Home Health & Hospice Week

Expect SNF, hospital usage to go up, commenters warn CMS.

Many commenters on the Home Health Groupings Model railed against the reform concept in general, but others got down to specifics in their feedback to CMS.

One of the most cited flaws in providers’ comment letters on the Centers for Medicare & Medicare Services’ HHGM proposal was the model’s intention to cut Home Health Prospective Payment System episodes in half, from 60 to 30 days.

“The increase in labor needed to comply with the additional multiple billing cycles is additional cost to agencies and appears counter-intuitive,” said Lisa Haglund with Sunshine Home Health Care in Spokane, Washington. “The level of complexity to learn the regulatory guidance to transition successfully [and] the frequent billing cycles adds to the financial burden of the home health agency … making successful survival for the agency perilous.”

Marcy Miller in Michigan told CMS that “as proven historically, behavior follows regulatory and fiduciary changes. The change to 30-day periods … will reduce overall length of stay due to the administrative burden on HHAs from a billing standpoint. The reduction in HH usage will create an increase in SNF and ER usage, thus, increasing Medicare expenditures overall.”

A 30-day billing period “requires us to spend yet more time with paperwork and micromanagement by our employers. That not only takes time away from patients, but it takes our energy away from our patients and increases burnout,” said physical therapist John Werle from Indiana in his comment letter.

Avera@Home and its parent Avera Health in Sioux Falls, South Dakota dismissed CMS’s claim that a 30-day period may promote more frequent review of patients’ status, leaving providers to provide a level of care that best suits patients’ needs. “Our member agencies already frequently review patient status given [patients’] vulnerable conditions and risk of re-hospitalization,” Avera said in its comment letter. “Furthermore, the 5-star rating system and home health Conditions of Participation promote more frequent review of patient status.”