NAHC Responds to Methodological Issues in MedPAC’s Home Health PPS Comments

The National Association for Home Care & Hospice (NAHC) recently addressed what it sees as methodological issues in MedPAC’s home health rebasing proposal stating that:

“The Medicare Payment Advisory Commission (MedPAC) recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Home Health Prospective Payment System (HHPPS) Proposed Rule for CY 2014.  In its comments, MedPAC appears to rely on data that are incomplete and outdated. 

Most alarming of all, however, is the assertion that “targeted payment policies” will be considered – but only after loss of access to care has occurred.

It will take several years for MedPAC to identify the expected care loss and for Congress to enact corrective action. Millions of homebound seniors and disabled individuals will suffer needlessly due to the flawed analyses that are the foundation of CMS’ unsustainable proposed rebasing adjustment.”

NAHC’s response focuses on several crucial areas including:

• MedPAC does not recognize the real and steep decline in Medicare home health margins.
• MedPAC errs in asserting that home health agencies (HHAs) can adjust to rate cuts by reducing patient visits.
• MedPAC relies on flawed, unrepresentative and unreliable audits conducted by CMS contractors.

Each of the points above is examined in greater detail in NAHC’s response. To view the full one-pager, please click here.

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