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HCA Comments on 2018 HHPPS, with Focus on HHGM Payment Cuts

HCA has sent comments to the U.S. Centers for Medicare and Medicaid Services (CMS) urging it to halt a new proposal that would fundamentally overhaul the Medicare home health reimbursement system to the tune of $1 billion in cuts, beginning January 2019, as part of the proposed 2018 Home Health Prospective Payment System Rule. (Our comments are available here.)

This payment system, (called the Home Health Groupings Model, or “HHGM”) is the most drastic reimbursement change affecting the home care sector in decades. Because it is not budget-neutral (which should be a fundamental requirement when modifying any payment system), CMS needs to rescind this policy change and put into place a stakeholder-involved process to make rational and methodical policy changes that will not have dire consequences on America’s home care agencies.

Further, CMS has yet to schedule any meaningful simulation demo of this fundamental payment change, so that providers and consumers can understand the implications of HHGM for patient care and services. CMS has extended similar demonstration and/or voluntary participation periods for other major payment initiatives, and this proposal should be no different.

Analysis of the HHGM system indicates that it would result in significant variation in reimbursement rates by states and regions, would reward inefficiency but not high quality outcomes (by redistributing payments away from services such as physical, occupational and speech therapy) and create access issues for patients in rural and under-served areas. CMS must also provide access to — and a demonstration of — the data sets and assumptions justifying HHGM, given that the proposal (now only in conceptual form, “on paper”) appears contrary to the very purpose of existing risk-based models of Medicare home health reimbursement.

HCA’s comments on the proposed 2018 HHPPS also: call for CMS to rescind its “case-mix-creep” adjustments; urge relief from the Medicare face-to-face (F2F) requirements; call for changes to the value-based purchasing demo; and address specific reimbursement and regulatory issues like the outlier payment policy, the proposed wage index, quality reporting and OASIS standards, the Consumer Assessment of Healthcare Providers and Systems, and more.