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  • Making the Profession's Voice Heard on Home Health: Multifaceted Advocacy Efforts Deliver Strong Message to CMS

    While the US Centers for Medicare and Medicaid Services (CMS) considers what to do with a proposed rule that APTA says creates "perverse financial incentives" for reductions in care in home health (HH), APTA and its members can be satisfied that the association, its components, and individual members mounted a strong, multifaceted education and advocacy effort that is likely to grab the agency's attention.

    The focus of the efforts is to stop CMS plans for a new HH payment system that reduces episodes of care from 60 to 30 days and shifts to a new case-mix model, called the Home Health Grouping Model (HHGM), that removes therapy service-use thresholds from the payment mix. CMS estimates that the combined effects of the proposed changes would result in a $950 million payment reduction to the HH payment system beginning in 2019.

    APTA identified glaring problems in the proposal almost immediately after it was released in late July and collaborated with the APTA Home Health Section to launch a series of advocacy efforts to ensure that CMS would receive a clear, unified, and strong reaction by the September 25 public comment deadline. Those efforts included:

    • A joint webinar with the APTA Home Health Section
    • Multiple meetings with policymakers on Capitol Hill, resulting in separate letters from Senator Orrin Hatch (R-UT) and 49 Senators, both telling the agency not to move forward with the HHGM proposal
    • Strategy discussions with other organizations, including the National Association for Home Care & Hospice and the Partnership for Quality Home Healthcare
    • Alerts to the PTeam, the association's advocacy network
    • Grassroots alerts to 4,300 members urging them to contact their member of Congress about stopping the HHGM plan
    • Meetings with CMS representatives in which APTA was joined by representatives from the American Occupational Therapy Association and the American Speech-Language-Hearing Association to discuss shared concerns
    • Educational sessions on the HHGM at the APTA State Policy and Payment Forum held in mid-September
    • A podcast created with Talus Media
    • The creation of a template letter for members to use in writing to CMS about the proposed rule

    A final decision on the proposed rule isn't likely to be released until sometime in November, but CMS records show that APTA's grassroots advocacy efforts made an impact, at least when it comes to the contents of the CMS inbox: as of the comment deadline, CMS reports that it has received 1,349 comments on the HH rule.

    "At this stage we don't know where CMS is going with the HHGM," said Kara Gainer, APTA's director of regulatory affairs. "But the level of collaboration and individual effort throughout the association, combined with our cooperative efforts with other organizations opposed to the rule, has sent a very clear and forceful message to CMS. We think this proposal will harm patients, and we hope CMS is getting that message loud and clear."

    CMS Shelves Controversial Orthotics and Prosthetics Proposal

    The US Centers for Medicare and Medicaid Services (CMS) has killed a controversial proposal that would have restricted many physical therapists (PTs) from furnishing custom orthotics and prosthetics. The proposal was opposed by APTA and a host of other provider and patient advocacy organizations.

    The proposed rule, issued in January, would have required PTs to be "licensed by the state [as a qualified provider of prosthetics and custom orthotics], or…certified by the American Board for Certification in Orthotics and Prosthetics…or by the Board for Orthotist/Prosthetist Certification." The association voiced its opposition to the CMS plan, characterizing the proposal as a set of unnecessary requirements that would limit patient access to appropriate care.

    The March 13 deadline for comments passed, and CMS issued no further communication on the proposal until last month, when a notice that the proposal was being withdrawn from the White House Office of Management and Budget’s “Unified Agenda” indicated that the proposal was no longer under active consideration by CMS. On October 3, notice that the proposal would be officially withdrawn appeared in the Federal Register, with the withdrawal document itself scheduled to be published the next day.

    The withdrawal represents a win for thousands of PTs who would have been saddled with significant additional regulatory and financial burdens in order to qualify as a provider. In addition to its direct comments to CMS, APTA's advocacy efforts included meetings with CMS and the creation of a template letter to be used by many members to voice their individual opposition to the proposal.