Partnership for Quality Home Healthcare Urges CMS to Reverse Proposed Medicare Payment Cuts for 2024 to Protect Patient Access

Home health leaders present multiple data sources showing it is becoming harder, not easier, for Medicare beneficiaries to access home health

Washington, D.C. – The Partnership for Quality Home Healthcare (the Partnership) submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on August 29 warning that the Calendar Year (CY) 2024 Home Health (HH) Prospective Payment System Proposed Rule must not be finalized. The Partnership remains deeply concerned with the additional 5.65% payment cut to Medicare home healthcare services and the detrimental impact it will have on access to high-quality home healthcare services for millions of older Americans. Additionally, the Partnership continues to oppose CMS’s methodological approach to calculating Patient Driven Groupings Model (PDGM) behavioral adjustments and urges CMS to reconsider the methodology it finalized last year.

The Partnership comments focus on the impact that cuts imposed under the PDGM methodology have had in 2023 and will have going forward if CMS continues its current course. According to the Partnership, “Access to home health is already diminished. If CMS cuts payments further as proposed for 2024, access will be decimated.”

The comment letter calls on CMS to withdraw its proposed application of permanent adjustment to home health payment rates in CY 2024, ensure that the home health market basket more accurately reflects price trends and the cost of providing care, and finalize a one-time forecast error correction to account for the underestimates of the market basket for CY 2021 and 2022.

The proposed cuts come at a time when data show access to home healthcare services is declining across the board and disadvantaged populations are experiencing inequitable access. Meanwhile, demand for home healthcare has been on the rise in recent years. For example, a CarePort study found that rejection rates for patients being discharged from a hospital to home health agencies (HHAs) hit an all-time high at an average of 76% in December 2022, up from 54% in 2019 as HHAs struggle with capacity constraints, demonstrating the need for financial stability from CMS. Despite acknowledging that the full permanent payment adjustment “may be burdensome for some providers,” CMS is disregarding the reality that these proposed cuts would dramatically harm the home health provider community and Medicare home health beneficiaries.

“CMS must assess the on-the-ground realities for patients, clinicians, and HHAs and finalize a 2024 HH PPS that allows the sector to stabilize, rather than perpetuating a downward spiral. Finalizing the rule as proposed will continue the demise of the home health benefit, to the detriment of beneficiaries, particularly the most vulnerable,” the letter stated.

Within the comment letter, the Partnership presents various analyses examining the status of the home health benefit and patient access to care, including a report from Dobson| DaVanzo detailing the harmful effects of Medicare’s proposals on home health providers using 2022 home health claims, including the range of payment impacts across home health care providers for CY 2024 resulting from the Proposed Rule, the average payment impact by state, and the average payment impact for the ten states with the highest percent reduction in payments.

To read the full Partnership comment letter, click here.

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