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HCA Comments on 2016 HHPPS Proposed Rule

HCA has submitted extensive comments (see here) on the U.S. Centers for Medicare and Medicaid Services (CMS) proposed rule for the 2016 Home Health Prospective Payment System (HHPPS). The comments address such areas as the continued methodology flaws in CMS’s rebasing of Medicare home health rates, including the incorporation of a “case-mix-creep” adjustment that appears to adjust the rebasing cuts to a level beyond that authorized by Congress. We also seek CMS action to address the lack of a comprehensive impact analysis for rebasing and the failure of rebasing to incorporate all usual and necessary indirect and direct costs in CMS’s analysis. The comments also address concerns with the Medicare face-to-face rule, CMS’s value-based payment proposal and several other detailed, technical aspects of the proposal.