Home Health & Hospice Week

PDGM, RCD, and more deal multiple blows to many agencies.

While the Request for Anticipated Payment change will impact all HHAs, it is small, nonprofit, and rural providers who will feel its sting most acutely, commenters caution.

“As a small business owner I am struggling to figure out a way to stay open, serve the patients I love, and continue to provide employment for the amazing health care workers who have devoted their life to caring for our community,” the owner of Anchor HomeCare in northwest Florida says in her letter. “This huge cut to cash flow will be beyond inconvenient — it will be devastating,” she exclaims. “I have sustained the many cuts to the point I have not made a profit in four years,” she tells CMS.

“There are a significant number of home health agencies that are small in size and would be significantly impacted by a reduction and eventual elimination of the RAP,” warns Gold Coast Coding in its comment letter. “The RAP payment is critical to provide these small and medium-sized agencies with the required capital to provide medical supplies and payroll for clinical visits.”

With nonprofit providers, “particularly smaller organizations, cash flow can still be an issue if RAP payments were to go away,” says the Visiting Nurse Associations of America’s comment letter. “Not all organizations that request RAP payments are fraudulent,” VNAA reminds CMS.

Remember: HHAs aren’t just grappling with RAP reduction and elimination in a vacuum. Many agencies (those in Illinois and Texas) will already be navigating the Review Choice Demonstration when the RAP changes hit. “This financial burden will have a huge impact on our very small agency with very few patients as we rely and wait for on-time Medicare payment to pay our staff on time,” relates Velma Tolentino in Illinois. “We are trying so hard to survive and comply with the RCD … and it’s already hard getting delayed payments until the reviews are done and approved.”

And agencies will be tackling the other, paradigm-shifting PDGM changes, as well as regulatory initiatives such as the IMPACT Act, points out Mary Myers with the Johns Hopkins Home Care Group in Maryland.

RAP elimination is unnecessary anyway, multiple commenters insist. CMS cites fraud and abuse as the reason for the change. “It is unfair to cause operational disruption to thousands of home health agencies that do not pose a risk to the Medicare program to address important concerns triggered by a very small minority of home health agencies,” criticizes Pat West with Pioneer Home Health Care Inc. in Bishop, California. Instead, CMS should “explore a targeted approach to the RAP suppression or termination,” West encourages.

Home care providers are tired of the hardships they must face in the name of fraud-fighting. “Year after year, we have to deal with burdensome new regulations that don’t make sense, and continuous reimbursement cuts,” says 30-year home health nurse Simara Bianchi in Florida. The notion that PDGM changes, including the 8 percent behavioral adjustment, “will weed out fraudulent agencies is both ludicrous and comical,” Bianchi blasts. “What it will do is make it more difficult for high quality, ethical agencies who day in and day out strive to provide excellent care, to operate.

CMS should shift their focus to other matters, and stop spending ridiculous amounts of money implementing regulations and cuts that ultimately penalize our industry,” she insists.