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  • Proposed Home Health Rule Includes $80 Million Reduction in 2018, Potential $950 Million Reduction and Move to 30-Day Episodes in 2019

    In brief:

    • The proposed 2018 home health prospective payment system (HH PPS) includes an $80 million reduction in payments—a 2% drop from 2017
    • CMS will shift to a new payment methodology in 2019 that would establish 30-day episodes of care instead of the 60-day episodes currently used, and eliminate therapy service use thresholds in favor of payments more focused on clinical characteristics and patient information
    • 2019 changes could result in an estimated $950 drop in payment
    • Additional quality-reporting requirements to be added in 2020: skin integrity, falls, long-term care hospital patient functional assessments/care plans

    The Centers for Medicare and Medicaid Services (CMS) has issued a proposed rule for the 2018 Medicare home health prospective payment system (HH PPS) that would continue a planned series of cuts that began in 2014, with an estimated overall 0.4% reduction, or about $80 million, scheduled for next year. The proposal, released on July 25, also includes a plan to adopt a new payment model in 2019 that would shift from 60-day to 30-day payment episodes and lead to a nearly $1 billion reduction in home health reimbursements.

    Payment in 2018. The $80 million payment adjustment continues a set of reductions mandated by the Affordable Care Act, which began with a $60 million drop in 2015, a $260 million reduction in 2016, and $130 million for 2017. CMS arrived at the overall estimate by weighing a 2% payment increase against various decreases, mostly related to reductions in the 60-day episode payment rate and cuts to account for nominal growth in case mix.

    Episodes of care in 2019. In 2019 CMS would adopt a new payment methodology, known as the Home Health Grouping Model (HHGM), that would change the unit of HH payments from 60-day episodes of care to 30-day episodes of care. According to an article in Modern Healthcare, the change is based on a CMS analysis that concluded that the average length of home health care was 47 days, "but roughly a quarter of all 60-day episodes of care lasted 30 days or less."

    Therapy service use thresholds in 2019. Also part of the HHGM: the removal of therapy service use thresholds that CMS uses to make case-mix adjustments to HH payments. Instead, CMS would "rely more heavily on clinical characteristics and other patient information to place 30-day periods of care into meaningful payment categories," according to a CMS fact sheet on the proposed rule. Combined with the switch to 30-day episodes of care, CMS estimates that the adoption of the HHGM would result in a payment reduction of $950 million in 2019.

    Quality reporting in 2020. CMS is proposing the addition of 3 assessment-based quality measures beginning in 2020: changes in skin integrity postacute care; percent of residents experiencing 1 or more falls resulting in a major injury; and percentage of long-term care hospital patients who receive functional assessments at admission and discharge, as well as a care plan that addresses function.

    General comments on Medicare. As in previous proposed rules, CMS also seeks input on how the overall Medicare system might be improved—an offer APTA took up in its comments to proposed rules earlier this year.

    APTA regulatory affairs staff is reviewing the proposed rule and will submit comments on it to CMS by the September 25 deadline.


    • As a PTA was 24 years experience in which half of this experience in Home Health I believe more cuts than this are necessary. Over the years I have seen too many companies abuse the privilege of being paid 100% through Medicare Part A. Imagine if there was a $20 co-pay on all Home Health visits. This would result in people who really needed Home Health care receiving it. To be honest how many people seen are really and truly home bound? I strongly feel that Home Health needs to get back to providing skilled physical therapy intervention for the people who actually need it not people that just need to move.

      Posted by Bob Sheridan PTA on 7/28/2017 6:45 PM

    • Please stop reducing reimbursements. My rent and cost of living continues to increase while your reimbursements continue to decrease.

      Posted by Margaret Hayes on 7/29/2017 5:36 PM

    • I have worked as a PT for 23 years, 18 of which have been in home health care. If this change goes into effect I predict that many patients will no longer receive PT, OT or SLP at home and that many home health rehab staff will lose their jobs. A switch from 60 day to 30 day certification period will make things a little more difficult. More documentation, more re-certs. While this will pose some problems home health rehab staff should be able to handle it. The end of the case mix adjustment and no more service score with be a major change to home health rehab. This will take away any direct reimbursement for PT, OT and SLP treatment. I predict that home health agencies will react by cutting way back of rehab staff and limiting existing staff to only a few visits per patient. I ask the APTA as our representative to please lobby hard to get this proposed rule changed before it goes into effect.

      Posted by Fred Wixson on 8/6/2017 3:07 PM

    • Working 25 years in home healthas a DPT, I have seen the dire predictions after the Balance budget act of 1997, the changes with OASIS and therapy thresholds all predicting dire outcomes each time for patients. (Crying wolf too many times!) By having a 30 day period it will put the burden upon the DPT to be meaningful and productive. If we aren't helping a patient who has 20$ skin in the game they will likely ask the DPT "what are you doing for me?" I am in favor of these changes.

      Posted by Daniel Huddart -> =FY`BJ on 5/13/2018 7:56 PM

    • While a 20 dollar copay may seem manageble to some, many patients on fixed income do not have that money. They will go without and suffer for it. If there is no financial incentive for home health companies, nurses will not get an order for therapy and visit numbers will be cut to those initiated by physician

      Posted by Michelle mayhew on 9/17/2018 9:00 PM

    • America is spending itself bankrupt on war and tax cuts for corporations and the wealthy. This is austerity. Take needed services from the masses to pay for war and tax cuts. Any bedside RN will tell you, the old folks in America today will never cough up a co-pay. They can’t afford it. The comments above are from morons working for Think Tanks, paid to push the wealth class agenda of austerity. Revolution in this country can’t come soon enough.

      Posted by Richard Barber R.N. on 11/9/2018 6:13 PM

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