Support Clarifications to Medicare Home Health Payment Reform

Extensive payment reforms to the Medicare home health benefit were included in the Bipartisan Budget Act (BBA) of 2018 (P.L. 115-123) that was signed into law by President Trump on February 9, 2018.

These reforms included a budget neutral transition to a 30-day unit of service, authorization for the Secretary of HHS to make rate adjustments, and an ambitious implementation date for theses reforms which all need to be clarified.

Congress needs to pass additional legislation to clarify the 30-day unit of payment, prevent prospective payment rate adjustments, allow time for these reforms, establish an optional demonstration program, and ensure the home health agency’s records are considered when determining claim's status.

Contact your member of Congress to support clarifications to Medicare home health payment reform

Subject:

Support Clarifications to Medicare Home Health Payment Reform

Dear Official,

I am writing to ask for your support of clarifications to Medicare home health benefit and payment structure included in the Bipartisan Budget Act (BBA) of 2018 (P.L. 115-123).

The BBA contained significant reforms to the Medicare home health benefit, including: a shift to a 30-day unit of service from the current 60-day episode model and an authorization for the Secretary of Health and Human Services to make prospective and permanent adjustments to reimbursement rates based on assumptions and predictions of provider behavior. Additionally, the BBA attempted to address the long standing face-to-face/physician documentation certification requirement, but likely will not be implemented to the full effect intended.

The following clarifications are needed to improve the home health benefit and its payment reforms:

• Clarify that the 30-day unit of service would apply to reimbursement alone, and not affect the certification, patient assessment, or documentation time-frames.
• Ensure that payment modifications would be retrospective and based on observed evidence of change and estimates of impact  rather than prospective assumptions and predictions.
• Modify the start date for reforms to take place "no earlier than 2020."
• Establish an optional demonstration program to test any new payment model. 
• Direct CMS to consider the home health agency record in conjunction with the physician record when determining claim's status.

Thank you for your consideration of this important legislation.

Regards, Your Name

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