Situation Report | August 30, 2021
HCA Vice President for Finance and Management Patrick Conole recently submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposed Calendar Year (CY) 2022 payment rule for home health. Members can read our comments here.
The proposed rule includes updates on a mix of longstanding payment-related programs and structures, but also maintains the -4.36 behavioral adjustment associated with the Patient-Driven Groupings Model (PDGM) first implemented in CY 2020. CMS’s proposed rule also includes a nationwide expansion of the Home Health Value-Based Purchasing (HHVBP) demonstration for 2022, as well multiple updates to the survey and enforcement requirements for hospice programs in Fiscal Year (FY) 2022.
CMS is expected to finalize the rule, following the comment period, in late October, with the rule going into effect on January 1, 2022.
Some significant highlights of HCA’s comments to CMS include:
PDGM Maintaining the Behavioral Adjustment
HCA’s comments lead by addressing the most prominent part of the proposed rule: PDGM. Top among the Association’s concerns is CMS’s decision to maintain the -4.36 percent “behavioral adjustment” cut. The assumed behavioral assumptions are troubling in several ways.
HCA and other stakeholders have maintained that the data to date clearly shows that the assumptions made by CMS in its establishment of the adjustment have not become reality, especially as it pertains to Low Utilization Payment Adjustment (LUPA) avoidance.
Further, the methodology, assumptions, analytic documentation and underlying data supporting these behavioral assumptions are also troubling, especially considering CMS did not apply the same type of adjustment to the PDGM methodology for the nursing home industry.
Concerns with CMS’s Proposal to Expand the HHVBP Demonstration Model Nationwide in CY 2022
One of the most significant changes in the rule is CMS’s proposal to expand the HHVBP Demonstration model to the entire nation beginning January 1, 2022, as the first performance year and CY 2024 as the first payment year. This initiative would result in a proposed maximum or minimum payment adjustment, upward or downward, of 5 percent on CY 2024 final claims. As a result of this proposed expansion, CMS would end the existing HHVBP model one year early for HHA participants in the original model’s nine states.
While HCA is generally supportive of CMS’s VBP expansion proposal, HCA does have many concerns and suggested recommendations, which include the following:
- Additional time to help agencies prepare for HHVBP;
- CMS should keep its Total Performance Score (TPS) Analysis to state by state at least for the first year;
- The TPS measures fail to reflect the full scope of the home health benefit especially in cases where agencies are trying to maintain a beneficiary’s health; and,
- The 5 percent positive or negative adjustment is too much as a first year starting point.
In its comments, HCA addresses many longstanding concerns which include: the inadequacy and inconsistencies of the wage index classifications (which do not adequately reflect market conditions in many locales); the need for extension and refinements to the rural add-on tiers; and CMS’s decision to not pay for telehealth services in lieu of an in-person visit.
Other Comment Areas
HCA also commented on concerns with the implementation of the new Notice of Admission (NOA) requirement beginning in CY 2022, the inequities of the revised market basket update not reflecting new pandemic related costs experienced by agencies, as well concerns with the new hospice survey and enforcement requirements for hospice programs in Fiscal Year (FY) 2022.
PDGM and More at HCA’s Senior Financial Managers (Virtual) Conference: September 9
HCA’s upcoming Senior Financial Managers Retreat is a signature finance program for Certified Home Health Agencies (CHHAs), Licensed Home Care Services Agencies (LHCSAs), hospices and Managed Long Term Care (MLTC) plans. While the retreat was originally planned for the Mohonk Mountain Resort in New Paltz, New York, it will once again be a virtual event this year.
Included in this year’s program are two sessions on PDGM. The first of these sessions, will be conducted by SemiTree Health Care Consultants and focus on optimizing revenues under PDGM. The second session will have Chris Attaya, from Strategic Healthcare Programs, provide many key benchmarks and trends from the first 1.5 years of PGDM in 2020-2021, which agencies can use to track performance. Other sessions will be focused on assisting LHCSA and MLTC plans with their day-to-day financial operations.
HCA members can register for this signature finance program here.
A detailed brochure and agenda of the program can be downloaded here.