Home Health & Hospice Week

Lawmakers back up request.

The Medicare Payment Advisory Commission is cheering on the cuts for co-called case mix creep under the home health prospective payment system, but providers are urging the Centers for Medicare & Medicaid Services to put on the brakes.

In their comment letters on the 2016 home health prospective payment system proposed rule, home health agencies and their representatives provide a laundry list of faults with the cuts and negative effects that will result from them (see stories p. 290 and 292).

Do this: “CMS should withdraw the proposed case mix weight adjustments proposed for 2016 and 2017,” urged the National Association for Home Care & Hospice. “No adjustments should be considered until CMS conducts a thorough analysis of real and nominal changes in case mix through evaluation of changes that occurred during the actual years of concern (2012-2014),” the trade group told CMS. “Such evaluation should analyze any variable that may reasonably explain changes in average case mix weights in addition to those variables considered in earlier analyses.”

“CMS’s reliance on an earlier legislative authority to justify an additional type of rebasing cut above the more recent cap on rebasing cuts is clearly contrary to Congressional intent,” said the Visiting Nurse Associations of America in its letter. “Instead, we urge CMS to adhere to the limits on home health rate cuts established by Congress” and drop the cut for 2016.

At least: “In the event that CMS does not withdraw the proposed adjustments, CMS should hold off on imposing the adjustments until the completion of rate rebasing in 2017,” NAHC recommended.

Or: “Alternatively, CMS should phase-in the adjustments over a five (5) year period,” NAHC said. VNAA recommended that CMS should evaluate the impact of the rebasing adjustments after they are complete, “and consult with Congress before considering additional cuts based on intensity of services i.e. nominal case mix growth.”

The industry has members of Congress on its side. Members of the House and Senate sent letters to CMS last month, urging the agency to “reconsider” the case mix creep cut. The cut “may drive Medicare reimbursement to unsustainable levels for thousands of small, rural and other home health providers across the country, impacting the care upon which many of the most vulnerable Medicare beneficiaries, as well as their communities, depend,” said the House letter.

Stay tuned: HHAs will find out whether CMS heeds the requests of providers and lawmakers when the final rule is issued, most likely in the next few weeks.