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CHA Comments on CY 2024 Home Health PPS Proposed Rule

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CHA submitted comments on the calendar year (CY) 2024 home health (HH) prospective payment system proposed rule.

In the letter, CHA raised concerns about the impact of CMS’ proposed payment adjustments. CHA requested that CMS take steps to eliminate punitive and unwarranted decreases in reimbursement that have negatively impacted access to HH care. CHA specifically asked CMS to: 

  • Provide a forecast error adjustment to the final 2024 market basket update to account for CMS’ underestimation of the market basket in the years 2021 and 2022 because of the COVID-19 public health emergency (PHE).  
  • Eliminate the productivity adjustment to the market basket update for any year impacted by the COVID-19 PHE. 
  • Delay implementation of the budget-neutrality adjustment as currently proposed.  
  • Delay rebasing the labor-related share and include data from hospital-based HH agencies.   
  • Conduct additional testing on the Cross-Setting Discharge Function Score Measure.