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In Win for Home Care, HHGM Withdrawn from 2018 HHPPS Final Rule

Responding to a united voice of advocacy from the home care community, the U.S. Centers for Medicare and Medicaid Services (CMS) has withdrawn its Home Health Groupings Model (HHGM) from the final Calendar Year 2018 Medicare Home Health Prospective Payment System (HHPPS) rule, posted late this afternoon.

Noting the volume of technical comments on “various aspects of the proposed case-mix adjustment methodology under the HHGM,” CMS says that commenters “were most concerned about the proposed change in the unit of payment from 60 days to 30 days and such change being proposed for implementation in a non-budget neutral manner.”

HCA made this a major point in our comments on the rule, noting that “HHGM must be revised to be implemented in a true budget-neutral fashion,” we wrote. “Budget neutrality is an essential hallmark of past payment reform policies and is an important protection against system-wide fiscal destabilization.”

CMS also says that commenters “stated their desire for greater involvement in the development of the HHGM and the need for access to the necessary data,” a point also made clear in HCA’s comments and briefing papers to Congress opposing the HHGM model.

When the HHGM proposal was first floated over the summer, HCA immediately engaged with state and national partners on a strategy to get it withdrawn, not only in our comments to CMS but in our work to enlist Congressional action. Just this past week, 174 members of Congress, including 20 out of 27 New York Members of the U.S. House of Representatives, sent a letter to CMS, prompted by the home care community, seeking HHGM’s withdrawal from the 2018 HHPPS.

We thank the strong showing from our New York House Delegation on this message to CMS. We also thank our members for responding in force through our Legislative Action Center to promote sign-on from their elected representatives, as well as our legislative affairs representative, Brett Heimov of Envision Strategy, for his routine contact with the Delegation to share data, present messaging, and urge action steps on HHGM.

As extensively reported in HCA’s weekly newsletter and alerts, a separate HHGM proposal has been advanced in the House Ways and Means Committee. Our national partners at the National Association for Home Care and Hospice (NAHC) and the Visiting Nurse Associations of America (VNAA) have worked on a consensus legislative package to mitigate the impact of this bill, the status of which will need to be further understood in the context of CMS’s decision to withdraw HHGM from the 2018 HHPPS rule. We thank NAHC and VNAA for their steadfast work on a national level throughout the past several months which was pivotal to this outcome on HHGM.

Other overall components of the rule

As a whole, the final 2018 HHPPS rule, which can be viewed here, establishes rates of payment for Medicare home health services and other regulatory updates for Calendar Year 2018.

According to CMS, overall Medicare payments to home health would be reduced by 0.4 percent, or $80 million, under the 2018 final rule. The aggregate decrease reflects upward and downward adjustments resulting in this net overall payment reduction of 0.4 percent. These adjustments (both positive and negative) include a:

  • 1 percent home health payment update percentage ($190 million increase);
  • 0.5 percent reduction in payments due to the sunset of the rural add-on provision ($100 million decrease); and
  • -0.97 percent adjustment to the national, standardized 60-day episode payment rate to account for nominal case-mix group ($170 million decrease)

The final rule also: recalibrates the HHPPS case-mix weights; finalizes changes to the Home Health Value-Based Purchasing (HHVBP) Model and to the Home Health Quality Reporting Program (HHQRP); and updates the 2018 home health wage index.

The summary in this alert is based on a very cursory review of CMS’s materials released this afternoon so that we could provide you with an immediate update. HCA will be carefully reviewing and analyzing this lengthy proposal. Over the next week, we will be preparing a detailed memorandum for HCA members summarizing the rule’s provisions and various rate calculations.