With new conditions of participation (CoPs) coming in 2018 for home health care providers, the recently proposed payment system update feels like regulation overload to an industry already dealing with years of reimbursement rate cuts.
The 2018 Home Health Prospective Payment System Rate Update from the Centers for Medicare & Medicaid Services (CMS) included a proposal to modernize the payment system with the home health groupings model (HHGM), in addition to an $80 million payment cut to the industry for 2018. The HHGM—which categorizes patients into six groups and changes the current 60-day episode of care to a 30-day period—has been hailed as a “significant threat” by stakeholders, while others have said the model will impact margins.
In the context of other regulations taking effect next year, the new payment system is coming too quickly, industry associations argue.
Pump the brakes
While the groupings model could be coming as soon as 2019, home health care providers are still figuring out how to prepare for the new CoPs, which are expected to cost providers nearly $300 million in the first year alone.
CMS has stated that the interpretive guidance, which provides more information on the CoPs, will not be available until December 2017, giving home health care agencies a small window to finalize preparations for the implementation of the new regulations on January 13, 2018. CMS also noted it would not delay the implementation date again—whether providers were ready or not.
“There is a lot of on-the-ground learning in 2018 to make sure everyone is in line [for the CoPs],” Joy Cameron, vice president of policy and innovation at ElevatingHome, told Home Health Care News. “My concern is that it will be information overload. We should pump the brakes and look at this in a way that is much more collaborative. It’s too much too fast.”
A similar issue has been identified with the proposed HHGM, as providers and associations still want more information.
“Given this is such a monumental change, we think it’s prudent for CMS to be transparent and as helpful as possible on the impact,” Bill Dombi, interim president of the National Association for Home Care & Hospice (NAHC), told HHCN. “The consequences of a bad model are not only [an impact] to a home health agency’s bottom line, but on the bottom line of patients and Medicare.”
Dombi also agrees that 2019 is “too soon.”
As providers prepare for the CoPs by educating staff and investing in technology, they are also dealing with payment cuts across the industry.
“We’re already taking a hit and have much less than what we need to invest for [the new] CoPs and HHGM,” Cameron said. “There’s not as much margin there.”
Calling for collaboration
Industry associations have also called for CMS to work more with the industry to finalize the rule. While the proposal is open to a 60-day public comment period on the Federal Register—ending September 25, 2017—stakeholders are eager for more face time with CMS to provide feedback.
One such issue that may require more input from the industry lies in the categorization of patients, as most home health care patients are afflicted with multiple chronic conditions.
More than half of home health patients have five or more chronic conditions, according to Cameron. How patients are categorized when they have several serious conditions is yet another unanswered question, she said.
“If they’re trying to move to patient-centered payment, then [they] need to consider the whole patient, and you can’t consider the top two ailments the person has,” Cameron said. “When you’re in the home and providing care, you have to consider all the aspects. If [a patient has] diabetes or cognitive issues, is that not [CMS’] concern?”
However, the industry is not opposed to changing the payment system, particularly if it can become more patient centered.
“There is great value in modernizing and even replacing the system and stepping away from anything that is a utilization-driven model,” Dombi said. “A lot of negative things can come from that.”
Dombi believes CMS should push back the proposed implementation date of the model and open up a discussion with the industry. The association is already planning to challenge the proposal.
ElevatingHome argues that CMS should have allowed the industry to take part in shaping the proposal with an Advanced Notice of Proposed Rulemaking, and included agencies and associations to discuss areas of concern, education assistance and a timeline for implementation, Cameron told HHCN.
“We would like an opportunity to sit down and talk this through with CMS in a more collaborative way,” Cameron said. “We’re not saying we can’t do this. Just if we’re going to do this, let’s answer all the questions in advance.”
Written by Amy Baxter
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