“Opposed.” That was the one-word response a home health provider left for the Centers for Medicare & Medicaid Services’ (CMS) during the comment period on the 2025 home health proposed payment rule.
This comment was an anomaly, in terms of its brevity. While most respondents expressed similar sentiments, they chose to utilize more words to do so.
Overall, providers went into detail about the specific challenges they are facing in their market, and why the proposed payment rule would impact access to care.
Below are the comments Home Health Care News thought stood out from providers, as they see their margins decrease year over year.
Some comments have been edited for length and clarity.
***
Within our market, the incidence of home health admissions that include wound care and specifically the types of wounds included within this proposal are increasing. Any decrease to reimbursement for HHAs who are treating these types of wounds would be detrimental to patient care. The cost of supplies continues to increase like everything else in the economy and labor costs to access skilled nurses or therapists who actually have proper wound care treating in these types of cases are also increasing.
In our agency, we recently had to refer a patient who was sent to us to another agency due to the patient’s insurance. The patient developed a pressure wound and the nurse who was sent to treat the patient was not properly trained in wound care. Over the next few weeks, the patient reported that the wound was increasing in severity and he was concerned that the nurse did not seem to know what she was doing. He requested that she get some additional help. The nurse brought her supervisor to observe the wound care provided and ask if it was proper or adequate. The supervisor instructed her that the only thing she could do correctly at that point was call an ambulance for the patient. The patient had developed gangrene in the wound and was transported to a hospital. A few weeks later, the patient’s leg was amputated just below the knee. The result of amputation resulted in significantly higher expense to Medicare than paying for adequate wound care wound cost. Worse, the patient’s quality of life is now irreversibly affected by loss of limb.
I understand the need to try to reduce expenses and cut costs across our federal budget. Home health is a great program that allows for significant improvement in patient outcomes while decreasing hospitalization. I strongly encourage Medicare to consider increasing spending for home health companies to provide quality supplies and hire or train their staff with the necessary certifications and skills needed for advanced care in the home. While the expense for home health may increase, I don’t think it’s a surprise that the rate of hospitalization will decrease and that significantly decreases the overall cost of health care while also improving patient outcomes.
— Primary Home Health LLC
***
I am an administrator of a small independent home health care agency in Calumet City, IL. Every year we are fighting for survival and every year CMS is proposing to cut reimbursement and adding more regulations. Unfortunately, it is the same this year. There has got to be a way that you come up with a plan to stop this madness. It is difficult to pay nurses and have enough people in the office to maintain all of the regulatory requirements. Can you please remove some of the regulations so we can get back to the business of taking care of patients? You just extended RCD 5 additional years. You have extended HHVBP. You have added NOAs but didn’t remove any regulatory burdens nor have you given an increase in reimbursement. The hospital systems are dropping home health agencies like flies in Illinois because it appears we are not valuable. Independent home health agencies are closing because they can’t provide care, pay field staff and keep up with the regulatory burdens put upon us by you. We need a break, please!
— Deirdre Hezekiah Onwukwe
***
I would like to express my concerns regarding the recently released proposed rule for the CY2025 Home Health Prospective Payment System (HH-PPS). As an occupational therapist and a former home health provider, the proposed changes could significantly impact access to quality occupational therapy services for Medicare beneficiaries. Reducing payment for key occupational therapy services raises alarms about the sustainability of these essential services, which play a crucial role in enhancing the well-being and independence of patients in their home environments. It is required to maintain focus on ensuring that Medicare beneficiaries receive the highest quality of care, and adequate compensation for occupational therapy. I urge CMS to reconsider these proposed payment reductions to ensure that patients continue to receive the necessary occupational therapy services for their recovery and overall health.
— Vera Gallagher
***
While we appreciate CMS’ efforts to combat fraud, waste, and abuse, CMS must provide clear guidance to any provider under a PPEO, including the timeline for reviews, the process for any appeals, and the criteria for when sanctions and penalties are imposed.
CMS’ proposed rate reduction does not consider the high costs of inflation, staffing shortages, turnover, and labor stresses that home health providers are facing. Combining those challenges with significant cuts to funding would reduce our patients’ access to life-changing care. This affects the patients who need us the most who may not have the funds and are most vulnerable.
The most vulnerable populations rely on our high-quality care and these cuts will restrict their access to care, particularly in rural and underserved areas.
Changes to the wage index will move some agencies from an urban designation to a rural one, thereby further reducing their reimbursement at a time when rural agencies are facing increased challenges recruiting and retaining employees.
We give excellent care to all who need us and even give charity/indigent care as we can but further cuts to our funding would make it almost prohibited. Our clinicians work very hard and they are not given annual raises, in fact some have not had a raise in almost 3 years. Home health is not an easy job, it is an act of the heart and yet they give everything they have to the patients and community we serve!
— Seaport Scripps Home Health
***
My home health agency serves rural Wyoming. With the high cost of supplies, labor, recruitment and overall cost to service a rural area, the proposed Rule will nearly eliminate our ability to continue to service these areas. We are currently facing high inflationary wages And stiff staff competition with the hospital and other health care providers. A 4% reduction in our reimbursement will only exacerbate the issue.
The 5% wage index cap also prevents our rural communities from obtaining a market rate wage that allows us to hire competitively.
The need for home health in rural communities is only becoming more and more necessary. This rule will prevent all home health agencies from being able to have sustainable reimbursement to service rural communities.
CMS needs to consider the overall stress home health agencies are under with the current economic environment. CMS should consider a reimbursement increase of 5%.
— Symbii Home Health and Hospice Wyoming
***
Compared to CY 2024, CMS estimates a decrease of 1.7% in Medicare payments to HHAs for CY 2025. Henry Ford Health is concerned that the annual update to the home health payment rate has not kept pace with significant increases in the cost of labor, medical supplies and other resources needed to provide high-quality care to our patients.
Much of this cut is attributable to a 4.067 percentage-point decrease that is a result of the behavioral assumption adjustment. CMS’ behavioral assumption adjustments are in direct response to regulatory changes that home health providers are required to follow since implementation of the PDGM on January 1, 2020. These behavioral assumptions are challenging because they are punishing home health providers for decisions brought on by regulatory change. For instance, one reason for lowering payments under the behavioral assumption adjustment was the assertion that there would be an increased volume of “home health periods of care” that would receive a comorbidity adjustment resulting from considering all 24 comorbidities on a claim rather than just five. Specifically, the intent of the PDGM was to rely more heavily on clinical characteristics and other patient information to place home health periods of care into meaningful payment groups, with 432 possible case-mix adjusted payment groups.
As a result of the effects of these changes – as well as to PDGM calculations, low-utilization payment adjustment (LUPA) threshold and outlier reimbursement – HHAs will experience even deeper cuts than the 1.7%. Henry Ford Home Health Care estimates that the reduction is closer to 2.3%.
— Henry Ford Health
***
You continue to cut reimbursement to providers and limit access to services that impact independence, member health, sustainability for providers, and ability for members to remain at home. You cut these services and then blame the providers for poor outcomes. By limiting access to these services, Medicare in the end spends more money to provide services to members in hospitals and skilled nursing facilities. It is time to support members in their home and maintain their health in the first place. It is far less expensive for Medicare to treat people who are healthy enough to recover than to provide services once diseases have progressed and prognosis is far less positive.
— Anonymous
Companies featured in this article:
