Unified Compromise Proposal to House Ways and Means Committee to Withdraw HHGM

In an unprecedented display of industry collaboration, a unified compromise proposal was offered to the House Ways and Means Committee in an effort to gain a withdrawal of the HHGM proposal from the CY2018 Home Health Prospective Payment System final rule. As we have previously advised, the final rule is with the Office of Management and Budget, but is expected to be finalized in the next few days. In order for any element of the rule to take effect by January 1, 2018, it must be finalized and released by November 1.

There was much discussion, collaboration, and compromise among all parties to reach this unified proposal. The providers and associations, along with their Boards, involved in developing the consensus proposal included ElevatingHOME, the National Association for Home Care and Hospice, the Partnership for Quality Home Health Care, Kindred, Healthsouth/Encompass, Amedisys, LHC Group, and Almost Family. 

The core elements of the proposal include the following:

  1. The rule is withdrawn by way of Congressional and CMS agreement.
  2. Home health reforms are implemented, but no earlier than 2020.
  3. Reforms are developed through stakeholder involvement and the use of a CMS Technical Experts Panel subject to fully transparent public notice and comment opportunities.
  4. The reforms include shifting to a 30-day payment period from the existing 60-day episodic payment.
  5. The base 30-day payment rate is set at $1772.
  6. The inflation update (MBI) is reduced by 0.5 MBI in 2021-2023.
  7. Rural add-on is extended for five years.
  8. Reform to the F2F and physician documentation is implemented.
  9. Reform allowing nurse practitioners and other advance practice nurses to certify Medicare home health services is enacted (H.R. 1825/S. 445).
  10. Stratification of the Medicare Home Health Improper Payment Rate as overpayment, underpayment, documentation error, or improper care.
  11. The current Home Health Value Based Purchasing Program demo is extended to all 50 states, DC, and territories.

At this time, we are awaiting a response from the House Ways and Means Committee staff. Please contact Joy Cameron with any questions.