NAHC Submits Additional Comments on Rebasing to MedPAC
April 9, 2014 02:52 PM
The National Association of Home Care and Hospice (NAHC) is submitting additional comments to MedPAC on the issue of rebasing. NAHC’s new comments stem from a recent MedPAC meeting, where it was made clear that MedPAC still does not see rebasing as adversely affecting quality or access to home health care.
NAHC is providing comments regarding the presentation at the April 3, 2014 MedPAC public meeting on the “Mandated Report: Impact of Home Health Payment Rebasing on Beneficiary Access to and Quality of Care.”
During the public meeting, MedPAC staff offered flawed statistics that home health agencies will experience a net rate cut of just 1.6 percent by 2017 – or 3.6 percent if sequestration is considered. That cut level is calculated by offsetting the rebasing cuts with annual Market Basket Index inflation updates. As such, it is based on the unfounded assumptions that home health agencies will face no cost increases in the next four years or that Medicare revenue increases can offset higher costs.
For more on the recent MedPAC meeting, please see NAHC Report, April 4, 2014.
In its comments, NAHC respectfully cautions MedPAC to rely on the impact forecast presented at the meeting. That forecast is based on key unfounded assumptions that are at direct odds with the current data on costs, revenues, Medicare margins, and industry changes. NAHC hopes that MedPAC will examine the facts and data in greater detail before preparing its report to Congress.
NAHC is open at anytime to meet with MedPAC commissioners and staff to initiate a robust and deep analysis of the recent data trends and emerging changes in Medicare home health services that would inform an evaluation of the impact of the ongoing rate rebasing. Such an analysis is crucial as it will be difficult to reverse the rebasing course when access-to-care concerns accelerate during the four-year phase-in of rebased rates.
Below is a summary of NAHC’s main objections to MedPAC’s rebasing analysis:
Why is the MedPAC analysis of the impact of rate rebasing inaccurate?
It is based on unreliable forecasting assumptions that are in serious conflict with current data
The CMS rebasing methodology establishes a “less-than-cost” aggregate payment model
MedPAC’s “Medicare Margins” do not include all necessary and appropriate costs of care
The use of averages is a high risk method of analysis given the wide range in costs for care that is provided in widely differing locales and significantly varying home environments
Overall financial margins for home health agencies indicate near-bankruptcy status for the industry at large
The “efficient” home health agency is not simply the one with the lowest cost.
To read NAHC’s full comments to MedPAC, please click here.