Home Health Proposed Rule Results in $810M Decrease in Payments

WASHINGTON, D.C. (June 21, 2022)—The annual proposed rule for Medicare home health services includes an estimated 4.2% or $810 million decrease in aggregate payments, said the Centers for Medicare and Medicaid Services (CMS) in its fact sheet on the rule. The rule would apply to calendar year 2023. 

This decrease reflects the effects of: the proposed 2.9% home health payment update percentage ($560 million increase); an estimated 6.9% decrease that reflects the effects of the proposed prospective permanent behavioral assumption adjustment of -7.69% ($1.33 billion decrease); and an estimated 0.2% decrease that reflects the effects of a proposed update to the fixed-dollar loss ratio (FDL) used in determining outlier payments ($40 million decrease).  

Overall, the rule presents serious concerns for the home health community as it includes significant proposed rate reductions to account for the change in the payment model in 2020, the National Association for Home Care & Hospice (NAHC) said. Medicare law requires CMS to make permanent and temporary adjustments intended to ensure that the transition to the Patient Driven Groupings Model (PDGM) is budget neutral in comparison to expected Medicare spending on the 2019 payment model. 

“We are extremely disappointed in the CMS proposed rule issued today. The stability of home health care is at risk because of CMS proposing the application of a fatally flawed methodology for assessing whether the PDGM payment model led to budget neutral spending in 2020 and later years,” stated William A. Dombi, president of NAHC. “That has been made clear to CMS in the 2021 rulemaking and in multiple discussions since. With significantly rising costs for staff, transportation, and more, home health agencies across the country cannot withstand the impact of the proposed rate cut. Reliable analyses proves that PDGM underpaid home health agencies. We will be taking all steps to protect the home health benefit as this proposed rule advances and have fully prepared for congressional action and more.” 

“Considering that access to home-based care has become increasingly important to the health and safety of American seniors, it is very troubling that CMS would propose such steep rate cuts for next year and potentially even deeper cuts in the future,“ said Joanne Cunningham, CEO of the Partnership for Quality Home Healthcare. “If implemented as proposed, this payment adjustment will jeopardize the stability of this vital sector and risk seniors’ access to Medicare home health services.”

“What we see in the proposed rule is the equivalent of a declaration of war against home health agencies and the 3 million plus patients they serve. To believe this will have no impact on patients is to live in a bubble,” Dombi stated.

The rule also contains:

  • A net 2.9% inflation update (3.3% market basket index – 0.4% productivity adjustment)—This is a strikingly low inflation update given that current inflation is at a 20-year high, nearing double digits.
  • A 7.69% budget neutrality adjustment allegedly related to provider behavior changes triggered by PDGM
  • An alleged $2 billion overpayment in 2020 and 2021. CMS proposed withholding any adjustment at this time to reconcile the alleged overpayment.
  • Recalibration of the 432 case mix weights—Recalibration has been done annually to account for changes in case-specific resource and cost changes.
  • Modification of the LUPA thresholds Institution of a 5% cap on negative changes in the area-specific wage index.

Read Full Article