The Center for Medicare and Medicaid Services (CMS) has moved forward with a proposed Prospective Payment System (PPS) rate change and implementation of the new Home Health Groupings Model (HHGM) for 2019. The new model would cut nearly $1 billion in annual Medicare payments to home health care providers, which could adversely impact in-home senior care and related services.
If the proposed changes go through, CMS will phase in the Medicare payment reductions over two years, cutting an estimated $80 million in 2018 and $950 million in 2019. There is also a partial implementation option that would reduce payments by $480 million in 2019 to help soften the blow, and delaying the full $950 million reduction until 2020.
The Partnership for Quality Home Healthcare questions whether or not CMS has the unilateral authority to make a change that impacts the budget, and has urged CMS to work collaboratively with the home health care community to address significant flaws in the proposed HHGM. Generally, changes that are not budget neutral require an act of Congress, and the Partnership is asking that those impacted the most are included in the process before moving forward with such a major change.
What Will Change if the HHGM is implemented
If the HHGM goes through, there will be several changes to Medicare coverage of home health care. Some of the most notable include:
- Replacement of the current 60-day episode of care billing model with a 30-day model
- Phasing out of the Request for Anticipated Payment (RAP)
- Phasing out of the Rural Add-on Provision, a 3% additional payment for home health services furnished in rural areas
- The creation of 6 clinical groups used to categorize 30-day episodes of care based on the patient’s primary reason for home care and other factors
- Implementation of a comorbidity adjustment
- Changes to the Low-Utilization Payment Adjustment (LUPA) threshold
- Changes to the Home Health Value-based Purchasing Model (HHVBP)
- Changes to the Home Health Quality Reporting Program (HH QRP)
The proposals outlined in the HHGM would represent the most significant changes to the home health reimbursement system in nearly two decades. We believe that such changes should not be implemented without strong feedback from the industry, patients, families, caregivers, and all those who will be impacted.
CMS has indicated a potential willingness to work with industry advocates and other experts to refine their proposal with their stated goal of “making the health care system more effective, simple, and accessible while maintaining program integrity and preventing fraud.” They are currently accepting comments on the proposed rule change until September 25.