The U.S. Facilities for Medicare & Medicaid Companies (CMS) formally closed its public remark window for the 2021 proposed dwelling well being cost rule on Monday.
Not like the previous couple of years, the newest proposed cost rule included comparatively minor adjustments and price changes for the yr forward. In gentle of the delicate proposal, CMS solely acquired 161 feedback from dwelling well being stakeholders.
When initially releasing its proposal, company officers prompt that CMS did need to make any drastic overhauls because of the ongoing transition to the Affected person-Pushed Groupings Model (PDGM) and the disruption brought on by the COVID-19 virus.
The 2021 proposed cost rule included growing Medicare funds to dwelling well being companies by 2.6%, a bump worth an estimated $540 million. Comparatively, the 2020 proposed rule included a rise of 1.3%.
The proposed rule additionally made sure telehealth necessities granted throughout the public well being emergency everlasting, such because the face-to-face requirement for dwelling well being. It additionally created new Medicare enrollment insurance policies for certified dwelling infusion remedy suppliers and up to date the house infusion cost charges.
The Nationwide Affiliation for Residence Care & Hospice (NAHC) was among the many group of 161 commenters that made its emotions recognized. Whereas CMS has but to publicly launch all the feedback, the Washington, D.C.-based advocacy group shared a duplicate of its feedback with Residence Well being Care Information.
In its feedback to CMS, NAHC first addressed the cost programs in place for dwelling well being companies — and why they’re, at instances, insufficient for an trade coping with COVID-19 head on. Particularly, NAHC urged CMS to determine a course of that may modify dwelling well being company cost programs and charges throughout a public well being emergency.
Greater than half of all dwelling well being companies have now handled COVID-19-positive sufferers in 2020, in line with NAHC information. And whereas the hospitals and expert nursing services (SNFs) have seen changes made to their cost models and quantities, dwelling well being companies haven’t.
“Instead, the COVID-19 patients have had to be fit into a payment model that had no such comparable patients in its foundational database,” NAHC wrote in its feedback to CMS.
The feedback had been listed in a letter signed by NAHC President William A. Dombi, together with Mary C. Carr, vice chairman of regulatory affairs. Katie Wehri, the director of regulatory affairs, additionally signed.
CMS left dwelling well being companies out of comparable aid elsewhere. Hospitals, for example, can now present reimbursable digital take care of sufferers inside their dwelling. Residence well being companies are nonetheless unable to take action.
“CMS should develop a model for claims reporting and payment for home health visits provided by telecommunication,” NAHC wrote.
NAHC additionally requested for clarification on audio-only expertise and believes it needs to be included within the permitted telecommunication applied sciences umbrella transferring ahead.
Permitting suppliers to be reimbursed for telehealth visits rather than in-person visits would cut back person-to-person contact, which might additionally lower the quantity of PPE every company would wish — a ache level for suppliers since COVID-19 hit the U.S.
PPE, on common, was costing every company $11.50 per go to and elevated 30-day prices by over $100 — roughly 5% of base cost charges, in line with NAHC.
That 5% mark is troublesome as a result of the Supplier Reduction Fund, which derived from the CARES Act, solely coated 2%, on common.
“If CMS had included a process for mid-year adjustments for unexpected cost increases, stabilization of home health care access would be more readily achievable,” NAHC wrote.
NAHC recommends that CMS embody a PPE price add-on to the 2020 cost episodic and per-visit cost charges.
Shifting ahead with PDGM
The speed of Low Utilization Cost Changes (LUPAs) in 2020 is prone to be far completely different from what CMS initially anticipated.
“While the available data to date obviously does not represent a full year of experiences under PDGM, it is equally obvious that the existing data shows a massive increase in LUPA episodes in clear contrast to the decline assumed by CMS,” NAHC identified.
Information suggests LUPA charges are 2 to three instances what was anticipated out of companies in 2020, in line with NAHC.
Nonetheless, general, NAHC agrees with CMS’s choice to face pat on PDGM and its continued utility in dwelling well being, regardless of the pandemic.
At this level, it’s too onerous to know whether or not the cost model is working as deliberate, given the consequences of the COVID-19 disaster and it nonetheless being a comparatively new model.
NAHC did have one specific advisable change to PDGM, nevertheless.
“One exception is that CMS should restore the use of symptom codes as a patient diagnosis. Practitioners continue to use these codes in patient referrals and care planning for home health patients,” NAHC wrote. “Given that other reimbursement systems in Medicare accept these codes, CMS should incorporate these codes into the existing model with later refinements where needed.”