Partnership for Quality Home Healthcare Urges CMS to Adopt Evidence-Based Approach in New Home Health Payment Rule

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, submitted comments on the CY 2019 Home Health Prospective Payment System rule that was proposed by the Centers for Medicare & Medicaid Services (CMS). The Partnership’s comments represent constructive feedback for CMS to further refine a newly proposed payment model – called the Patient Driven Groupings Model (PDGM) – so the millions of Medicare beneficiaries who require home health services continue to receive undisrupted care.

“We are appreciative of the fact that CMS has consistently recognized the value and quality that the Medicare home health benefit provides to patients, as well as the value it creates in savings for the Medicare program,” wrote Keith Myers, Chairman of the Partnership. “It is important that any improvements to this payment model ensure continued access to this valued benefit through continued growth, allowing more patients to be cared for in their home as an alternative to institutional services, which in turn results in savings to the Medicare program.”

The newly proposed payment model incorporates minimal changes from previously proposed reforms (HHGM) introduced in 2017, which were broadly opposed and not finalized by CMS. The Partnership is concerned CMS did not incorporate critical policy recommendations from home health leaders and experts when crafting the proposed payment rule for 2019.

Recognizing and supportive of CMS’ efforts to align payment with patient characteristics, quality, and to remove utilization-based incentives from the process, the Partnership urges CMS to make positive reforms to the newly proposed PDGM that would ensure that patient access is not compromised and urges CMS to amend the policy before the final rule is implemented.

Specifically, the Partnership is concerned by:

• the proposed rule’s emphasis on using untested behavioral assumptions not based on observed data;
• the suggestion that aggregate spending on home health services must be capped, which would result in potentially harmful limits on Medicare beneficiaries’ access to the home health benefit;
• CMS’ reliance on unaudited and unreliable cost reports that differ from provider to provider;and
• CMS’ decision to implement the program in 2020, well before it has completed a comprehensive review to ensure a smooth transition and no unintended consequences.

“CMS should monitor the impact to ensure no disruption in access to services for patients,” wrote Myers. “We recommend that CMS form an advisory committee made up of consumers, providers, and physicians to provide regular feedback and advice on necessary technical changes to this reform.”

View the Partnership’s full comment letter here.

###