Advocacy Alert: Urge your US Rep to Support HHPPS Proposed Rule Letter

With another $350 million cut to Medicare home health payment and Massachusetts selected as one of nine states for a “Value-Based Purchasing” Pilot, it is important that a strong message is sent to CMS and that means getting strong support from our state’s Congressional Delegation.

A new message is posted on the Home Care Alliance’s Advocacy Center that you can easily send to your federal elected representative to gain support for a Congressional sign-on letter to CMS. Just fill out the contact information, hit “send” at the bottom of the page, and the message will automatically go to your member of Congress.

The letter, which can be seen below, voices concern about the burdensome payment reductions and severe Value-Based Purchasing penalty in CMS’ proposed rule. Home health care champion Congressman Jim McGovern is co-leading the effort – known as a “dear colleague” letter in Congress – and the Alliance continues to appreciate his ongoing support of our issues.

Here is the text of the letter:

The Honorable Andy Slavitt
Acting Administrator
Centers for Medicare and Medicaid Services
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Dear Acting Administrator Slavitt:

We are writing today to express our concern with Medicare home health funding cuts set forth in the Home Health Prospective Payment System (HHPPS) proposed rule for 2016. Home healthcare is a vital service that allows millions of the most vulnerable senior citizens and disabled individuals to receive the treatment they need in the cost-effective environment they most prefer – their home. As a result, we request a careful reconsideration of two of the draft policy changes in light of their anticipated impact on homebound Medicare beneficiaries and the home health delivery system upon which they depend.

First, we are concerned with the draft HHPPS rule’s proposal to cut home health payment rates by an additional 1.72 percent in 2016 and again in 2017. This proposed “case mix” reduction is of concern because it appears to be based on a 2000-2010 case mix weight change analysis rather than changes in the condition of beneficiaries during the 2012 to 2014 period that Medicare proposes to address.

Second, the draft rule proposes a Home Health Value-Based Purchasing (HHVBP) program that would impose an incentive/penalty range of as much as 5 to 8 percent over a 5-year period. We are very concerned with the aggressive nature in which the Secretary intends to ramp up HHVBP. Implementing a VBP program with a 5 percent withhold that increases to 8 percent just three years later is too much too fast. We are also concerned that the Secretary is proposing 25 measures for use in the HHVBP— far too many for providers to focus on.

In closing, we wish to express our concern that, in its current form, the draft rule may drive Medicare reimbursement to unsustainable levels for thousands of small, rural and other home health providers across the country, impacting the care upon which many of the most vulnerable Medicare beneficiaries, as well as their communities, depend. As a result, we request that the Agency reconsider its proposed case mix cut until it evaluates the specific causes of case mix weight changes from 2012 to 2014 and consider a more reasonable implementation schedule for the proposed withhold amount in the HHVBP program.

We thank you for your attention to this critical matter.

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