Congressman Urges End to Home Health Behavioral Adjustment

WASHINGTON, D.C. (October 2, 2020)—The Partnership for Quality Home Healthcare—a coalition of home health leaders dedicated to developing innovative reforms to improve the program integrity, quality and efficiency of home healthcare for our nation’s seniors—commended Congressman Vern Buchanan (R-Florida) for sending a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma asking the agency to eliminate the 4.36% “behavioral assumption” rate reduction in the home health payment system for 2021. These cuts originally took place in 2020 as a result of Medicare’s implementation of a new home health payment system called the Patient Driven Groupings Model (PDGM).

“The Partnership thanks Congressman Buchanan for his leadership on this issue and continued support of issues impacting the delivery of Medicare home health to American seniors,” said Joanne Cunningham, Executive Director of the Partnership. “Congressman Buchanan is a long-standing supporter of the home health community, and we echo his request that CMS discard any previous theoretical assumptions and projections of providers’ behavioral response to PDGM and remove the -4.36% behavioral adjustment for CY 2021.”

“I believe the actual experience of home health agencies this year should be reflected in CMS’s calculation of payment rates for 2021, and I am concerned that CMS’s CY 2021 proposed HH PPS rule would instead carry forward assumptions made well before any of us could have anticipated what 2020 would look like,” Rep. Buchanan wrote to Administrator Verma. “From a policy perspective, I believe that these rate reductions should be eliminated, because there is compelling data that refutes the need for this reduction.”

A recent analysis of 2020 Medicare data completed by Dobson|DaVanzo & Associates on behalf of the Partnership found that home health provider’s actual behaviors have been inconsistent with two of the three behavioral assumptions described by CMS in the CY 2020 HH PPS final rule as the basis for their estimate and justification for the prospective reduction to home health payments to ensure budget neutrality, as required by Congress. The 2020 actual data confirms that the assumptions used as the basis of the 4.36% rate reduction were incorrect and did not reflect actual provider behavior thus far in 2020.

“I urge CMS to carefully consider the data submitted by commenters and to re-evaluate the assumptions used as the basis of the 4.36% rate reduction made in last year’s rule and proposed again for 2021,” added Rep. Buchanan. “CMS should take a data-based approach to its 2021 rulemaking responsibilities and move away from earlier theoretical assumptions and projections in favor of relying on actual provider experience.”

To read the Rep. Buchanan letter to CMS, click here.

To read more about the PDGM home health cut, click here.