The Home Care Alliance of Massachusetts today submitted comments to CMS on the proposed rule for Medicare home health PPS. In our comments, we recommend that CMS rescind the across-the-board 5.06% case mix reduction and instead use its enforcement authority to identify and prosecute those few agencies that inflate their billings. The Alliance urges CMS to conduct a comprehensive review of the case mix system, with involvement of home health industry experts.
Regarding the proposed wage index changes and in light of the new rural floor wage index for hospitals in Massachusetts, we urge CMS to establish a policy to set the wage index for home health agencies to be equal to the wage index of the largest hospital within each CBSA if that hospital has been re-classified to another CBSA or qualifies for the rural floor wage index.
The Alliance also urges CMS to waive the Face-to-Face documentation requirement for patients discharged from an acute or post-acute care setting within 14 days of the home health admission, and recommends that CMS provide additional clarification to the “confined to the home” definition (and provides clarification and guidance to Medicaid programs to reduce wasteful TPL initiatives that hinge on the definition.
Alliance member agencies are urged to use the Alliance’s comments as a model to submit their own comments on the www.regulations.gov website.