CMS announced today cuts to the home health payment system for 2012 as follows (link):
A proposed rule was displayed at the Federal Register today proposing a 3.35 percent decrease in Medicare payments to home health agencies (HHAs) for calendar year (CY) 2012. This would be an estimated net decrease of $640 million compared to HHA payments in CY 2011. It would include the combined effects of market basket and wage index updates (a $310 million increase) and reductions to the home health prospective payment system (HH PPS) rates to account for increases in aggregate case-mix that are largely related to billing practices and not related to changes in the health status of patients (a $950 million decrease).
Provisions of the Affordable Care Act (ACA) mandate that CMS apply a one (1) percentage point reduction to the CY 2012 home health market basket amount; this would equate to a proposed 1.5 percent update for HHAs next year. As part of the HH PPS rate update, CMS also proposes to reduce HH PPS rates by 5.06 percent in CY 2012 to account for the increase in the case-mix that is unrelated to changes in patient acuity.
The Medicare HHA proposed rule would also make structural changes to the HH PPS by removing two hypertension codes from the case-mix system, lowering payments for high therapy episodes and recalibrating the HH PPS case-mix weights to ensure that these changes result in the same amount of total aggregate payments.
Notice they left the therapy and the hypertension changes for last. If I were younger and less cynical, I would guess that many agencies will just find different codes for hypertension to use. Nurses: please recognize sarcasm when you read it. Coding is NOT an exercise in creative writing.
The proposed changes also reference Medicaid. The Olmstead decision is referenced which says that Medicaid cannot require patients to be confined to the home in order to receive services under the Medicaid benefit. Many states have already changed this rule but a few, including Louisiana, have not. Since Olmstead, I have known of no state that enforced it so this is largely a formality.
The relationship between the Federal Medicare Programs and state Medicaid programs is the center of much attention these days. On Medicaid, the federal notice states:
For clarification and consistency among programs, our expectation regarding the person-centered philosophy is that the plan of care reflects what is important to the recipient and for the recipient. (Emphasis mine.) This is hardly a novel idea to nurses but it will be interesting to see how it is spelled out in federal guidelines.
The announcement posted today does ask for comments. I am planning on reading more thoroughly and submitting my own comments. This is our only chance to be heard by the folks making the rules. And when final rules are published, you will note that many comments are taken into consideration. So, do us all a favor and give the proposed changes some thought and send in your comments.
Occasionally when I post a link to a pdf document, some readers are unable to access it. If that is the case for you, please email me and I will send a copy.