A unified compromise proposal has been offered to the House Ways and Means Committee, the chief tax-writing committee of the Congressional House of Representatives, to withdraw the proposed home health groupings model (HHGM).
The model was proposed by the Centers for Medicare & Medicaid Services (CMS) in July as part of the home health prospective payment system (PPS) update, and has since been met with outcry from providers, association groups and even federal and state lawmakers.
The proposal to the Ways and Means Committee comes as the home health care industry is awaiting news from the Office of Management and Budget (OMB), which has been reviewing HHGM and is expected to release a final rule by November 1. What will be included in the finalized version is up for speculation—though the National Association for Home Care & Hospice (NAHC) recently stated there is a 50/50 chance HHGM will be finalized with a 2019 implementation date.
Withdrawal Proposal Components
Industry association groups and stakeholders, including ElevatingHome, NAHC, the Partnership for Quality Home Health Care, Kindred Healthcare (NYSE: KND), HealthSouth/Encompass (NYSE: HLS), Amedisys (Nasdaq: AMED), LHC Group (Nasdaq: LHCG) and Almost Family (Nasdaq: AFAM), were involved in developing the consensus proposal.
Here are the core elements of the proposal, as reported by Elevating Home:
- The rule is withdrawn by way of Congressional and CMS agreement.
- Home health reforms are implemented, but no earlier than 2020.
- Reforms are developed through stakeholder involvement and the use of a CMS Technical Experts Panel subject to fully transparent public notice and comment opportunities.
- The reforms include shifting to a 30-day payment period from the existing 60-day episodic payment.
- The base 30-day payment rate is set at $1772.The inflation update (MBI) is reduced by 0.5 MBI in 2021-2023.
- Rural add-on is extended for five years. Reform to the F2F and physician documentation is implemented. Reform allowing nurse practitioners and other advance practice nurses to certify Medicare home health services is enacted (H.R. 1825/S. 445).
- Stratification of the Medicare Home Health Improper Payment Rate as overpayment, underpayment, documentation error, or improper care.
- The current Home Health Value Based Purchasing Program demo is extended to all 50 states, DC, and territories.
Home health care providers and associations have pushed a full-court blitz against HHGM, including an outpouring of public comments on the Federal Register, meetings with CMS and OMB officials and legislative approaches.
Written by Amy Baxter