Last year, Congress passed the Bipartisan Budget Act (BBA) of 2018. Included in this law were various reforms to the Medicare Home Health benefit. One such provision called for budget neutrality in any change to the payment model, so that future spending would remain consistent with projections of current spending levels. Additionally, Congress authorized CMS to make changes in reimbursement rates based on assumptions of provider behavior in response to the payment model reforms.
CMS has since taken this authority and incorporated behavior based rate-reductions to take effect in 2020 as included in the final Medicare home health rule. These reductions are based on the assumptions that providers will up-code and also add additional visits to LUPA cases to obtain the full episodic payment. It is notable that these projections significantly differ from their 2017 assumptions in the Home Health Groupings Model (HHGM). Further, in their finalized rule for the Skilled Nursing Facilities payment rule, CMS states that they did “not have any basis on which to assume the approximate nature or magnitude of these behavioral responses.” It is wildly inconsistent for assumptions to be made about one provider type, but not another.
Legislation (S. 433/H.R. 2573) introduced by Senators Collins, Stabenow, Kennedy, Jones, Cassidy, Paul, and Shaneen, and Represetnatives Sewell, Buchanan, Abraham, Kuster, Marchant, Arrington, Graves, Larson, Thornberry, DesJarlais, and Panetta seeks to remedy these inconsistencies by removing the ability to adjust rates based on assumptions, but rather in response to observed evidence of behavioral changes. The legislation would also allow for waivers to the homebound requirement for beneficiaries in Medicare Advantage plans and innovative Medicare payment models such as ACOs.
Please urge your Legislators to support S. 433/H.R. 2573. https://p2a.co/DyTJVMk Stop CMS from making rate changes based on assumptions. #Advocacyinaction #NAHCHeartbeat
©2019 by Rowan Consulting Associates, Inc., Colorado Springs, CO. This reprinted article appeared in Tim Rowan's Home Care Technology Report. homecaretechreport.com Please duplicate and distribute freely. firstname.lastname@example.org