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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."


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