The AHA Friday urged the Centers for Medicare & Medicaid Services to withdraw a proposed 3.41% coding cut in its proposed rule for the home health prospective payment system in calendar year 2016. The rule bases the proposed cut on an analysis of nominal case-mix change in CYs 2000 through 2009, and extrapolates those findings to coding behavior in CYs 2012 and 2014. “We urge CMS to conduct the necessary analyses of CY 2012 through 2014 nominal case-mix change and share such analyses with stakeholders in the form of a new, evidence-based proposal,” wrote AHA Executive Vice President Tom Nickels, noting that the Medicare margin for hospital-based agencies was negative 15.5% in CY 2013. “…Given that HH services are expected to continue to play a prominent role in alternative models of care and payment, we encourage CMS to avoid reducing margins for HH agencies to levels that threaten participation in these important initiatives.” Among other comments, AHA urged CMS to consider adopting a maximum payment adjustment of no more than 2.0% for its proposed HH value-based purchasing program, and to reduce the number of measures in the program to focus on high-priority issues for improvement.

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