NAHC Tells CMS Payment Model Will Destroy Home Health Benefit

WASHINGTON—The methodology chosen to determine future home health payment rates “will eventually destroy the value of the home health services benefit,” the National Association for Homecare and Hospice (NAHC) said in a letter sent to the Centers for Medicare & Medicaid Services (CMS). 

NAHC President Bill Dombi submitted 36-pages comments on the organization’s proposed home health payment rule for 2024, plus a separate document focused on hospice rules. In it, NAHC argues that the rate cuts proposed would significantly reduce access to home health nationwide and sets the stage for further rate cuts that would “dismantle this crucial benefit” and asks the agency to go forward with setting 2024 rates without the proposed 5.653% rate cut. 

“We strongly recommend that CMS … withhold any such adjustments in 2024 to provide the opportunity for a full and deep review of the direction of the home health benefit, its impact on access to care, and options to preserve a longstanding benefit that has brought high quality of care and essential health care services to millions of Medicare beneficiaries since 1965, along with great value to the Medicare program through expenditure savings far in excess of any other Medicare benefit,” NAHC wrote in the letter. 

Some of the other recommendations it lays out are: 

• CMS should postpone application of any permanent adjustments related to budget neutrality connected with the patient-driven groupings model (PDGM) to preserve current access to home health services and the scope of care available.
• CMS should maintain its position to withhold any part of the PDGM budget neutrality temporary adjustments in 2024.
• CMS should recognize the disruptive and permanent financial impact of its forecasting error with respect to the annual Market Basket Index updates from 2021 and 2022 and implement a one-time adjustment to account for the 5.2% forecasting error.
• CMS should consider the negative and disruptive financial impacts of its proposed wage index changes and case mix weight recalibrations on care access as it finalizes the 2023 payment rates and any systemic reforms.
• CMS should abandon its proposals connected to the Home Health Value-Based Purchasing Model (HHVBP) to replace the total normalized composite (TNC) self-care and TNC mobility measures with the discharge (DC) functioning measure and to change the base line year to 2023 in the HHVBP model for performance year 2025.
• CMS should allow beneficiaries to receive intravenous immunoglobulin (IVIG) as an outpatient under Medicare Part B concurrently while under a home health plan of care.
• CMS should provide education to agencies and others about Medicare coverage for home health aide services, particularly around the definition of part time or intermittent home health aide services.
• CMS should cConsider other models for payment and coverage for Medicare covered home health aide services.

NAHC also said it supports CMS’ proposals related to the Home Health Quality Reporting Program, Care Compare and OASIS-E, and that supports proposed changes to payment for and education about disposable negative pressure wound therapy and asks for early guidance to give agencies time to adjust. It said it could not support or oppose proposals about the Home Health Quality Reporting Program Discharge Function Score Measure due to lack of information about potential impact and that it does not support the proposed reporting schedule. It said it does not not support the adoption and/or public reporting of COVID-19 patient vaccinations.