NAHC: Providers Need Pay Bump to Meet Proposed Rules

The National Association for Home Care & Hospice (NAHC) has publicly voiced its recommendations for the Centers for Medicare & Medicaid Services’ (CMS) proposed rule on discharge planning requirements.

In a letter to CMS Acting Administrator Andy Slavitt, NAHC said the proposed rule contains vague standards and imposes a burden on home health agencies that has been “grossly underestimated.” NAHC is a nonprofit association representing home care and hospice providers nationwide.

The proposed rule, in addition to revising discharge planning requirements that home health agencies (HHAs) and other providers must meet to take part in Medicaid and Medicare, would implement specific provisions called for by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act.


In its letter, NAHC said the requirements of the proposed rule are expected to boost home health agency costs by $283 million per year. This comes at a time when HHA payment rates are subject to major reductions through productivity adjustments, rebasing, and case mix weight change adjustments, which will reduce base rates by about 4.3% in 2016.

Medicare payment rates should be raised by an amount equal to the estimated costs—1.57%—if the proposed discharge planning responsibilities are to be adequately implemented and managed by HHAs while maintaining care access, NAHC said in the letter.

NAHC also said the proposed rule, as it stands, contains vague standards that may result in conflict between providers and CMS. NAHC, therefore, recommends that CMS provide clear guidance and flexibility for compliance.


NAHC also noted that CMS is proposing a Medicare HHA condition of participation on discharge planning that has significantly more requirements than the current discharge planning requirements. NAHC, consequently, suggests that HHAs be allowed 12 months following the issuance of any final rule to reach compliance.

Written by Mary Kate Nelson

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