Call for Comments to CMS on Case Mix, Other Important Issues


The Home Care Alliance is asking all Medicare-certified agencies to submit comments on the Proposed Rule issued by CMS on July 16, 2010, which addresses a variety of subjects that raise numerous concerns for home health services. These matters include:

  • 2010 HH PPS payments rates with a 3.89% case mix creep adjustment
  • New standards for therapy coverage, patient assessment, and documentation
  • Requirements for physician face-to-face encounters for care plan certification
  • Modifications of the 36-month rule on ownership changes
  • Modification of claims coding and data collections
  • Consumer Assessment of Healthcare Providers and Systems (CAHPS) implementation

Case Mix Background:

CMS has implemented three case mix weight change adjustments to date—2.75% rate reductions in each of 2008, 2009, and 2010. It planned on an additional reduction of 2.71% in 2011. In its recent Proposed Rule, CMS proposes to increase the 2011 adjustment to 3.79% and to add a further 3.79% adjustment in 2012.

With these adjustments NAHC estimates that nearly 45% of home health agencies would receive Medicare payments that are below the cost of care. These rate cuts are in addition to the projected $39.7 billion in cuts coming from the 2010 federal health care reform legislation.


Please make sure you send your comments on these matters to three places:

1) CMS

  1. a. By Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1510-P, P.O. Box 1850, Baltimore, MD 21244-1850
  2. b. Or electronically by clicking here, then clicking “submit comment.”

2)      The Home Care Alliance of Massachusetts

3)      Your Congressperson

Also, please contact your congressperson and urge their support of the Home Health Planning Improvement Act and the Home Health Access Protection Act.

Aside from the obvious destination of sending comments to CMS, it is important for the Home Care Alliance to compile testimony for federal advocacy. Information is vital in making the argument against case mix adjustments, face-to-face encounters for care plan approval, and etcetera.

In addition, your agency sending comments to your Congressperson and asking that they in turn assist in this process is another very important step. HCA will follow up with your elected official once we have received your comments, but it is important for them to hear from businesses in their district that deliver care to their constituents.

Comments to CMS are due by September 14, and agencies are encouraged to have staff, patients and their families submit comments on these matters as well. The Home Care Alliance will have testimony available for agencies to view at least two weeks prior to the deadline.

Please contact James Fuccione at the Home Care Alliance if you have any questions.

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