Earlier this month, the National Association for Home Care & Hospice (NAHC) filed comments with the Centers for Medicare & Medicaid Services (CMS) on the proposed 2022 home health rule (CMS -1747-P), calling for no major changes to the Patient-Driven Groupings Model (PDGM) payment system, while also calling attention to the fact hospitals and skilled nursing facilities received payment boosts during the COVID-19 pandemic, while home health agencies did not.

More specifically, NAHC recommended the following modifications to the proposed rule in their comments to CMS:

• The structure and design of PDGM should be maintained for 2022.
• Withdraw the proposal to recalibrate PDGM case mix weights based on 2020 care utilization data, given the fact it’s unreasonable to assume health care utilization in 2020 is an appropriate basis for 2022.
• Replace the suggested methodology for assessing whether behavioral changes of home health agencies resulted in PDGM achieved budget neutrality in comparison to the HHPPS HHRG payment model with a methodology that focuses on behavioral changes, not change in average case mix weight. 
• Reconsider the decision to apply the new OMB geographic designations for core-based statistical areas (CBSAs) in the annual wage index. Instead, CMS should treat all provider types equally in the transition to an updated wage index as it has done for inpatient hospitals.
• Establish a process and methodology to modify HHA payment systems and rates during a Public Health Emergency.

CLICK HERE to read the full text of NAHC’s comments to CMS.