AHA Aug. 31 expressed support for the Centers for Medicare & Medicaid Services’ efforts to develop an alternative to the current home health case-mix system, but urged the agency to continue to refine the proposed patient-driven groupings model to address provider concerns. “The PDGM approach of basing payment on five case-mix elements is clearly far more complex than the current HH PPS’s approach that uses patients’ therapy utilization as a key determination of payment,” AHA wrote, commenting on the proposed rule for the HH prospective payment system for calendar year 2019. “While we understand and support this effort to increase payment accuracy by basing payment on patients’ comprehensive clinical profiles, the transition to such a multifaceted model will be monumentally complex. At this time, the provider community is striving to understand how their mix of patients would fare under the new payment structure and struggling to plan for the extensive operational changes that will be needed to adapt to PDGM.”