Another ‘Doomy, Gloomy’ Home Health Landscape Awaits Providers In 2024

Home health providers could be facing a “doomy, gloomy” landscape in 2024, fresh off of two years that could be characterized as, well, doomy and gloomy.

On Monday at the Home Care 100 conference in Scottsdale, Arizona, Partnership for Quality Home Healthcare CEO Joanne Cunningham tried to emphasize the positives, while also recognizing the realities.

In particular, she harped on the need for the Preserving Access to Home Health Act to pass. The bill was introduced in the Senate in June, and in the House in August. A similar bill was also put forth in 2022, but failed to gain traction.


“If things don’t change with regard to payment policy, we will see a very doomy, gloomy future of the PDGM payment stream,” Cunningham said. “I don’t think I’ve ever said it this emphatically, but we must see this legislation pass.”

The legislation would mitigate further cuts to fee-for-service home health payment cuts and any future payment “clawbacks” from the Centers for Medicare & Medicaid Services (CMS).

In addition, it would force the Medicare Payment Advisory Commission (MedPAC) – which regularly recommends additional cuts to home health payments – to view home health margins more holistically.


“All of those [cuts] need to be wiped away,” Cunningham said. “This is also really important. In the legislation, we require MedPAC to do a better analysis of the financial condition of home health agencies right now. They take a very skewed look at the fiscal picture and financial stability picture of home health agencies.”

Part of the reason that view is skewed is because MedPAC does not include Medicare Advantage (MA) reimbursement for home health services, which tends to be considerably lower than fee-for-service reimbursement from CMS.

On that note, MA remains one of the hot-button issues in the home health industry.

Ironically, MedPAC also could finally be directing some of its scrutiny toward MA plans as well, Cunningham said.

“The MedPAC staff recently presented a report that essentially said that, [according to their calculations], in 2024, CMS will be overpaying MA plans to the tune of $88 billion,” she said.

MA plans receiving less reimbursement in the future would not necessarily be good news for home health providers, but the discussion around overpayment could help CMS realize something the home health industry has been pushing for a while: that the agency is essentially subsidizing MA plans.

Because of relatively healthy fee-for-service rates over the years, MA plans have been able to skate by while paying providers 50%-70% of fee-for-service rates.

Cunningham said that advocacy at the local level needs to continue. In fact, she argued that local-level advocacy – in lieu of just lobbying lawmakers in Washington, D.C. – is a better way to make noise that leads to action.

“The name of the game is trying to cut through the noise and the clutter,” she said. “As soon as that staffer hangs up the phone, as soon as you leave that office, as soon as you’re finished talking to your Senator, they have 10 more people right behind you, of course saying, ‘My problem is worse, and here’s why.’ So they quickly and easily can just forget what you said. That’s why repetition is key.”

Providers may be exhausted after the last couple of years of advocacy. But, to a certain extent, the advocacy has paid off.

Both proposed cuts in the summer – in 2022 and 2023 – were adjusted in favor of home health agencies by the time the final rules were released.

Still, cuts haven’t been completely done away with.

“We really still need to do a better job,” she said.

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