Serving the home health, home care and hospice industry since 1999.

Untitled Document By now, everyone has come to accept that Value-Based Purchasing is the wave of the future for Medicare participating healthcare providers. Yet CMS seems to feel the need to go one step further for Home Health by making major changes in our segment's payment system. CMS proposed, and a law has been passed to set in concrete, to replace the Home Health Prospective Payment System with the Home Health Groupings Model, more commonly known as the 30–day episode. 

This need was apparently so urgent that it was attached to a February 9 bill whose intended purpose was to avoid a government shutdown, then secretly passed in the middle of the night. No legislator wanted an second shutdown, no matter what unrelated amendments had been attached, so it passed without comment. Preserve the government and shut down home health providers…the logic escapes me.


Fifty-six percent of home health episodes of care analyzed by Abt Associates and MedPAC fall under the Medication Management Teaching and Assessment category (MMTA). Using resource utilization analytics, they estimate this type of 30-day episode -- whether services include PT, OT, ST, MSW, HHA or Skilled Nursing -- will average $1,095.00 to $1,321.00 per episode. It is safe to say this payment rate will bring about the closure of 30%-50% of today's home health providers, just as it did during the IPS to PPS transition in the late 1990’s.  Fear not, CMS will add some type of margin to the final mix.

Q. So what needs to happen to make HHGM a reality? 
A. Nothing but the scheduled implementation.


Change is the enemy

To be sure, change in and of itself is neither good nor bad. Getting nurses on board, however, will be your biggest hurdle. Surviving HHGM will require making big changes to your basic operational processes, which means big changes to familiar staff routines.

The 30-day episode
The current standard, one clinician per OASIS with up to several days to complete it, QA it, lock it, and send it will no longer be sustainable. The entire home health industry must embrace collaboration and data analysis in order to meet a new standard: to complete OASIS during the time the patient is assessed. HHAs taking up as much as 20% to 25% of the 30-day episode to produce the plan of care will simply not survive.

No More Therapy Reimbursement
Agencies soon will not be able to rely on a little extra money in their episode payments from therapy services. Margins must be made instead by data driven utilization decisions and efficiency, which again means completing the OASIS during the assessment visit, not hours, or days, later. It will become essential to increase productivity through the practice of live, interactive QA and developing evidence based, disease focused care plans.  

Certainly, HHGM will fundamentally change the way we deliver care. The question is how hard will we make it on ourselves before we accept the need to innovate and renovate the systems of the past twenty years. In part 2, we will propose the preferred methods of adapting to the requirements this new payment change.


"Abt Associates convened a Technical Expert Panel (TEP) on February 1, 2018 to collect perspectives, feedback, and recommendations from a wide variety of industry experts and representatives regarding the public comments received on the Home Health Groupings Model (HHGM), as described in the CY 2018 Home Health Prospective Payment System (HH PPS) Proposed Rule (82 FR 35270). The TEP materials are now available for download. If you have any questions or comments on the TEP materials, please email Abt Associates at"






Michael McGowan is a former OASIS instructor for CMS Region 9. He is the CEO of OperaCare and lives with his wife and daughters south of Albuquerque, NM. To see a video demonstration of the collaborative OASIS assessment described in this article, click here. Michael can be reached at


©2018 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.