President's Message

Posted: June 29, 2022

So, the 2023 Proposed Final Rule is upon us. And it is ugly. The long and short of it is a 4.2% decrease in reimbursement versus 2022. This is along with the onset of Home Health Value Based Purchasing AND OASIS E on January 1, 2023. Yes, I agree that it looks like CMS is asking more of us and paying us less. And CMS says that they are paying the Home Health industry 7.69% more under PDGM than under the previous iteration of PPS, but that PDGM is supposed to be budget-neutral. CMS is arguing that this can be attributed mostly, if not completely, to “behavioral changes”—changes in how agencies answer the OASIS questions, and changes in how agencies assign ICD-10 codes. We as an industry beg to differ, but hold that thought for a moment.

What is APTA Home Health doing about this? I have already met with APTA’S Regulatory Affairs department once to begin strategizing. And our Government Affairs Committee will meet this week to further discuss this. All this despite the fact that we are all still digesting the entire Rule. I have not yet been able to read it in its entirety. I expect it to make for stimulating reading on the beach this week.

What can YOU do in response to this proposal? USE YOUR VOICE! Shortly, there will be a sample comment letter that you will be able to utilize. Keep an eye out for that in your e-mail, on Facebook, and on Twitter. The more comments that CMS receives from us, the more stock they put in our views. If you have hard data to prove that our clients are more ill, more complex, and more resource-intensive than CMS believes them to be, please come forward with it if you are able to! We need the statistics and data to prove CMS wrong.

We know that our clients and the majority of older Americans want to stay at home, and we know that the services that we provide in the home are vital, and save CMS and the health care system as a whole millions of dollars. We need to speak out NOW to be able to continue providing those services and be reimbursed in a manner consistent with our value.

Sincerely, 

 


 Phil Goldsmith
 President
 APTA Home Health

Home Health Proposed Rule Results in $810M Decrease in Payments

WASHINGTON, D.C. (June 21, 2022)—The annual proposed rule for Medicare home health services includes an estimated 4.2% or $810 million decrease in aggregate payments, said the Centers for Medicare and Medicaid Services (CMS) in its fact sheet on the rule. The rule would apply to calendar year 2023. 

This decrease reflects the effects of: the proposed 2.9% home health payment update percentage ($560 million increase); an estimated 6.9% decrease that reflects the effects of the proposed prospective permanent behavioral assumption adjustment of -7.69% ($1.33 billion decrease); and an estimated 0.2% decrease that reflects the effects of a proposed update to the fixed-dollar loss ratio (FDL) used in determining outlier payments ($40 million decrease).  

Overall, the rule presents serious concerns for the home health community as it includes significant proposed rate reductions to account for the change in the payment model in 2020, the National Association for Home Care & Hospice (NAHC) said. Medicare law requires CMS to make permanent and temporary adjustments intended to ensure that the transition to the Patient Driven Groupings Model (PDGM) is budget neutral in comparison to expected Medicare spending on the 2019 payment model. 

“We are extremely disappointed in the CMS proposed rule issued today. The stability of home health care is at risk because of CMS proposing the application of a fatally flawed methodology for assessing whether the PDGM payment model led to budget neutral spending in 2020 and later years,” stated William A. Dombi, president of NAHC. “That has been made clear to CMS in the 2021 rulemaking and in multiple discussions since. With significantly rising costs for staff, transportation, and more, home health agencies across the country cannot withstand the impact of the proposed rate cut. Reliable analyses proves that PDGM underpaid home health agencies. We will be taking all steps to protect the home health benefit as this proposed rule advances and have fully prepared for congressional action and more.” 

“Considering that access to home-based care has become increasingly important to the health and safety of American seniors, it is very troubling that CMS would propose such steep rate cuts for next year and potentially even deeper cuts in the future,“ said Joanne Cunningham, CEO of the Partnership for Quality Home Healthcare. “If implemented as proposed, this payment adjustment will jeopardize the stability of this vital sector and risk seniors’ access to Medicare home health services.”

