Home Health & Hospice Week

Get your act together on case mix, commenters tell CMS.

To eliminate therapy as a HH PPS case mix factor, the case mix system needs to do its job. And many commenters want CMS to work harder on that.

“As a therapist, I recognize the need to remove incentives for visits,” acknowledged the comment letter from Brett Thompson from Utah, who said he’s been a home health therapist for 24 years. “We support the move from a therapy volume-based system to one based on patient characteristics,” noted the California Hospital Association in its letter.

Multiple other commenters echoed those sentiments. But they nearly universally agreed that the Home Health Grouping Model is not the way to fix PPS’s therapy problem.

“There are many options that don’t require severely hampering care delivery to patients and forcing smaller but excellent care companies out of business,” Thompson insisted in his letter.

The HHGM model just doesn’t adequately capture the resource needs of patients currently receiving therapy, many commenters insisted.

“CMS conceded in the original Home Health Prospective Payment System (PPS) that there was no correlation between OASIS data and diagnosis and the amount of therapy visits a patient received,” pointed out physical therapist Joseph McLean, the rehabilitation manager at Visiting Nurse and Health Services of Connecticut. “Has this changed? I see no studies done showing that CMS can now predict through data collection how much therapy a patient might need.”

CHA urged CMS to “continue to evaluate the validity of specific data elements in predicting therapy service needs. In discussions with our member HHAs, we have found great concern that the classification system will not fully account for certain patient types who have high therapy needs that are not directly tied to overall functional status.”

For example: “Patients who have undergone breast surgery may require treatment for lymphedema, which typically requires an intensive period of physical or occupational therapy to improve function, reduce pain and limit complications,” CHA offers.

For-profit chain Almost Family Inc. went so far as to submit “an alternative case mix model that would excel at aligning payments with costs while also encouraging desirable provider responses,” according to the company’s comment letter. “Rather than focusing on patient ‘characteristics’ (for example disease states or the presence of a wound), our model focuses on patient ‘goals’ — staying out of hospitals and improving or maintaining patients’ ability to care for themselves.”

Many, many commenters urged CMS to work with the industry on developing some alternative payment reform model that would function better than HHGM. “I urge CMS to please partner with home health industry leaders to design and develop a payment model that supports a patient-centered, quality driven system,” said PT Bob McKneely from Georgia in his letter.

Jackson, Michigan-based Great Lakes Caring Home Health & Hospice “urges CMS not to finalize the HHGM policy and instead work with stakeholders to develop a budget neutral policy that does not limit access and quality care for beneficiaries,” the regional chain’s CEO said in his comment letter.

Many commenters echoed this sentiment from the director of therapy services at Three Rivers Home Health in Eastman, Georgia: “Stop punishing agencies … and start asking real clinicians about some of these issues that are on the front lines every single day to help make more realistic decisions that are in the best interest of the patients.”