The general public remark window for the house well being proposed fee rule closed on Tuesday. General, trade stakeholders had submitted 691 feedback to the U.S. Facilities for Medicare & Medicaid Companies (CMS) as of Tuesday morning.
From the beginning, house well being stakeholders took subject with CMS’ methodology for figuring out whether or not the Affected person-Pushed Groupings Mannequin (PDGM) led to budget-neutral spending in 2020.
For the Nationwide Affiliation for House Care & Hospice (NAHC), this remark interval has given the group the chance to assessment the methodology that CMS used to undertake its evaluation, at the least to some extent, William A. Dombi, president of NAHC, informed House Well being Care Information.
“We have been handicapped by way of the depth that we may analyze CMS’ methodology, as they refused to provide a wide range of knowledge that we expect is important to duplicate what they’ve achieved,” he mentioned. “There are loads of holes within the data they offered, however there was sufficient data offered to point to nearly a universe of commenters that CMS actually wasn’t compliant with the legislation, and wasn’t utilizing an analysis methodology that made sense.”
Alongside these strains, the trade can be collectively on the identical web page about CMS’ everlasting behavioral assumption adjustment of -7.69%, based on Dombi.
“It’s surprisingly inconsistent with the best way CMS approached the expert nursing facility sector — primarily the identical sort of analysis want — wanting whether or not or not motion from one fee mannequin to a different was price range impartial,” he mentioned. “I believe the consensus is very sturdy that CMS wants to return to the drafting board.”
On its finish, NAHC submitted its formal feedback on Tuesday.
Commenters additionally took subject with the proposal’s failure to totally handle operational inflation pressures house well being suppliers have been going through.
“House well being funds ought to replicate the price of inflation, gasoline costs and elevated price for recruitment and retention,” a commenter lamented. “House well being businesses are struggling to rent workers and compete with large will increase in pay by hospitals who’ve acquired large quantities of COVID cash.”
The proposed fee replace proportion is 2.9%. That is under present inflation, which peaked at 8.5% in March.
“Though a 2.9% enhance is inadequate to permit businesses to maintain up with inflation and different monetary pressures, we imagine any enhance in reimbursement will assist beleaguered businesses,” the Affiliation of House Care Coding and Compliance wrote in its official feedback.
Many expressed that companies would take successful and entry to care companies can be severely compromised.
“The influence of this proposed change can be devastating for house care businesses, and extra importantly, it’s going to restrict entry of care to beneficiaries that want it, as businesses can solely scale back efficiencies a lot earlier than the standard of care [and] affected person satisfaction are impacted,” one other commenter mentioned.
Feedback from one group, nevertheless, did obtain pushback from NAHC.
“One set of feedback we did assessment was these provided by the Medicare Fee Advisory Fee (MedPAC),” Dombi mentioned. “MedPAC has been saying for years that house well being fee charges ought to be minimize, in order that they like what CMS is proposing. However at no level did MedPAC even consider the bona fides of what CMS was proposing. What stood out for me was that MedPAC cares in regards to the consequence of lowered fee charges, moderately than the validity and the results of it.”
Dombi additionally took CMS to activity for the contradictions surrounding the company’s objectives for the House Well being Worth-Primarily based Buying Mannequin (HHVBP) enlargement.
“CMS is betting on the success of a House Well being Worth-Primarily based Buying Mannequin enlargement nationwide to garner nearly $3.5 billion in Medicare financial savings via lowered hospitalizations and the like,” he mentioned. “But they’re pulling assets away from house well being businesses to succeed in these objectives. It appears so counterproductive what CMS is doing in slicing fee charges, growing prices and undervaluing the inflation that each one of well being care goes via.”
Whereas house well being stakeholders have been submitting feedback for CMS’s consideration, trade advocates have been additionally engaged on the legislative entrance.
Final month, the Preserving Entry to House Well being Act was launched into the Senate. The invoice was launched by Sens. Debbie Stabenow (D-Mich.) and Susan Collins (R-Maine); it will cease CMS from reducing house well being funds till 2026.
Not lengthy after, an similar invoice was additionally launched within the Home of Representatives. This invoice was launched by Reps. Terri Sewell (D-Ala.) and Vern Buchanan (R-Fla.).
Finally, Dombi believes that the efforts on the legislative aspect might be a manner ahead.
“We’re getting very favorable responses from Home and Senate, Republicans and Democrats, to what that laws is meant to do,” Dombi mentioned. “We do see it as a failsafe of types, ought to CMS select to not repair what it’s proposed. We’ll proceed that advocacy so long as needed.”
LeadingAge and several other of its house well being supplier members likewise submitted feedback earlier than Tuesday’s deadline.
“On the one hand, the Biden administration has persistently and publicly promoted its dedication to making sure older People’ entry to high quality getting older companies – with an emphasis on care within the house and neighborhood,” Katie Smith Sloan, president and CEO of LeadingAge, mentioned. “But in its actions, the administration is undermining suppliers’ capability to ship these important companies. Simply because it did with nursing properties, CMS is unfairly assuming all suppliers are unhealthy actors. This isn’t acceptable.”
Mark McPherson, president and CEO of Trinity Well being at House, echoed these remarks.
“Fee cuts now will probably be devastating,” he mentioned. “CMS’ 2.9% inflationary issue assumption is unsuitable on a number of ranges. Our base wages, coupled with signal ons and referral bonuses, elevated labor prices by 4.5%. Gasoline costs, in addition to these of private protecting gear and different provides, have ballooned. We’ve been making arduous selections for months; we flip away 250 admissions every week as a result of we would not have sufficient workers. CMS should perceive that with this price minimize and staffing challenges, older adults merely is not going to get a lot wanted care.”