PQHH Recommends Rescinding Behavioral Assumption Cuts in 2022 Final Payment Rule
Summary
Given the cost pressures and the importance of maintaining a viable home health benefit for Medicare beneficiaries, now is not the time to implement further payment reductions. The Partnership urges CMS to rescind the -4.36 percent behavioral adjustment for CY 2022, accept our recommendations for a more accurate assessment of budget neutrality in the PPS for future years,” the Partnership letter states.“Our comments and the expert third-party analysis offer very technical feedback to CMS’ proposed payment adjustments and methodologies, which we hope will help inform payments that are accurate, predictable, and support access to high quality home healthcare,” said Joanne Cunningham, executive director of the Partnership. “We are concerned that the continued implementation of the -4.36 percent behavioral adjustment cut in 2022 is unjustified and that CMS’ assessment of budget neutrality will lead to additional unsubstantiated cuts in future rulemaking.”The new findings come shortly after another DDA analysis found that two of the three anticipated behavioral changes that CMS used to justify prospective payment rate reductions have largely not occurred. The data reflect the fact that home health providers did not change their billing behavior to the highest paying diagnosis as CMS assumed they would under PDGM.In addition to these concerns, the Partnership comments caution that the annual payment rate update does not reflect rising costs of providing care including labor costs and urge CMS to review and incorporate these important considerations before finalizing the rule.“Now more than ever, older Americans need the option of home healthcare,” continued Cunningham. “CMS’ annual payment update has not kept pace with labor costs and other expenses of home health delivery, which, if not addressed, will continue to impact the stability of our sector.