APTA illustrates several ways that the home health prospective payment system (HH PPS) can be revised to better reflect the role of physical therapists in home health, as well as bolster clinically appropriate practice patterns that improve quality of care and lower growth in expenditures, in comments submitted on September 4 to the Centers for Medicare and Medicaid Services (CMS).
APTA's remarks focus heavily on therapy coverage requirements. While calling on CMS to begin the work of developing an alternative payment system for therapy services under the Medicare home health benefit, the association makes specific interim recommendations to alleviate the burdens associated with missed reassessment visits and alter provisions regarding coverage of compliant therapy disciplines and visit ranges.
In response to CMS' quality reporting proposal, APTA advocates for the alignment of HH measures with current measures under the inpatient prospective payment system. Specifically, the association asks that CMS apply consistent measures regarding emergency department use and readmissions.
Recognizing CMS' commitment to ensuring that home health payments are accurate and are not unduly influenced by practices not associated with changes in the patient's condition, APTA recommends that the agency find alternative ways to account for these nominal case-mix changes that do not impose further cuts to HH PPS.
Finally, APTA urges CMS to finalize its proposal to provide more flexibility in the physician face-to-face requirement.