Dissecting the 2023 Home Health Final Rule: Several Articles to Help

The following articles help to bring additional perspective to the home health final rule and bring attention to things to look out for besides the pending rate cuts. Also see the downloadable resources included at the end of this section. 

NAHC President: CMS Was Tactical, Strategic In How Final Rule Was Announced
Home Health Care News | By Patrick Filbin

By walking back severe cuts initially proposed in the home health payment rule, the U.S. Centers for Medicare & Medicaid Services (CMS) was strategically trying to create positive feelings about the final rule in order to have an upper hand down the line.

That is the assessment made by William A. Dombi, president of the National Association for Home Care & Hospice (NAHC), less than a week removed the final rule’s publishing.

“It’s important to understand some of the politics of what happened in this final rule,” Dombi said during a NAHC webinar Friday. “CMS went with a headline saying they were cutting over $800 million — in one year alone — from home health care spending to a headline that now says they’re increasing spending by $125 billion. That was a strategic, tactical move by CMS to put out a positive headline.”

That messaging, Dombi said, has helped CMS initially convince Congress that lawmakers may not have to make any additional changes.

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From HHVBP to LUPAs: Additional Takeaways From The 2023 Home Health Final Rule
Home Health Care News | By Patrick Filbin

Following the Centers for Medicare & Medicaid Services’ (CMS) release of the final payment rule, it is critical for each home health agency to figure out its own financial standing and strategic plan for 2023. 

In addition, agencies should be finding key areas for improvement and educating clinicians on the recalibrated case-mix weights and Low-Utilization Payment Adjustment (LUPA) thresholds.

Those suggestions came during a Thursday webinar with experts with the home health consulting firm SimiTree.

“Each agency is going to be different in terms of what the financial impacts are going to be,” Nick Seabrook, managing principal at SimiTree, said. “The LUPA threshold going down is going to be a pretty significant change to agencies and that could move the needle pretty significantly from a revenue standpoint as well. It’s important to know what the impact of this is for your agency.”

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What Home Health Providers May Change Due To Final Rule
Home Health Care News | By Andrew Donlan

Now that the final payment rule for the home health care industry is officially out, providers and advocates will take the long-awaited next step.

For advocates, that will mean continuing legislation efforts. Although the final rule includes a 0.7% aggregate payment bump for home health agencies, behavioral adjustment cuts are still being implemented. That’s a phased-in approach that the Centers for Medicare & Medicaid Services (CMS) would like to continue in coming years. 

“We now turn to Congress to correct what CMS has done and prevent the impending harm to the 3.2 million highly vulnerable home health patients that depend on this essential Medicare benefit annually,” National Association for Home Care & Hospice (NAHC) President William A. Dombi said in a statement shared with Home Health Care News Monday. “Even with the limited phase-in of the rate cut, with significantly rising costs for staff, transportation, and more, home health agencies across the country cannot withstand the impact of rate cuts.”...

...There will still be margin pressures due to the final rule – and final rules for future years – if the Preserving Access to Home Health Act does not gain any more traction in Washington, D.C. That piece of legislation would curb any cuts to home health reimbursement until 2026.

And if the margins are not there, less investment in other service lines is almost a certainty. But what may actually tick up is investment in technology in order to increase efficiency in certain areas.

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HH Final Rule 7.85% Rate Cut: Advocacy 1-Pager

HH Final Rule Federal Health Policy Strategies Analysis