fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

FAH Comments on Proposed Home Health Payment and Methodology Changes

September 25, 2017 | FAH Policy Blog Team

Category: Financing, Health Care Delivery, Medicare

The Federation of American Hospitals sent comments to CMS today on proposed changes to the 2018 home health prospective payment system (HH PPS) rate and proposed refinements to the case-mix adjustment methodology that would begin in 2019.

CMS’s proposed home health grouping model (HHGM) would group patients into payment categories using primarily clinical characteristics and other patient information as a replacement for the five current categories, which are based on the number of therapy services provided and the episode’s timing in a sequence of episodes.

FAH expressed concern that the changes described in the proposed rule are not ready for implementation in 2019 and urged CMS not to finalize the proposed adoption of the HHGM. FAH’s letter notes that: “The proposed new case mix system represents a major departure from how home health agencies are currently paid by Medicare. It is untested, its details are not transparent, and if implemented as proposed, the new HHGM could result in unintended consequences for Medicare beneficiaries, the Medicare program, and home health service providers, as well as hospitals and the broader health care system…”

FAH supports continued work on a HHGM-based case-mix adjustment, but asked that CMS continue to work with all stakeholders to develop a system that is “clinically coherent and transparent, results in appropriate payment for services rendered, and ensures continued access to needed home health services.”

FAH believes that in order to successfully design and implement a HHGM, CMS should:

•         Defer implementation of the proposed 2019 HHGM, and establish a process for continued dialogue with stakeholders in anticipation of a re-proposal of an HHGM in the future

•         Make all data used in preparing the proposed rule groupings and impact analysis available to stakeholders to further understanding and replication of the proposed system

•         Propose any subsequent HHGM with a multi-year transition in order to minimize disruptions

•         Make conversion to the HHGM budget neutral, which FAH believes is statutorily required.

You can read the entire comment letter by clicking here.