AHA stated that the two.7 % Medicare reimbursement replace for house well being companies doesn’t precisely replicate the monetary challenges that house well being companies have confronted in the course of the pandemic.
The American Hospital Affiliation (AHA) has urged CMS to rethink the Medicare reimbursement replace for house well being companies proposed within the Calendar Yr 2023 Residence Well being Potential Cost System (PPS) Fee Replace.
AHA expressed issues concerning the proposed Affected person-Pushed Groupings Mannequin (PDGM) behavioral offset, market basket replace, and productiveness adjustment.
The updates included within the proposed rule would lower Medicare funds to house well being companies by $810 million in 2023.
Along with the unique behavioral offset of 4.36 % in CY 2020, CMS proposed a 7.69 % behavioral offset to the 30-day fee fee for CY 2023. The company said that the extra offset displays its statutory requirement to make sure PDGM price range neutrality.
AHA asserted that the proposed behavioral offset is predicated on flawed assumptions and would inaccurately penalize house well being suppliers. The offset fails to account for the lower in common per-episode remedy providers below PDGM, which might have decreased funds below the prior case-mix system.
As such, we urge CMS to not finalize any price range neutrality adjustment for CY 2023. As a substitute, we ask the company to reevaluate its PDGM price range neutrality methodology to account for the drop in remedy in CY 2020 and subsequent years. Doing so may considerably scale back or negate the necessity for any behavioral offset, or really create the necessity for a future restoration of funds.
AHA additionally opposed the proposed market basket replace of three.3 % for CY 2023. The replace doesn’t replicate the monetary struggles that house well being companies are experiencing, the group wrote. The COVID-19 pandemic and rising inflation have led to elevated prices and financial instability for healthcare suppliers.
In response to AHA, if CMS had used newer information, the market basket adjustment would extra precisely replicate the financial setting by which house well being companies are working.
AHA requested CMS to make clear within the closing rule how the company will account for the elevated prices that aren’t mirrored out there basket replace and the way it will guarantee sufferers preserve entry to house well being providers.
The letter voiced concern concerning the proposed productiveness discount as effectively. The rule included a productiveness adjustment of 0.4 share factors, which, when coupled with the market basket replace, would end in a 2.7 % fee enhance for CY 2023.
AHA has requested CMS to elaborate within the closing rule on the productiveness positive aspects that the discount is predicated on, because the lower doesn’t align with the losses house well being companies have confronted in the course of the pandemic.
The usage of the personal nonfarm enterprise [total factor productivity] is supposed to seize positive aspects from new applied sciences, economies of scale, enterprise acumen, managerial abilities, and adjustments in manufacturing. Thus, this measure successfully assumes that [home health] companies can mirror productiveness positive aspects throughout the personal nonfarm enterprise sector. Nonetheless, in an economic system marked by nice uncertainty attributable to inflation in addition to demand and provide shocks, this assumption generates vital departures from financial actuality.
AHA supported the proposed 5 % cap on wage indexes to mitigate adjustments in house well being funds. Nonetheless, the group urged CMS to implement this modification in a non-budget-neutral method for the house well being PPS and different fee methods.
The rule included a proposal to require house well being companies to report high quality information on all sufferers no matter their payer within the Residence Well being High quality Reporting Program (HH QRP). CMS stated house well being companies should submit this information starting January 1, 2024.
AHA requested the company to increase the implementation requirement till a minimum of January 1, 2025 to account for the elevated burden and provides suppliers extra time to organize
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