CHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2022 proposed rule for the home health prospective payment system.
In the letter, CHA urges CMS to:
- Delay the proposed expansion of the home health Value-Based Purchasing (VBP) Program and solicit broad stakeholder input on VBP design in future rulemaking
- Reconsider its proposal to revise the compliance date for reporting requirements for the Home Health Quality Reporting Program (QRP), the Inpatient Rehabilitation Facility QRP, and the Long-Term Care Hospital QRP
In addition, CHA provides comments on specific provisions of the proposed expanded VBP Program. It also expresses support for CMS’ proposals to defer implementation of a behavioral assumption payment adjustment to allow for additional review and analysis, and to update the home health conditions of participation to allow for occupational therapists to complete assessment when certain conditions are met, as well as to provide flexibilities in the supervision of home health aides.