When the Bipartisan Budget Act of 2018 was signed into law in February, a new home health payment system was back on the table. However, language of the bill left some unanswered questions about what the new model will look like.
Namely, the legislation outlined “30-day units of service,” which does not make clear if home health care providers will be required to conduct 30-day episodes of care, replacing the current 60-day episodes, or if the term refers to 30-day payment periods. Industry stakeholders are continuing to seek clarification with policymakers and the Centers for Medicare & Medicaid Services (CMS) on the issue.
“Unit of service is an entirely new term of art,” Tracey Moorhead, CEO of industry group ElevatingHome, told Home Health Care News. “We don’t know what it is. We’ve asked them to go back and clarify what is a unit of payment—not a 30-day episode. No one knows what that is. We are hoping that through some technical corrections, we will be able to achieve that clarification on unit of payment versus episode or unit of service.”
Executives with large home health providers are interpreting the 30-day unit of service as payments, rather than episodes.
“As it relates to the 30-day episodes, there is still a lot of conversation going on in Washington as to whether or not that’s a 30-day episode or a 30-day payment period,” April Anthony, CEO of Encompass Home Health and Hospice (NYSE: EHC), said during the company’s 2017 end-of-year earnings call. “Our conversations with CMS through our work at the Partnership for Quality Home Health Care as well as our conversations on the Hill would suggest that there is perhaps an unintended consequence that there was never really an intention to move to 30-day episodes, but rather 30-day payment periods.”
LHC Group (Nasdaq: LHCG) CEO Keith Myers also referred to the unit of service as a payment period rather than an episode of care during the Lafayette, Louisiana-based company’s fourth quarter earnings call.
Baton Rouge, Louisiana-based Amedisys (Nasdaq: AMED) is looking to the intentions of Congress and utilizing previous iterations of proposals to conclude the 30-day period will be payments, not episodes of care.
“We’re very confident that … the [continuing] resolution was for CMS to implement a 30-day payment period and not a 30-day episode,” Dave Kemmerly, general counsel and senior vice president of government affairs for Amedisys, said during the company’s fourth quarter earnings call.
He emphasized that this confidence is due to the fact that the company leadership has had conversations and “done a lot of homework” on the issue.
Written by Amy Baxter