Home Health PPS

At Issue

November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) issued a final rule to update the home health (HH) prospective payment system (PPS) for calendar year (CY) 2022.

AHA Take

We appreciate CMS’ issuance of a streamlined rule, which allows HH agencies, as well as their hospital and other local partners, to focus on their response to the COVID-19 pandemic. While virus surges continue in many communities, in others, HH agencies are now caring for the clinical needs of “long-haul COVID-19” and other patients while preparing for a possible resurgence of the virus during the fall and winter seasons.

In addition, AHA supports CMS’ caution in determining how best to ensure that the new HH PPS case-mix system was implemented in a budget-neutral manner in CY 2020, especially given the complexities wrought by the pandemic. That said, we remain concerned about the prospective nature of the CY 2020 behavioral adjustment, especially given that analyses conducted thus far indicate a substantial gap between CMS’ and independent findings. Specifically, CMS found that Medicare overpaid for HH services in CY 2020, while analyses by HH stakeholders found an underpayment for that year. Moving forward, we urge CMS to partner with stakeholders to transparently evaluate projected annual payments versus actual payments that year. In addition, we appreciate that CMS will delay the expansion of the HH Value-based Purchasing model for one year as we suggested, but continue to be concerned by other details in the model’s design.

Watch for a detailed Regulatory Advisory in the coming weeks. In addition, AHA’s HH members will receive a separate invitation to a member call to discuss the rule and its impact.

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