Home health sector glad CMS didn’t finalize pay adjustment method
House well being suppliers are counting CMS’ resolution to not finalize strategies for holding the cost system for dwelling well being companies funds impartial as a win, although they’re nonetheless disillusioned that CMS determined to maneuver ahead with a 4.36% minimize for the third 12 months in its ultimate 2022 cost rule.
CMS started the Patient-Driven Groupings Model for dwelling well being companies final 12 months, aiming to chop down on pointless therapies and as an alternative emphasize affected person traits. PDGM additionally modified the case-mix system and switched to reimbursing companies based mostly on 30-day durations.
The company assumed the brand new system would lead suppliers to vary their coding practices so they may log the highest-paying codes. CMS determined to chop funds by 4.36% to regulate for this assumed habits change to make sure the cost system did not change the general funds.
The 2022 home health payment rule, launched Tuesday, retains the pay minimize for an additional 12 months, which continues to concern suppliers, Partnership for High quality House Healthcare Government Director Joanne Cunningham stated. A examine of commissioned by PQHH earlier this 12 months urged the minimize is not justified and funds ought to be elevated to realize funds neutrality, Cunningham identified.
That is particularly regarding given the present healthcare workforce landscape and different COVID-19-related challenges that proceed to impression dwelling well being companies, Cunningham stated.
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The 4.36% minimize would not absolutely clarify the staffing points, nevertheless it does have an effect on them, Nationwide Affiliation for House Care & Hospice President Invoice Dombi added. “We wish to rigorously watch what occurs, as a result of administrative prices, operation prices – every part – have already been minimize to the bone, so we simply hope that they do not minimize things like the amount of care to sufferers due to this.”
CMS’ proposed 2022 dwelling well being potential cost system additionally requested for suggestions on a proposed methodology for analyzing the right behavioral adjustment sooner or later. The tactic concerned utilizing information from 30-day durations throughout 2020 to simulate 60-day episodes – the cost commonplace earlier than PDGM – to determine what funds would have seemed like below the previous mannequin. The evaluation discovered that dwelling well being company base cost was 6% increased in 2020 than it ought to have been, CMS stated.
Suppliers together with PQHH, NAHC and the American Hospital Affiliation disagreed with the method CMS proposed and stated it might result in inappropriate and extreme cost cuts down the street. NAHC urged in feedback on the proposed rule that CMS’ concept for determining whether or not PDGM spending was funds impartial went in opposition to Medicare legislation, because it was tied to adjustments in case-mix weight as an alternative of assumed habits adjustments.
Nonetheless, the Medicare Fee Advisory Fee stated in feedback that the urged methodology was applicable.
CMS acknowledged within the ultimate that almost all commenters disagreed with the proposed methodology and stated it would contemplate different approaches in future rulemaking.
Whereas NAHC President Invoice Dombi would have preferred to see CMS alter the 4.36% minimize, its willingness to look into different strategies is a optimistic consequence for dwelling well being companies, he stated.
“We actually assume the right methodology would present an underpayment relatively than overpayment. However, you recognize, as a center floor between getting what we had been asking for, and the danger that CMS may take a deeper minimize, we’re okay with the place we ended up in the mean time,” Dombi stated.
Dombi hadn’t anticipated CMS would finalize its methodology this 12 months, however he did count on to see the company put ahead a stronger protection of its proposal within the ultimate rule, he stated.
As a result of CMS did not finalize a way within the ultimate rule, Dombi is not frightened in regards to the authorized points NAHC raised in its feedback.
Nonetheless, CMS’ response to feedback on the proposed rule “did not go away me with a sense that both they absolutely understood what we had been saying or that they felt they wanted to reply to the feedback a method or one other,” Dombi stated.
Each Dombi and Cunningham stated their organizations plan to proceed assembly with CMS about one of the best ways to determine behavioral pay adjustment forward of subsequent 12 months’s proposed rule.
“Truthfully, I believe they admire the discussions,” Cunningham stated. “We’ll proceed to attempt to be a collaborative companion and share all of the evaluation that our information people produce, and you recognize, on the finish of the day, there will likely be a reconciliation of the charges sooner or later — that is a requirement of the statute. So, you recognize, we’ll see how that goes.”