October 31, 2018

Home Health Leaders Urge Additional Refinements to Patient Driven Groupings Model Before 2020 Implementation in Response to HHPPS Final Rule

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WASHINGTON – The Partnership for Quality Home Healthcare – a coalition of home health providers dedicated to improving the integrity, quality, and efficiency of home healthcare for our nation’s seniors – today asserted that key refinements will need to be made to the Patient Driven Groupings Model (PDGM) included in the Home Health Prospective Payment System (HHPPS) Final Rule for 2019 released today by the Centers for Medicare & Medicaid Services (CMS). Modifications will need to be made to ensure protections for Medicare patients and to assure a smoother transition to the new payment system before it is implemented in 2020.

While additional modifications are necessary, the Partnership is pleased to see the final rule implements key provisions of the Bipartisan Budget Act on home health payment reform including the guardrails of budget neutrality for the new payment system. The Partnership is also pleased the final rule contains the inclusion of costs associated with telemonitoring and the provision for home health medical records in patient certification considerations of eligibility for the benefit, and better payment accuracy related to the Medication Management Teaching and Assessment (MMTA) clinical group.

During the comment period, the Partnership and its member companies provided extensive recommendations to CMS on the proposed payment model, carefully and constructively outlining concerns with PDGM, what the unintended consequences will be and how the model could be strengthened to ensure American seniors dependent on home health are not negatively affected by this new system. For two years, the Partnership – through CMS expert panels and meetings with CMS officials – has provided guidance and sought out opportunities to work collectively with CMS to develop a payment model that protects patient access to consistent, high quality home healthcare.

“While we had hoped CMS would consider modifications outlined by the home health provider sector when finalizing this rule, this announcement reinforces the need for the industry to continue our advocacy to get the new home health payment system right,” said Keith Myers, Chairman of the Partnership. “We will continue to work collaboratively with CMS and lawmakers in Congress to refine this new payment system to ensure it is based on a data-driven approach and will support the delivery of uninterrupted, high quality home healthcare to older Americans.”

The Partnership’s primary concern with PDGM is its approach to make payment adjustments to address certain behavioral assumptions initially that are not based on actual evidence, data or experience. Instead, The Partnership believes PDGM should be implemented using evidence actually observed and collected after implementation of the new payment model, which is an industry standard, and has been the practice in the Skilled Nursing Facility (SNF) new payment model.

The Partnership is pleased that Members of Congress agree with the industry’s call for a data-driven approach and will continue to work with Congressional allies to advance reforms to ensure stability in the new payment system. Three bills introduced in the House and Senate last month (S. 3545 S.3458, H.R. 6932) eliminate one of the concerning provisions of the new payment system – the assumption-based, front-loaded cut of 6.42 percent in the first year of the new model. These bills represent a strong bipartisan, bicameral understanding that payment cuts based on assumptions rather than evidence-based data should not be supported.

“The Partnership will continue its strong advocacy efforts with both Congress and CMS, working with a unified home health sector to ensure the home health payment model implemented in 2020 is done so in a way that preserves access to care for patients and assures stability for providers,” added Myers.