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Home Health Industry Pushes Back on CMS Budget-Neutrality Methodology for PDGM

Because the launch of the U.S. Facilities for Medicare & Medicaid Companies’ (CMS) proposed fee rule, residence well being stakeholders have been sitting of their respective “battle rooms” attempting to navigate the proposal.

As suppliers equipped for the revealing of the proposal, many knew that CMS’ evaluation of whether or not the Affected person-Pushed Groupings Mannequin (PDGM) led to increased, decrease or equal spending in comparison with the outdated fee mannequin could be a significant factor, in response to William A. Dombi, the president of the Nationwide Affiliation for House Care & Hospice (NAHC).

Many are pushing again in opposition to CMS’ methodology for assessing price range neutrality, with organizations akin to NAHC expressing their issues even previous to the discharge of the proposed rule.

“After we came upon on Friday that CMS selected to make use of the identical methodology which had been roundly condemned by anyone who had evaluated it, we needed to conclude the CMS had successfully declared battle in opposition to residence well being,” Dombi stated. “I don’t imply that in an emotional sense, however in a sensible sense, the place the result of this proposal might be terribly — not simply disruptive — however devastating to the house well being care neighborhood.”

He made these feedback throughout NAHC’s newest webinar on Thursday.

Total, the proposed rule comes with a decrease to payment rates by 4.2%, or $810 million much less in comparison with 2022 charges.

“CMS solely will get to that [$810 million] by including within the inflation replace, so the inflation replace for 2023 is a meager 2.9%,” Dombi stated.

The proposed rule additionally features a 7.69% PDGM budget-neutrality adjustment.

“It’s startling to see on this interval of excessive inflation, this great change within the degree of the bottom fee charges,” Dombi stated.

Together with the modifications within the fee price, CMS principally maintained the identical PDGM case combine mannequin however, like final yr, the company recalibrated all 432 case combine weights. CMS additionally recalibrated the LUPA thresholds for the primary time since 2020.

Dombi famous that CMS realized the significance of maintaining “some degree of stability” for suppliers of companies because of the modifications made to final yr’s wage index.

“Like they’ve performed of their proposal for expert nursing services, hospitals, hospices, and all different supplier sectors the place there’s a wage index relevant, CMS proposes to institute a everlasting 5% cap on any unfavourable wage index modifications that might replicate modifications in workforce prices,” he stated.

Moreover, CMS modified the outlier fixed-dollar loss to 0.44, which might then change the variety of outlier episodes.

“CMS does make these modifications for functions of staying throughout the 2.5% of the Medicare spend as a price range for outlier spending,” Dombi stated.

The house well being trade is at the moment getting ready for the nationwide growth of the House Well being Worth-Based mostly Buying (HHVBP) Mannequin.

In CMS’ proposal, the beginning date of Jan. 1, 2023 stays the identical, however there are some modifications on the standard reporting. This consists of the requirement that OASIS should be performed for all sufferers — no matter payer supply.

Shifting ahead, NAHC is leaning into its advocacy efforts for the house well being trade as a way to activate modifications forward of the ultimate rule.

“This isn’t a proposal that we will simply really feel comfy and relaxed with to maneuver ahead with,” Dombi stated. “It is a rule which goes to require a major quantity of advocacy efforts from all of us, as a way to find yourself with an alternate consequence than what we see proposed right here by CMS.”

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