House well being suppliers are counting CMS’ determination to not finalize strategies for conserving the fee system for residence well being companies finances impartial as a win, although they’re nonetheless disillusioned that CMS determined to maneuver ahead with a 4.36% reduce for the third 12 months in its last 2022 fee rule.
CMS started the Patient-Driven Groupings Model for residence 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 intervals.
The company assumed the brand new system would lead suppliers to alter their coding practices so they might log the highest-paying codes. CMS determined to chop funds by 4.36% to regulate for this assumed habits change to make sure the fee system did not change the general finances,
The 2022 home health payment rule, launched Tuesday, retains the pay reduce for an additional 12 months, which continues to concern suppliers, Partnership for High quality House Healthcare Govt Director Joanne Cunningham mentioned. A examine of commissioned by PQHH earlier this 12 months instructed the reduce is not justified and funds ought to be elevated to realize finances neutrality, Cunningham identified.
That is particularly regarding given the present healthcare workforce landscape and different COVID-19-related challenges that proceed to affect residence well being companies, Cunningham mentioned.
The 4.36% reduce is not the would not totally clarify the staffing points, however it does have an effect on them, Nationwide Affiliation for House Care & Hospice President Invoice Dombi added. “We need to rigorously watch what occurs, as a result of administrative prices, operation prices – all the pieces – have already been reduce to the bone, so we simply hope that they do not reduce things like the amount of care to sufferers due to this.”
CMS’ proposed 2022 residence well being potential fee system additionally requested for suggestions on a proposed technique for analyzing the proper behavioral adjustment sooner or later. The strategy concerned utilizing knowledge from 30-day intervals throughout 2020 to simulate 60-day episodes – the fee commonplace earlier than PDGM – to determine what funds would have regarded like underneath the previous mannequin. The evaluation discovered that residence well being company base fee was 6% increased in 2020 than it ought to have been, CMS mentioned.
Suppliers together with PQHH, NAHC and the American Hospital Affiliation disagreed with the method CMS proposed and mentioned it could result in inappropriate and extreme fee cuts down the highway. NAHC instructed in feedback on the proposed rule that CMS’ thought for determining whether or not PDGM spending was finances impartial went towards 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 mentioned in feedback that the instructed technique was acceptable.
CMS acknowledged within the last that almost all commenters disagreed with the proposed methodology and mentioned it can contemplate different approaches in future rulemaking.
Whereas NAHC President Invoice Dombi would have favored to see CMS alter the 4.36% reduce, its willingness to look into different strategies is a constructive consequence for residence well being companies, he mentioned.
“We actually suppose the correct methodology would present an underpayment slightly than overpayment. However, , as a center floor between getting what we had been asking for, and the danger that CMS may take a deeper reduce, we’re okay with the place we ended up in the intervening time,” Dombi mentioned.
Dombi hadn’t anticipated CMS would finalize its methodology this 12 months, however he did anticipate to see the company put ahead a stronger protection of its proposal within the last rule, he mentioned.
As a result of CMS did not finalize a technique within the last rule, Dombi is not anxious concerning 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 totally understood what we had been saying or that they felt they wanted to answer the feedback a method or one other,” Dombi mentioned.
Each Dombi and Cunningham mentioned their organizations plan to proceed assembly with CMS about one of the simplest ways to determine behavioral pay adjustment forward of subsequent 12 months’s proposed rule.
“Actually, I believe they respect the discussions,” Cunningham mentioned. “We’ll proceed to attempt to be a collaborative associate and share all of the evaluation that our knowledge of us produce, and , on the finish of the day, there shall be a reconciliation of the charges in some unspecified time in the future — that is a requirement of the statute. So, , we’ll see how that goes.”
