Important HHGM Update Released on 10.27.17

Posted on Friday, October 27, 2017 5:44 PM

Bill Dombi, President of NAHC, released an email about a possible HHGM rescue proposal as they team up with Elevating Home/VNAA and Almost Family. See below for the communication from Bill Dombi:

Yesterday, NAHC, the Partnership, Elevating Home/VNAA, and Almost Family reached an united agreement on a proposal to rescue the home health community from the threat of the CMS proposal to institute the Home Health Groupings Model (HHGM). That proposal was presented last night to staff from the House Ways and Means Health Subcommittee. It is not a perfect solution. However, given the CMS actions and its inaction to withdraw the HHGM proposal, NAHC and others have taken this step of seeking direct legislative intervention. Our proposal was crafted after many hours, involving difficult choices, and necessary compromises.

Over the past few weeks, NAHC and others concluded that the threat posed by HHGM was so great that it needed to be withdrawn wholesale particularly in light of the lack of transparency that shrouded the proposed rule and its impact on home health care. A nearly endless series of meetings and other communications with CMS did not result in the withdrawal of the proposal nor did CMS provide the information that had been sought to better understand its impact. NAHC and others submitted significant formal comments in the rulemaking process challenging the legal validity of the proposal and questioning the merits of the policy.

A campaign was initiated to garner congressional support in our fight. A bipartisan majority of the Senate and over 158 members of the House asked CMS on our behalf to withdraw the proposal. CMS has not heeded that request. Instead, CMS has stayed silent and has provided not even a hint that it will withdraw this dangerous proposal. We are now approaching the deadline for CMS to issue the Final Rule. While it remains possible that CMS will withdraw the HHGM proposal or modify it in some way, NAHC has determined that we cannot count on CMS to do the right thing.

As stated earlier, the proposal is not perfect. Also, there may not be enough time for Congress to act. Nevertheless, it is in the best interests of the home health community that we try to secure this relief.

The core elements of the proposal include the following:
1. The rule is withdrawn by way of congressional/CMS agreement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 a $1772 rate
6. The inflation update (MBI) is reduced by 0 .5 MBI in 2021-2023
7. Rural add-on is extended for 5 years
8. The NAHC devised reform to the F2F and physician documentation is implemented
9. The NAHC bill that permits Non-physician Practitioners to certify Medicare home health services is enacted
10. The current Home Health Value Based Purchasing Program demo is extended to all 50 states, DC ,and territories.

While this outline includes a number of important positive changes, it also has its financial impact. The proposed rate of $1772 would be a rate cut. However, it is significantly less of a cut than CMS proposed at approximately $1600. Also, the proposal to shift to a 30-day payment unit is an important departure from the 60-day standard in use since the beginning of prospective payment.

The proposal includes a number of specific protections that would prevent CMS from taking steps like HHGM again. It would also maintain the use of a 60 day plan of care, certification , and OASIS timetable.

If the matter progresses in Congress, it may change. However, NAHC is willing to compromise only so far. Access to care must be preserved. The whole home health benefit must be protected. The home health community must have a chance to remain financially viable.

If we do not succeed with the congressional effort, NAHC will continue to fight against HHGM as it is not slated for implementation before 2019. And we will take our fight to federal court if needed. We earnestly hope that CMS will prefer to work with the industry rather than fight it. We remain hopeful that CMS will see the light and that the Final Rule does withdraw the HHGM proposal. We will know what CMS will do in the next few days.

Thank you for all of your support. We look forward to a favorable conclusion to this Medicare chapter. In the end, we strongly believe that home health care will continue to progress and grow as it is an essential part of health and the solution to many of the problems in care today.

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