WiAHC Signs on as Supporting Organization

Earlier this month, the National Association for Home Care & Hospice (NAHC) submitted its formal comments on the CY 2023 Medicare home health services Proposed Rule, which includes 2023 payment rates, along with a variety of other changes affecting the value-based purchasing demonstration program and the collection of quality-of-care data. It’s estimated the proposal would slash aggregate home health payments by 4.2%, or $810 million, next year. The Wisconsin Association for Home Health Care (WiAHC) officially signed-on to the comments as a supporting organization. 

“The proposed rule is the most impacting of policy actions by CMS (Centers for Medicare & Medicaid Services) in years,” said William A. Dombi, President of NAHC.  “The proposed payment rate cut of 7.69 percent would send 51.5 percent of all home health agencies into financial deficit in 2023. That would place over three million of the most vulnerable Medicare patients and the five million of Medicaid, VA, and Medicare Advantage patients they serve in real jeopardy of losing care. Medicare would also lose the value that home health services brings to health care overall, likely increasing care costs through extended hospitalizations and higher use of institutional care to fill in the gaps,” added Dombi.

The comments submitted by NAHC argue that:

• More than 300,000 Medicare beneficiaries have lost access to home health services in recent years, with over 1000 HHAs have closing, and Medicare spending in 2020-2021 at its lowest point since 2010.
• Congress required that CMS institute a budget neutral payment model in 2020. That model underpaid home health agencies by 2.5-3.2% in contrast to the 6.9% overpayment alleged by CMS.
• CMS’s evaluation as to whether the new payment model was “budget neutral” is fatally flawed in its methodological approach and is inconsistent with comparable evaluations CMS applied in other sectors.
• CMS’s evaluation methodology is at odds with the clear mandates established by Congress in 2018 in all respects.
• CMS compounds the risks to patient care by adding new, unnecessary costs while failing to adequately recognize the significant labor and transportation cost inflation that has hit home health services.
• CMS is pulling resources from home health care at a time it is depending on that care to reduce Medicare spending on hospitalizations and other care.

CLICK HERE to review the full text of NAHC’s comments on the proposed rule.

Bipartisan legislation, the Preserving Access to Home Health Act of 2022 (S. 4605/H.R. 8581), is currently pending in the United States Senate and House of Representatives, would suspend any payment rate reductions, thereby allowing CMS additional time to reconsider its proposed actions. GO HERE to tell your members of Congress to support this critical legislation!