answered any time soon, it appears.

In its Aug. 9 Home Health Open Door Forum, a caller asked the Centers for Medicare & Medicaid Services why its Home Health Groupings Model payment reform proposal isn’t budget neutral. In the 2018 HH PPS proposed rule published in the July 28 Federal Register, CMS says HHGM would strip nearly $1 billion from home health spending in 2019 alone (see Eli’s HCW, Vol. XXVI, No. 28-28).

A CMS official responded that the agency can’t answer that question because the rule is in a public comment period.

However, the CMS staffer recommended reading the proposed rule to get an idea of the agency’s mindset in proposing the massive cut to home health spending.

Don’t miss: And the CMS official urged HHAs to submit public comments on the rule. The comment period closes Sept. 25.

That $1 billion estimate might even be low, experts suspect. One caller pointed out that in its impact analysis, CMS says it used “assumptions on behavioral responses as a result of the new case-mix adjustment methodology,” according to the proposed rule. The caller asked what those assumptions were, whether they increased or decreased the estimated cut, and by how much.

CMS again said it couldn’t answer those questions due to the public comment period, but did urge the caller to submit those questions via the comment submission process and look for answers in the final rule.

Other topics covered in the forum include:

• OASIS cuts. To see the 35 OASIS items or data elements CMS proposes for removal in the 2018 proposed rule, go to www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Proposed-Data-Elements-to-be-Removed-from-OASIS-on-January-1-2019.pdf.
• Reducing regulatory burdens. In the HH PPS proposed rule, CMS also solicits ideas on cutting bureaucratic red tape, a CMS official highlighted in the forum. “We would like to start a national conversation about improvements that can be made to the health care delivery system that reduce unnecessary burdens for clinicians, other providers, and patients and their families,” the rule says. “We aim to increase quality of care, lower costs, improve program integrity, and make the health care system more effective, simple and accessible.”

CMS invites “the public to submit their ideas for regulatory, subregulatory, policy, practice, and procedural changes to better accomplish these goals,” the rule says. Agencies can submit their ideas through the PPS rule comment submission process outlined in the rule at www.gpo.gov/fdsys/pkg/FR-2017-07-28/pdf/2017-15825.pdf.

• Home Health Compare. Medicare’s home health outcomes website is scheduled for its next refresh in October, but your OASIS-based outcomes should look pretty much the same as the July update, a CMS staffer explained. New OASIS-based data won’t be included because there is a new process for reviewing and correcting data.

CAHPS- and claims-based outcomes will refresh as usual in October; then in January all three types of measures will update in alignment.