THE ISSUES

While evidence already confirms that home healthcare is a cost effective care setting with positive clinical outcomes for patients, the Partnership is working to further improve quality and access for the patients we serve.

PATIENT DRIVEN GROUPINGS MODEL

In the Home Health Prospective Payment System (HHPPS) Final Rule for FY2020, the Centers for Medicare & Medicaid Services (CMS) finalized plans to implement a new payment model for home health services in 2020, known as the Patient Driven Groupings Model or PDGM. Under the Bipartisan Budget Act (BBA) of 2018, the model must be budget neutral and change payment from a 60-day unit to a 30-day unit. It also mandates Medicare to apply “behavioral adjustments” to account for changes in provider behavior unrelated to changes in patients served or services delivered that increase payments.

In the HHPPS Final Rule for 2020, CMS used this authority to institute an adjustment in the first year of PDGM based solely on assumptions of behavior change that might occur in 50 percent of the episodes of care. Therefore, CMS will use behavioral assumptions in adjusting the payment rate for half the 30-day episodes of care, opposed to all 30-day episodes of care in 2020, which reduces the first year payment cut to 4.36 percent from a previously planned 8.01 percent.

Under the new model, the volume of therapy visits as a payment level determinant cannot be used as a basis for payment – in contrast to the Home Health Perspective Payment System (HHPPS) model in effect since October 2000.

The Partnership appreciates that CMS leaders responded to the home health community’s comments and feedback. As payment system changes under PDGM are implemented in 2020, the Partnership will be monitoring the impacts on care delivery and patient access as providers navigate the new system. The Partnership will share its observations with CMS and our legislative champions in Congress to ensure the continued provision of quality home healthcare to Medicare beneficiaries nationwide.

REVIEW CHOICE DEMONSTRATION

In October 2019, the Centers for Medicare & Medicaid Services (CMS) announced that the agency would hold the Home Health Review Choice Demonstration (RCD) in the remaining states of Texas, North Carolina, and Florida until home health agencies had the opportunity to transition to the Patient Driven Groupings Model (PDGM). At the time, the Partnership applauded the decision as a wise and prudent move while the home health sector prepared for the largest payment model change in two decades.

The RCD requires home health providers to choose either pre-claim, post-payment review, or a minimal review with a 25 percent payment reduction of their home health Medicare claims.

Despite currently being at the epicenter of the COVID-19 public health emergency, CMS announced in July 2020 plans to proceed with the implementation of RCD in Florida and North Carolina. The Partnership is concerned that moving forward with RCD in these states will inflict greater stress and administrative burden on providers already overwhelmed by the challenges of providing patient care during this unprecedented time. We strongly urge CMS to institute an immediate pause on this policy announcement.

>RELEASE: Implementation of RCD Amidst Public Health Emergency Ill-Advised

>INSIDE HEALTH POLICY: Home Health Providers Upset By Review Choice Demo During Pandemic

>HOME HEALTH CARE NEWS: ‘An Absolute Travesty’: Home Health Advocates Make Last-Ditch Effort to Delay Review Choice Demonstration