In a nutshell, the model proposed by Centers for Medicare and Medicaid Services (CMS) would end the impact to reimbursement based on the number of therapy visits. Reimbursement would then be based on newly modified mix of patient and case characteristics, such as episode timing, admission source, certain clinical groups, functional level and comorbidities. The proposed rule would also shorten home health episodes from 60-days to 30-days.
CMS hopes the plan will reduce Medicare home health payments by $950 million, and it insists that it will only help providers by reducing stress, support patient-doctor relationships and improve care delivery. They maintain that the HHGM will not have any significant impact to access or quality of care, but, as a whole, the home health industry disagrees and contends that the proposed plan is HHGM is a significant and negative change from the current model.
The HHGM has largely been received as unwelcome by home health providers across the U.S. Many providers believe that CMS may be overstepping the mark with the plan that, from the provider perspective, will decrease revenue, increase costs and add additional administrative strain, causing tremendous concern and worry for the industry.
Many in the industry are confounded by the idea that CMS is even proposing changes that are not budget neutral, saying it goes against authority given by Congress. Some feel that the plan was not given enough representation from the industry and some may even consider legal action to contest the proposal.
There is also a looming concern that lack of proper consideration and vetting of the complex plan opens up the potential for additional issues beyond less funding. Groups argue that the HHGM recommendations will steer the industry delivery segment in a direction that has been untried and unproven in any healthcare industry. The removal of incentives for agencies to provide more therapy at higher reimbursement rates may open up opportunities for fraud. Others are worried about technical flaws that could create major redistribution issues across markets.
Home health agencies and industry leaders are calling for a more thorough review of details of the model, saying some of the policies and recommended practices in the proposal are proposed without knowing much about the risks and benefits.
Overall, it can be described that the home health industry as a whole is not supportive of the HHGM, but industry organizations and care providers are very much willing to work towards a solution to meet everyone’s needs while causing little, if any, disruption for agencies in all markets across the country as well as the individuals they serve.
A lot can be said for home health’s reaction to the proposed rule. There is a positive note in the willingness for providers and leaders to join voices and open up dialog with CMS, but it’s still unclear how or if the industry can initiate changes with CMS. The frustration felt by the industry is substantial and real and it will be a matter of time to see how their voices impact the future of the industry.
Next time, we’ll wrap up our series and explore what it means for the future of home health. Make sure to join us!
Want to explore more? Check out our Home Health Groupings Model white paper here!