NAHC, PQHH Sound The Alarm Over ‘Irreparable Fracturing Of The Foundation Of Skilled Home Health Care In America’

Two of home health care’s biggest advocacy organizations have joined forces on a proposed payment rule pre-comment letter addressed to the Centers for Medicare & Medicaid Services (CMS).

On Friday, the National Association for Home Care & Hospice (NAHC) and the Partnership for Quality Home Healthcare (PQHH) submitted a joint comment letter that called for “corrective action” in the final rule expected in October.

“The purpose of this letter is to sound the alarm for CMS, which bears critical responsibility for overseeing the Medicare program,” NAHC and PQHH wrote in the letter. “The cuts proposed by CMS in the CY 2024 HH PPS Proposed Rule must not be finalized. Doing so risks irreparable fracturing of the foundation of skilled home health care in America and the erosion of seniors’ ability to receive care in their home.”


The proposed payment rule, which was released in June, includes a 2.2% aggregate reduction in Medicare fee-for-services payments for next year. It also includes a 5.653% permanent rate cut, which would reduce home health payments by an estimated $870 million in 2024. 

NAHC, in particular, has taken aim at what it considers to be a flawed methodological approach to calculating home health payment. Earlier this month, NAHC filed a lawsuit against CMS and the U.S. Department of Health and Human Services (HHS).

In their joint letter, NAHC and PQHH focused on Medicare beneficiaries and the long-term impact the rule will have if finalized.


The organizations cited the recent proposed rule on Medicaid home- and community-based services (HCBS) as an acknowledgement from CMS that rate reductions and access reductions are linked.

“CMS already recognizes the clear connection between rate reductions and access reductions,” the organizations wrote. “In CMS’ recent proposed rule on Medicaid [HCBS], the agency is proposing that states must conduct thorough access analyses when proposing ‘rate reductions or payment restructurings’ in order to assure that such proposed rate reductions will not hinder access to care.”

Broadly, the cost of care delivery has risen quickly and substantially.

“In many places, the salaries for skilled clinical workers have increased by double-digit percentages year over year,” NAHC and PQHH wrote. “At the same time, the U.S. Treasury has repeatedly increased borrowing rates. Supplies, including fuel, cost more than they used to. Yet, CMS is choosing to propose massive cuts that would put the Medicare home health benefit at grave risk.”

Even prior to the proposed payment rule, providers were struggling to keep up with the demand for home health care. In 2022, the home health referral rejection rate reached an all-time high at an average of 76%, compared to 54% in 2019, according to CarePort data.

Rejections that are related to staffing shortages have also gone up, according to Homecare Homebase data. This went up from 3.8% at the beginning of 2020 to 12.1% at the beginning of 2023.

“Together, these trends indicate that patients referred to HHAs are now less able to receive HHA care,” the organizations wrote. “Importantly, these patients who are not taken into the care of an HHA do not simply disappear. Rather, they often are instead directed to institutional settings that cost far more and are typically a non preferred care setting. Patients who cannot access home health may also go home without adequate support.”

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