CHA submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) calendar year proposed rule for the home health (HH) prospective payment system.
In the letter, CHA reiterates concerns about the cumulative impact of rate reductions and adjustments on hospital-operated home health agencies. Of particular concern is CMS’ proposal to reduce payments by approximately 8% beginning Jan. 1, 2020, based on behavioral assumptions associated with the implementation of a new case-mix classification system, the Patient Driven Groupings Model.
CHA also comments on CMS’ proposals to make changes to the HH quality improvement program and to add multiple new standardized patient assessment data elements (SPADEs) to the Outcome and Assessment Information Set. CHA restates its previous recommendations to modify the speed and scope of SPADE implementation, create a transparent data analysis plan, and adopt an implementation grace period.