WASHINGTON—The National Association for Home Care & Hospice (NAHC) and the Partnership for Quality Home Healthcare (the Partnership) submitted a pre-comment letter to the Centers for Medicare & Medicaid Services (CMS) on July 28 warning that the CY 2024 HH PPS Proposed Rule must not be finalized. The purpose of the letter is to sound the alarm for CMS about the risks associated with implementing additional rate cuts to Medicare home health.
According to the letter, “CMS’s implementation of PDGM and resulting rate cuts have undeniably contributed to declining access to home health services for Medicare beneficiaries.” Excerpts from the groups’ letter to CMS include:
- “CMS already recognizes the clear connection between rate reductions and access reductions. In CMS’ recent proposed rule on Medicaid home and community-based services (HCBS), the Agency is proposing that States must conduct thorough access analyses when proposing “rate reductions or payment restructurings” in order to assure that such proposed rate reductions will not hinder access to care.”
- “According to a CarePort survey of HHA referral data from more than 2,000 hospitals and health systems across the country, HHA referrals for Medicare beneficiaries are increasingly being rejected by HHAs, rising to an all-time high at an average of 76% in December 2022, up from 54% in 2019. This comports with reports from hospitals that indicate that referrals to home health, in order to successfully transition patients from hospital to home, are increasingly problematic, impeding the discharge process.”
- “CMS must show concern for what happens to beneficiaries who are unable to access the HHA care to which they are directed… CareJourney analysis shows that approximately 20.5% of all short-term acute hospital discharges in 2022 were directed to HHA care as the discharge destination. However, of those beneficiaries directed to HHA care following their hospital stay, only 63% were successfully converted to HHA care within 7 days of discharge.”
- “The current economic environment for home health, with dramatically increased costs associated with clinical staff, medical supplies, fuel and other inputs to care, is not reflected in CMS’ payments. Rather, annual updates are simply used by CMS to show an offset for significant cuts in payments and, in any case, do not reflect real increases in providers’ costs.”
In closing, the groups write, “NAHC and the Partnership strongly encourage CMS to exercise discretion to reverse, delay, or at the very least significantly moderate the cuts it has proposed for CY 2024 and to work together with providers to ensure access to a sustainable home health benefit for beneficiaries.”