State Home Health Leaders Go on the PDGM Offensive 

On a federal level, the National Association for Home Care & Hospice (NAHC), LeadingAge and the Partnership for Quality Home Healthcare (PQHH) have all ramped up their home health advocacy efforts this summer and in early fall.

Increasingly, state home health leaders have joined in on those efforts as well.

Over the past three months, home health leaders in North Carolina, Alabama, Tennessee, Michigan, Kansas and Texas have all publicly written opinion pieces slamming the current version of the Patient-Driven Groupings (PDGM) model and the Medicare cuts that potentially come with it.


“This unnecessary and draconian cut to Medicare for seniors could result in home health agency closures and force seniors into in-patient settings like nursing homes to receive the medical care they need for a higher price to patients and taxpayers,” Rachel Hammon, a registered nurse and executive director of the Texas Association of Home Care & Hospice, wrote in a July 15 op-ed.

“Across Kansas, the home-health industry employs more than 7,300 people,” stated Kansas Home Care & Hospice Association Executive Director Jane Kelly in an Aug. 10 opinion piece. “These home health workers deliver quality, compassionate care to more than 29,700 Kansans annually. Their jobs could be at risk under the PDGM, with payment cuts to Kansas providers under the new plan projected at almost 11%.”

And other state home health leaders have expressed their concerns on a more personal level.


“Rural patients, like my grandparents, particularly appreciate the fact that they can receive care near friends and loved ones, instead of having to travel long distances to receive care in facility-based settings,” Maegan Carr Martin, executive director of the Tennesee Association for Home Care, penned in a Sept. 1 column. “Yet despite the clear benefits, the federal government is moving to impose new regulations that threaten to rob Tennesseans of the ability to age in place.”

Overall, the proposed home health payment rule released by the Centers for Medicare & Medicaid Services (CMS) on July 11 included updates that would increase Medicare payments to home health providers by 1.3%, or about $250 million, in 2020.

However, the proposed rule also included language that actually increased PDGM’s widely opposed behavioral adjustment aspect, which broadly pertains to CMS assumptions around how agencies code and handle Low Utilization Payment Adjustment (LUPA) claims.

When originally introduced, PDGM’s behavioral adjustments posed a potential 6.42% cut to home health payments in the coming year.

That figure jumped to 8.01% in CMS’s more recent proposal.

In theory, PDGM is supposed to be budget neutral, a point mandated by the Bipartisan Budget Act of 2018.

“Every year, growing numbers of senior citizens are choosing to receive care in the comfort and safety of their own homes through Medicare’s home health benefit,” John Beard, founder of Alacare Home Health Services, wrote in a Sept. 4 op-ed. “Unfortunately, despite the expanding need to maintain and strengthen home health services in our state, recent policy developments in Washington, D.C., threaten to undermine patients and providers alike.”

Birmingham, Alabama-based Encompass Health Corporation (NYSE: EHC) announced plans to acquire privately-owned Alacare for $217.5 million in April.

Currently, legislation — H.R. 2573 and S. 4.33 — designed to refine PDGM and jettison its behavioral adjustments exists in both the U.S. House of Representatives and Senate. Dozens of co-sponsors on both sides of the political aisle have signed onto the bills in support of the home health industry.

Barry Cargill, president and CEO of the Michigan HomeCare & Hospice Association, praised Sen. Debbie Stabenow, a Democrat from the Wolverine State, for her legislative support in an Aug. 14 opinion piece.

“Sen. Stabenow, along with several other members of Congress, is hoping to stop any impacts before they are felt by patients,” Cargill stated. “These bills would require Medicare to implement reimbursement rate adjustments only after CMS observes any behavioral changes by home health agencies. It’s smart health policy that removes assumptions from provider payments and instead reimburses caregivers based on facts.”

Apart from PDGM, federal health care policymakers are also trying to phase out Requests for Anticipated Payments (RAPs) starting in 2020 while expanding the Review Choice Demonstration (RCD).

Both points are likely to yield more advocacy from state home health leaders in the months to come.

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