Data from a recent study of Medicare home health cost reports supports the case that the home health industry didn’t respond with the behavioral adjustments that CMS predicted prior to PDGM. And agencies have experienced increased challenges due to the public health emergency (PHE) that CMS should consider when finalizing the 2021 payment rule.
The Partnership for Quality Home Healthcare (PQHH), the Washington-DC-based company that commissioned the study, is recommending that CMS “consider taking corrective action to increase the base rate so the HH PPS will be more likely to achieve budget neutrality in the CY2021, as authorized by the Bipartisan Budget Act of 2018.” That’s according to comments to the proposed 2021 home health payment rule submitted by this company.
“Regardless of the root cause, two of the three anticipated behavioral changes that CMS used to justify prospective payment rate reductions have not occurred as of April – overall payments and case volume are down with very high LUPA rates. This affects case-mix severity in complex ways; the PHE may be the predominant cause of the observed increase in case-mix severity rather than provider adjustments,” the comments state.
PQHH commissioned Dobson | DaVanzo & Associates to examine 2020 Medicare claims data that included 2.6 million 30-day PDGM episodes and have included some of the data in their comments.
To view the full comments, visit https://bit.ly/3h6oK5q.