AHA Comments on CMS’ Home Health Proposed CY22 Rule

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including 900 hospital-based home health agencies, the American Hospital Association appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ calendar year 2022 proposed rule for the HH prospective payment system. Specifically, our letter focuses on the field’s behavioral response to the CY 2020 implementation of the new HH PPS case-mix system, the Patient Driven Grouping Model (PDGM), as well as the proposed quality reporting provisions. 

We continue to support the PDGM objective of increasing HH PPS payment accuracy. However, we remain concerned that the sizeable behavioral adjustment prospectively implemented in the payment system’s first year did not advance this goal. In fact, the field’s evaluation identified several specific elements of the adjustment that were erroneously projected, highlighting the historic difficulty CMS has had in aligning prospective adjustments with actual provider behavior.

These analyses show that several key CMS behavioral assumptions were inaccurate, as discussed below. In fact, the COVID-19 public health emergency (PHE), which of course could not have been anticipated, underscores the risks inherent in making prospective behavioral offsets. As such, with regard to any adjustments to the CY 2020 4.36% behavioral offset, we agree with and appreciate CMS’ decision to defer action in CY 2022 and ask the agency to hold until the conclusion of the PHE. Until then, closer analyses of the gap between projected and actual provider behavior is warranted. In addition, we are interested in better understanding the actual behavioral adjustments made by hospital-based HH agencies, given their unique role, including critical contributions toward pandemic response.   

See the letter below for our complete comments.