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NAHC Comments to CMS on CY2019 Proposed Payment Changes

Posted on Sunday, September 9, 2018 8:25 PM

CMS asked for comments to be submitted about proposed changes to payments for calendar year 2019 by August 31, 2018.  NAHC submitted their comments last week, here is a summary of their submissions.

NAHC continues to have concerns using an admission source in the case mix and believes this could unfairly disadvantage Medicare beneficiaries referred to home health from the community. 

They also stated that they are concerned about payment accuracy since the payment model incorporates non-routine supplies into the base payment rate instead of as an add-on.  The cost for therapy services is reduced when using cost report data rather than wage data from the Bureau of Labor Statistics, which has been the source for cost data for the HHPPS since 2000.

NAHC recommends that CMS maintain the single LUPA threshold instead of shifting from a LUPA with a threshold capped at 4 visits in a 60-day episode to a LUPA threshold that ranges from 1-5 visits over a 30-day period can have unintended consequences in terms of over or under payments for 30-day periods.

NAHC also disagrees with CMS’ plans to eliminate RAPs for new home health agencies under the PDGM. 

Source: NAHC Report

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