Home Health & Hospice Week

Policy is penalizing HHAs, expert points out.

Even before the recent big wage index area shake-up, hospitals still had a competitive advantage over home health agencies due to their ability to request wage index reclassification. And that policy has got to go, multiple commenters tell Medicare officials in their home health proposed rule comment letters.

“Unlike the hospitals nationally who are given the opportunity to appeal their annual wage index, HHAs do not have appeal rights with regards to their wage index,” Patrick Conole with the Home Care Association of New York State points out. “This lack of parity between different health care sectors further exemplifies the inadequacy of CMS’s decision to continue to use the pre-floor, pre-reclassified hospital wage index to adjust home health services payment rates,” Conole slams in his comment letter.

For example: “Hospitals in the Albany-Schenectady-Troy CBSA have been working hard with Congress and CMS to appeal its wage index, which is clearly needed,” Conole highlights. “But any inroads or success they may reach, unfortunately, would not apply to HHAs in the same CBSA.”

“We have experienced wide swings in wage index adjustments in the past, and these have created significant hardship,” relates Dianne Hansen, CEO of Partners In Home Care in Missoula, Montana. “Competition for staff with hospitals in our communities is very high, and any significant adjustment in wage index makes it very difficult to keep our salaries within the market rates,” Hansen says in her comment letter.

“For too long, the home health industry has been subject to the hospital-based wage index, when the hospital-based wage index has not been representative of too many HH service areas,” believes CPA John Reisinger with Innovative Financial Solutions for Home Health. “This has been an error in oversight by CMS and has been penalizing to too many HHAs … as the labor costs of many service areas have been understated because of this inequity,” Reisinger says in his comment letter.

“Hospitals, SNFs and Hospice have had their own Wage Indices for years,” Reisinger tells CMS. “Why not home health?”

Do this: “CMS should create a home health-specific Wage Index, which is based solely on the issues impacting the cost of labor and the ability to attract and retain quality staff to and for the home health industry, and discontinue the use of any other segment (e.g., IPPS Hospitals) of healthcare as a proxy for home health,” Reisinger recommends.

And this: LeadingAge wants CMS to adopt a policy “that would allow home health agencies and other post-acute providers to utilize a reclassification board similar to hospitals,” Katy Barnett suggests. “Home health providers are not afforded these same options to adjust their wage indices yet must compete for the same types of caregiving professionals as and with hospitals,” Barnett emphasizes.