Patient Advocates, Providers and Bipartisan Lawmakers Express Concern with CMS’s Proposed Home Health Groupings Model

Washington, D.C. — Concerns raised about the Home Health Groupings Model (HHGM) proposed by the Centers for Medicare & Medicaid Services (CMS) by the Partnership for Quality Home Healthcare (Partnership) — a coalition of home health providers dedicated to improving the integrity, quality and efficiency of home healthcare for our nation’s seniors — are being echoed by a broad range of patient advocates, provider groups and bipartisan lawmakers.

The Partnership has expressed concerns that the proposed HHGM would overhaul the current system for worse by rewarding inefficiency and jeopardizing patient access to care. Now patient advocacy groups, home care associations and Members of Congress are opposing these “drastic” and “radical” changes.

Dissent has been raised from a diverse collection of stakeholders. A number of associations, including the Coalition to Preserve Rehabilitation, which includes patient groups such as the Paralyzed Veterans of America and Easter Seals, submitted comments to CMS stating that HHGM will “create major incentives to underserve Medicare beneficiaries.” The Center for Medicare Advocacy wrote that “HHGM discriminates against…the very people CMS purports it seeks to protect” and state home care associations from more than 35 states signed a letter expressing uncertainty about the impact on patients.

Here are what groups are saying about the proposed change:

American Hospital Association:

• “In practical terms, the new model would change therapy to a cost center- which would represent a major paradigm shift for the field and has the potential to reduce patients’ access to medically necessary therapy.”

American Medical Rehabilitation Providers Association:

• “We cannot support such a radical shift within the home health payment model due to the effects it will have on patients and the rest of the post-acute care community.”
• “Such a significant payment reform poses serious risks to Medicare patients, home health agencies, and the financial stability of Medicare itself.”

Center for Medicare Advocacy:

• “HHGM will ensure little or no access for people who are clinically complex and have chronic illnesses and impairments.”
• “HHGM discriminates against people with chronic conditions, the very people CMS purports it seeks to protect.”
• “HHGM methodology only reflects the needs of some Medicare beneficiaries, while Medicare law applies to every Medicare beneficiary.”

Coalition to Preserve Rehabilitation:

• “This is a fundamental change to the home health payment model that will create major incentives to underserve Medicare beneficiaries with disabilities, longer-term, and chronic conditions.”
• “Vulnerable beneficiaries, who already struggle to obtain needed care, will face even greater access barriers.”
• “Patients will be left behind by the proposed system that further encourages providers to care for short-term, acute care patients.”

Council of State Home Care Associations:

• “This proposed rule represents a major change in both the payment and care delivery system that has not been adequately tested or validated for implementation, and it is unclear how it will impact patients.”
• “A change of this magnitude is also likely to put patient access at risk for Medicare beneficiaries in rural and smaller communities with few HHAs and America’s Veterans who largely depend on home health.”

49 Bipartisan United States Senators:

• “We have heard from a number of stakeholders who are concerned that the proposed rule lacks sufficient information and data points to allow home health agencies to accurately estimate the impact of the proposed HHGM.”

Georgia Republican Congressional Delegation:

• “We are concerned this large payment overhaul does not accurately understand the impact it will have on patients and providers. As our main concern remains patient access, we believe this HHGM could hinder the delivery of home health services to seniors and could result in a lower quality of care or limited access to these vital services.”

National Association for Home Care & Hospice:

• “The Home Health Resource Groupings model (HHRG) has been handicapped since its inception with a crude method of payment adjustment that is dependent on the number of therapy visits provided to patients.”
• “CMS’s proposal to institute a new payment model is based on severely flawed “behavioral adjustments” and rate reductions that will trigger a care access disaster…”
• “CMS has not explored the pros and cons of continuing a 60-day episode of payment with the new patient classification model and, as a result, may be adding complexity and confusion in the home health benefit.”