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HCA Submits Comments on HHPPS Rule for Medicare Home Health

HCA submitted extensive comments this week on the U.S. Centers for Medicare and Medicaid Services proposed rule for the 2017 Home Health Prospective Payment System (HHPPS). You can download the comments here.

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.

HCA’s comments also address CMS’s silence, in the proposed 2017 rule, on the question of Medicare face-to-face documentation issues which continue to plague providers with administrative costs and access-to-care burdens.

We also address concerns with CMS’s proposal to calculate outlier payments, using a cost-per-unit approach rather than a cost-per-visit approach. Along with this cost-per-unit change, CMS is proposing a cap on the amount of time per day that would be counted toward the estimation of an episode’s costs for outlier calculation purposes. Specifically, CMS proposes to limit the amount of time per day (summed across the six disciplines of care) to 8 hours or 32 units per day when estimating the cost of an episode for outlier calculation purposes.

HCA comments additionally address: concerns with CMS’s value-based purchasing demonstration project, the proposed wage index, payment for negative pressure wound therapy using a disposable device and the lack of funding for Health Information Technology/Exchange and other aspects of the rule. For each area of concern, HCA outlines specific recommendations.

A final rule is anticipated by November, with the 2017 HHPPS going into effect on January 1.