LeadingAge NY members are encouraged to submit comments on the Calendar Year (CY) 2023 Home Health Prospective Payment System (PPS) Proposed Rule by 5 p.m. on Tues., Aug. 16^th. Member Certified Home Health Agencies (CHHAs) may submit their own comments to the Centers for Medicare and Medicaid Services (CMS) or reach out to LeadingAge NY's Meg Everett or LeadingAge National's Katy Barnett to provide feedback and comments specific to your agency. Your agency-specific data will be the most persuasive arguments to turn the tide of this rule.

The proposed rule, which will cut Medicare home health payments by an aggregate 4.2 percent, including a 7.69 percent negative adjustment to the base payment, coupled with an effort to recoup an additional $2 billion from home health providers, will have a devastating effect on older adults who rely on these services. Further, it runs counter to the Biden administration’s stated goals of promoting equity and the use of home and community-based care.

LeadingAge National has released a Tips for Commenting to CMS document to assist members in submitting comments to the Federal Register on the proposed rule. The document, available here, provides an overview of the rule and arguments against several of the proposed changes from the perspective of not-for-profit providers. It provides a structure for agencies to insert some of their data to make the case against the continuation of behavioral assumptions incorporated in the rates.

Members may want to comment on all-payer Outcome and Assessment Information Set (OASIS) data collection in 2025. CMS proposes to end the suspension of the collection of OASIS data on non-Medicare and non-Medicaid patients and require home health agencies to report all-payer OASIS data for the purpose of the Home Health Quality Reporting Program (HHQRP) beginning in CY 2025. Providers may wish to contribute feedback on the following topics:

1. Does your agency currently conduct OASIS on all patients regardless of payer?
2. What proportion of your episodes are for private insurance (non-Medicare, Medicaid, or related managed care)?
3. How significant a burden would adding OASIS for all patients regardless of payer be?

Regarding the Home Health Value-Based Purchasing Baseline Year Adjustment, LeadingAge National encourages providers to state their support for moving the demonstration initial start date to CY 2024, as it will provide a level playing field for all providers.

More information on the proposed rule, including LeadingAge National's draft comment letter, can be found here.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871