Commenting on the Home Health Proposed Rule for CY2018
Commenting on the Home Health Proposed Rule for CY2018
The Issue
Did you see this info in the 9/8/17 PTinMotion News ( “There's still time to submit your comments on the US Centers for Medicare and Medicaid Services' (CMS) plan to dramatically change payment for home health services beginning in 2019. . . September 25 is the deadline for comments to CMS on its proposal to shift from 60- to 30-day episodes of care and to launch a new case-mix adjustment model that removes physical therapy visit thresholds, among other changes. Combined, the fully implemented proposal could result in a $950 million payment reduction, according to CMS.”
Your Comments Count
This proposal de-values therapy and could seriously affect home care patients’ ability to access needed therapies. Payments for caring for patients with multiple comorbidities would be no more than for patients with just one secondary diagnosis. Even if you don’t understand all aspects of the proposed rule, you can still comment to express your concerns that:
- Patient access to home care therapy services should be protected.
- Home health agencies serving medically-complex patients with multiple comorbidities should receive adequate payment. Amounts paid for caring for patients who have just one secondary diagnosis are often inadequate for meeting the needs of patients with multiple diagnoses.
- Therapy and other home care services help keep patients at home and out of the hospital and other institutions. These services will be threatened by the proposed payment reductions.
- Implementation of major payment changes should be delayed, so that adequate study, comments and preparations can occur.
Quantity of comments matters! If CMS receives a lot of comments – even brief ones – that will help draw attention to the need to proceed carefully and not rush into a changed payment method that could hamper patients’ access to care and cause some home care agencies to go out of business.
How to Comment
Anyone – members and non-members – can access APTA’s instructions for submitting comments electronically (or by postal mail), and also a sample/template comment letter, at:
Simple sample letter follows on the next page.
The Home Health Section thanks member Cindy Lane Moore, PT, MPH, DPT for preparing and sharing the above talking points and the sample letter on the following page.
SAMPLE COMMENT LETTER
September (date), 2017
Seema Verma, MPH
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G
Attn: CMS-1672-P
Hubert Humphrey Building
200 Independence Ave, SW
Washington, DC 20201
Submitted electronically
RE: Medicare and Medicaid Programs; CY 2018 Home Health Prospective Payment System Rate Update and Proposed CY 2019 Case-Mix Adjustment Methodology Refinements; Home Health Value-Based Purchasing Model; and Home Health Quality Reporting Requirements (CMS-1672-P)
Dear Administrator Verma:
I am writing in response to the Centers for Medicare and Medicaid Services (CMS) Calendar Year (CY) 2018 Home Health Prospective Payment System (PPS) and Rate Update and Proposed CY 2019 Case-Mix Adjustment Methodology Refinements proposed rule.
Take a couple sentences here to tell a little about you, the services you provide, and what types of patients you serve.
The proposed Home Health Group Model (HHGM) severely devalues the clinical importance of rehabilitation therapy, as well as its financial value. I believe this may negatively affect the level of therapy services furnished to patients, particularly those who are most vulnerable and have the greatest need for rehabilitation.
I am worried that, by implementing the Home Health Groupings Model (HHGM) in a non-budget neutral manner, many agencies will either have to close, or to cut therapy services. When older, homebound adults cannot obtain needed rehabilitation services, then they and their care givers are more likely to have reduced quality of life, and adverse events resulting in hospitalization or other institutionalization are more likely to occur.
In addition to applying this model in a budget-neutral way, I would like CM to delay implementation of this new, untested model, for several years. Postponing the effective date and instituting a transition period would allow time for healthcare providers and consumers to understand the model and be able to provide user-based feedback to CMS in an informed manner.
I am concerned that this proposal limits the co-morbidity payment adjustment to just one, so that a care period could receive only one comorbidity adjustment regardless of the number of secondary diagnoses. Many of our agency’s home care patients have multiple orthopedic, neurologic, cardiovascular, pulmonary, and endocrine diseases. It is common for our patients to have arthritis, joint replacements and/or fractures, Parkinson’s and/or Alzheimer’s Disease, hypertensions, COPD, and diabetes, and to be on over 25 prescription medications. Research has identified the many challenges of and resources needed for supporting chronic disease management and adhering to multiple clinical practice guidelines for multiple diseases. With many of our home care patients, we have to address all this while also addressing new or exacerbated pain and functional mobility, self-care, and communication limitations. I am afraid that the proposed reimbursement system will financially penalize agencies that accept the most frail and medically-needy patients, and particularly those needing rehabilitation.
I am also concerned about the proposed change in “early” care from the current 60-days of the certification period to only 30 days. Given the medical complexity of today’s home care patients, and their multiple, serious diagnosis requiring skilled assessment and interventions, many patients need more than 30 days of intense care. These patients and caregivers often need to have their learning “chunked” into manageable pieces. And many patients are so weak when they first arrive home from the hospital, that they require a carefully graded rehab program. In addition to the clinical rationale for keeping the “early” 60-day cert period, breaking up a 60-day cert period into two separate care categories would be administratively burdensome and increase administrative costs.
Creating 144 different LUPA thresholds, in which the thresholds vary from 2-7 minimum visits, depending on the home health grouping, will add additional administrative burden and cost.
Again, I strongly encourage CMS to only move forward with implementation of the HHGM in a budget-neutral manner, and to delay implementation for several years so that providers can have enough time to prepare for its big changes to how home care services are billed and paid for. Thank you for the opportunity to comment on the CY 2018 Home Health PPS proposed rule.
Sincerely,
Your name
Your title