• News New Blog Banner

  • APTA Resource Makes it Easy to Deliver Personalized Comments On Proposed Home Health Rule

    If a rule from the US Centers for Medicare and Medicaid Services (CMS) is adopted as proposed, physical therapists (PTs) and physical therapist assistants (PTAs) who work in home health could find themselves in a very different payment environment as early as 2019. That new environment could include a shift from 60- to 30-day episodes of care, and the startup of a new way to make case-mix adjustments that removes physical therapy service-use thresholds from the mix. All told, the changes being proposed could result in a $950 million payment reduction to home health, according to CMS.

    But the rule won't be finalized until later this year, and CMS is asking for public comments on its proposal. Ready to fire up your computer?

    APTA offers a template letter for PTs and PTAs who want to comment on the proposed 2018 home health prospective payment system (HH PPS) and the plans for changes to the case-mix adjustment methodology being considered for 2019. Among other positions, the letter encourages CMS to approach the new case-mix model, part of what's known as the Home Health Grouping Model (HHGM), in a budget-neutral manner and to audition the program by way of a limited demonstration project before making system-wide changes.

    Posted as a Microsoft Word file, the letter was created with the technical formatting that CMS is accustomed to, but it also includes areas that can be personalized with details and examples from the individual PT's or PTA's practice. Those personal touches can help to underscore the messages that the letter's shared elements deliver to CMS with a unified voice—namely, the concern that the HHGM "severely devalues the clinical importance of physical therapy" and negatively affects the most vulnerable patients who have the greatest need for rehabilitation.

    APTA outlined the basics of the proposed rule in a PT in Motion News story and will submit its own comments to CMS by the September 25 deadline. More information on the proposed rule is available through a CMS fact sheet.

    APTA just completed a live webinar on the proposed home health changes. PT in Motion News will alert readers when a recording of that session becomes available.


    • This would be very devastating to the profession and disadvantageous to the patients involved.

      Posted by Carmencita B. Walls on 8/23/2017 5:21 PM

    • Currently, a medium size agency is barely making it for survival. By adding more cut to the reimbursement the clinician who works in the home health field are pushed to find another setting. This will leave a vacuum in the home health business and lack of good clinicians who meet the needs of clients in the home health settings.

      Posted by Tarek Mohamed Hussein on 8/24/2017 12:57 AM

    • I'm glad to see the APTA begin to address this issue. Coupled with the proposed rule change in SNF, also slated for 2019, this would devastate the therapy profession. However it is not surprising that CMS would take these steps following MedPacs recent reports. Regardless each proposed rule will literally financially incentivize providers to NOT utilize therapy services.

      Posted by David Jackson on 8/24/2017 10:45 AM

    • With the CMS regulatory oversight & management of medical & surgical case admissions for primary care facilities and the impetus for short term & outpatient procedure choices, the early rehab interventions provided through home health agencies is a critical & cost conscious part of current comprehensive healthcare delivery. Arbitrary reductions in the Home Care Agency budgets would likely force many current service agencies to severely reduce or eliminate these often critical interventions that frequently prevent hospital readmissions or adverse & possibly life-threatening events during in-home confinement when family members require assistance in establishing the needed care & safety environment.

      Posted by Gary Vande Kamp, PT on 8/24/2017 1:40 PM

    • As a licensed SLP who has worked in home health, I want CMS to know cutting PT and PTA services to home health patients will NOT decrease costs but shift them (back or on) to acute or Long Term care. OT and SLP clinicians beware! When more costs are slated for reductions, we will be next!

      Posted by Maureen McCarron, CCC-SLP on 8/27/2017 12:35 AM

    • This appears to be the classic case of "shift the buck." If policies encourage withholding needed PT services in the homehealth setting, the costs will not be avoided. They will simply be passed on to other venues, where the costs will likely be higher. When therapy services are not provided there will be a cost. The cost will likely be more falls, more wounds, more surgeries, more hospital admits, longer hospital stays, more SNF admits, and the list could go on and on. The modus operandi for CMS seems to be to utilize "rules" as a means to restrict access to services in order to achieve budgetary goals. I believe the "holy grail" for effective healthcare reform is beneficiaryvoter education. Only when the beneficiary/voter knows what they are buying, can a fair approach to cost controls for healthcare costs be achieved. I believe informed beneficiaries/voters would be very upset if they realized how often CMS rules are devised with a tunnel vision perspective on accomplishing budgetary goals without consideration of delivering effective healthcare to beneficiaries. Beneficiaries/voters need to recognize they are being sold a bill of goods, and let legislators hear their discontent at the polls. It would be fantastic to see more effort in bringing these issues to the attention of the beneficiary/voter, and subsequently to our elected officials.

      Posted by William Bieker on 8/27/2017 9:56 PM

    • This idea of saving money on cutting back on PT in the home makes no sense. That means patient are going to have longer stays in the hospital or SNF, which is going to cost more money because they aren't going to be safe to return home. Or the patients are going to be discharged home without home health services and they will fall and end up right back in the hospital causing more expense. Patients are dependent on these home health services and if these services are taken away, how will these patients ever get back to living their life fully functional and independent..

      Posted by Mackenzie Wilkins, PT, DPT on 9/23/2017 10:55 AM

    Leave a comment
    Name *
    Email *