“What we see in the proposed rule is the equivalent of a declaration of war against home health agencies and the 3 million plus patients they serve. To believe this will have no impact on patients is to live in a bubble,” Dombi stated.

The rule also contains:

• A net 2.9% inflation update (3.3% market basket index – 0.4% productivity adjustment)—This is a strikingly low inflation update given that current inflation is at a 20-year high, nearing double digits.
• A 7.69% budget neutrality adjustment allegedly related to provider behavior changes triggered by PDGM
• An alleged $2 billion overpayment in 2020 and 2021. CMS proposed withholding any adjustment at this time to reconcile the alleged overpayment.
• Recalibration of the 432 case mix weights—Recalibration has been done annually to account for changes in case-specific resource and cost changes.
• Modification of the LUPA thresholds Institution of a 5% cap on negative changes in the area-specific wage index.

Read Full Article

CDC Authorizes COVID Vaccines for Children Ages 6 Months+

The Centers for Disease Control and Prevention (CDC) issued recommendations for vaccinating children 5 years of age and younger against COVID-19. The recommendation clears the way for the nearly 241,000 Utah children in this age group who are now eligible to get vaccinated.

Additionally, the U.S. Food and Drug Administration (FDA) has authorized both the Pfizer and Moderna mRNA vaccines for use with all ages (6 months and older) eligible for COVID-19 vaccinations. Previously, only the Pfizer vaccine was available for children younger than 18. 

Vaccines for this youngest age group will begin to arrive in Utah the week of June 20th. The first batch of doses is expected early in the week and another batch of doses is expected later in the week. According to the Utah Department of Health and Human Services (DHHS), providers have already ordered 32,300 doses of the vaccines. 

Providers such as local health departments, select pharmacies, and doctor’s offices will begin offering vaccinations to the youngest Utahns over the next several days to weeks. “We encourage parents to reach out to their child’s healthcare provider if they have questions about the COVID-19 vaccines and to find out when they can get their children vaccinated. Please be patient with vaccine providers over the next couple of weeks as they receive vaccines and prepare to administer them to our youngest children,” said Dr. Leisha Nolen, a pediatrician and the state epidemiologist at the DHHS.

A list of vaccine providers is available on the state’s coronavirus webpage. Vaccines will not be available for this youngest age group at all locations right away. Parents can visit vaccines.gov to verify which providers have younger pediatric vaccines available or call their child’s doctor’s office or local health department for information on scheduling a vaccination.  

Vaccine dosage is based on the brand of the vaccine and a person’s age the day they receive the vaccine, not weight. Depending on the type of vaccine given, children younger than 5 may need 2 or 3 doses. 

• Pfizer vaccine: Children ages 6 months through 4 years of age will need 3 doses to complete their primary vaccine series. The 2nd dose should be given 21 days after the 1st dose and then a 3rd dose 2 months after the 2nd dose.
• Moderna vaccine: Children ages 6 months through 5 years of age will need 2 doses to complete their primary vaccine series. The 2nd dose should be given at least 28 days after the 1st dose. 

For more information visit https://coronavirus.utah.gov/vaccine/ or call the COVID-19 hotline at 1-800-456-7707.

Home Health Value-Based Purchasing Model

First Five Performance Years (2016-2020) Evaluation Report - Key Takeaways: 

The Home Health Value‐Based Purchasing (HHVBP) Model provides financial incentives to home health agencies for quality improvement based on their performance relative to other agencies in their state. The first five years of the implementation of the original HHVBP Model have resulted in cumulative Medicare savings of $949.2 million, a 1.6% decline relative to the 41 non-HHVBP states, as well as improvements in quality. These impacts were observed during 2020, the third year for quality-based payment adjustments, as well as the first four years of the model.

The Two Page Overview:

• Findings-At-A-Glance (PDF)

The Report (includes an Executive Summary):

• Fifth Evaluation Report (PDF)

• Go directly to the Executive Summary (PDF)

Additional Supporting Materials:

• Appendix: Methods and Supporting Analyses (PDF)

Model Page: Home Health Value-Based Purchasing Model