Alliance Comments to CMS on CY2022 Home Health Rule

To ensure that home health agencies in Massachusetts can provide high-quality care to older adults, the Home Care Alliance of Massachusetts has submitted comments to the federal government regarding the proposed rule for next year’s Medicare home health rates. Our comments to the Centers for Medicare and Medicaid Services (CMS) address several sections of the proposed rule, including:

  • CMS’s flawed reasoning behind the -4.36% “behavioral adjustment” to the rates;
  • Concerns about a budget neutrality adjustment based on 2020 data skewed by COVID;
  • A market basket adjustment that does not account for ongoing costs related to COVID;
  • Protections for counties with large wage index reductions;
  • Modifications to the Value Based Purchasing model before it is implemented nationwide;
  • Greater flexibility around the five-day deadline to submit the new Notice of Admission;
  • Greater flexibility to allow therapist to conduct initial assessments; and
  • Expanded allowances for virtual aide supervisions.