by Darcey Trescone
When was the last time a phone call could get you an eight percent raise? Medicare Home Health providers can sit back and hope NAHC's lobbying efforts will be enough, or they can join the effort to pass two bills aimed at preventing CMS from cutting your 2020 pay rate an addition 8.01% based on assumptions that your behavior will change under PDGM. NAHC lobbyists themselves strongly urge all interested parties to choose the latter option.
Speaking about Senate Bill 433 and House Bill 2573, NAHC President Bill Dombi emphatically stated, "The best solution for the problems created by Medicare's behavior adjustment lies in the legislation pending before Congress. That legislation can be enacted if there is widespread and very vocal advocacy from home health agencies nationwide. We need to get Congresspeople and Senators to treat these bills as their priority."
The Patient-Driven Groupings Model, or PDGM, is the new CMS payment model for home health services starting in 2020. The Bipartisan Budget Act of 2018 requires PDGM to be budget neutral while changing from a 60-day payment unit to a 30-day payment unit. The BBA gives CMS the authority to apply "behavioral adjustments" to account for provider behavioral changes (unrelated to patients) in an effort to maintain budget neutrality. There is no mandate regarding the amount of the behavioral adjustment, whether that adjustment is up or down, or how it is implemented, which means CMS has exercised considerable discretion when interpreting that aspect of the law. The 8.01% figure is not mandated by law; CMS arrived at it through a series of assumptions.
According to NAHC, this reduction alone translates to $1.298 billion in reduced home health payments and would go into effect before any actual behavioral changes could occur. Historically, payment model changes have not triggered provider behavioral modifications that equate to 8.01% in year one and there is no documentation from CMS supporting what those anticipated behavioral changes are.
Additionally, the BBA also requires that PDGM not use the volume of therapy visits as a payment level determinant, as the Home Health Prospective Payment System (HHPPS) model has done since October 2000.
The Home Health Payment Innovation Act (S. 433 & H.R. 2573), which was introduced with bipartisan support in both the House and Senate would achieve the following:
In a document submitted by NAHC to Administrator Seema Verma September 9, 2019, NAHC provides strong arguments that there are alternative options regarding a behavioral adjustment and the risks associated with a behavioral adjustment of such magnitude being imposed all at once, concurrent with a major payment system update:
As home health providers we need to support this legislation and our team of experts over at NAHC who continue to be our voice in the industry and are clearly looking out for our best interests. If you have not submitted your support yet, click here.
©2019 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. homecaretechreport.com This one time, rights are waived. Share this article freely by clicking on one of the sharing icons at the top of the page. firstname.lastname@example.org