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CHA Comments on CY 2023 Home Health PPS Proposed Rule

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CHA submitted comments on the calendar year (CY) 2023 home health prospective payment system proposed rule issued by the Centers for Medicare & Medicaid Services (CMS). Comments were due to CMS on Aug. 16.

In the letter, CHA raised concerns about the inadequate proposed market basket update and asked CMS to use alternative sources of data that better reflect input price inflation experienced by home health agencies to calculate the CY 2023 market basket update. CHA also asked CMS to use its existing authority to eliminate the productivity adjustment from the market basket update calculation. .  

Additionally, CHA urged CMS to: 

  • Delay implementation of the proposed Patient-Driven Groupings Model budget neutrality adjustment  
  • Delay implementation of the updated home health outcome and assessment information set for all payers until at least January 2025, in alignment with other post-acute care settings 
  • Consider additional changes to support home health agencies’ ability to improve care and care access through telehealth and remote patient monitoring