Thanks to You, CMS Did Not Finalize the Home Health Groupings Model!

When the Centers for Medicare & Medicaid Services (CMS) finalized the Home Health Prospective Payment System (HHPPS) Rule for CY 2018, the home health community was pleased to see that the Home Health Groupings Model was not included in the final rule.

This was a huge relief for the three and a half million seniors who rely on home health services every year, whose care would have been at risk under this new rule.

Here at the Partnership, we are thankful that leaders at CMS and in the Administration listened to the concerns of theircolleagues in Congress and stakeholders throughout the home health community. And we are also thankful to you, our home health advocates!

Since the HHGM rule was proposed, you made sure that your voices were heard. Collectively, you sent more than 40,000 emails to Members of Congress.  With your help, we also secured publication of nearly 30 letters-to-the-editor across the country.

As a result of your efforts, more than 230 bipartisan lawmakers joined with us in urging CMS to not finalize HHGM and instead work with home health stakeholders on policy solutions that preserve access to quality cares services in the home.

We want to thank you for your hard work to protect seniors’ access to care, and encourage you to share a message of thanks with the lawmakers who stood with us on this issue. You can take action by clicking the button below:

Patient Groups, Providers and Lawmakers Agree: CMS Should Withdraw the Home Health Groupings Model

Our concerns about the Home Health Groupings Model (HHGM) proposed by the Centers for Medicare & Medicaid Services (CMS) are being echoed by patient advocates, provider groups and bipartisan lawmakers!

Groups ranging from the American Hospital Association to a group of 49 bipartisan members of the Senate have called the proposal “drastic” or “radical” and have pointed out that HHGM will “create major incentives to underserve Medicare beneficiaries.” Below are some examples of what these  groups are saying about HHGM:

“HHGM methodology only reflects the needs of some Medicare beneficiaries, while Medicare law applies to every Medicare beneficiary.”


“A change of this magnitude is also likely to put patient access at risk for Medicare beneficiaries in rural and smaller communities with few HHAs and America’s Veterans who largely depend on home health.” 


“We have heard from a number of stakeholders who are concerned that the proposed rule lacks sufficient information and data points to allow home health agencies to accurately estimate the impact of the proposed HHGM.”


Now, it is your turn to share concerns about HHGM with your local papers and Members of Congress!

It’s essential that every Member of Congress hear from the home health community on this important issue.

CMS Should Collaborate with the Home Health Community to Improve the HHGM

Recently, the Centers for Medicare & Medicare Services (CMS) released their CY 2018 proposal for the Health Prospective Payment System (HHPS) and the Home Health Groupings Model (HHGM) within it. This proposal would drastically alter the home health payment system, putting the 3.5 million Medicare beneficiaries that depend on the home health benefit at risk.

The HHGM would overhaul the current Medicare payment system in a non-budget neutral manner. Payments would now be based on patient characteristics instead of care needs, and distributed based on location of providers rather than their quality of service. This causes uneven payment distribution, as high-quality providers in certain areas could face disproportionate cuts. Furthermore, the geographic disparity would have the greatest effect on seniors living in rural, smaller areas, potentially putting their access to care at risk.

The HHGM could be implemented as early as 2019. If implemented as is, it could harm home health patients’ access to quality care and cause disproportionate home health provider payments.

We believe that CMS must work with the home health community in order to properly address and solve the issues within the HHGM. We welcome engagement with CMS, but need more data and information to be able to offer in-depth policy recommendations.

Click here to see our five reasons why CMS and the Home Health Community should work together to improve the HHGM.

Ask Congress to Extend the Home Health Rural Safeguard Today!

As a person gets older, certain things once taken for granted become increasingly difficult. Health becomes harder to manage and appointments with doctors and healthcare providers become harder to reach, especially for seniors residing in rural areas.

The Moran Company estimates the average rural patient’s travel distance to her doctor or nearest hospital is about double that of her city counterparts. Many older Americans are unable to travel such long distances, leaving them with no option but to depend on home healthcare services to ensure their wellbeing.

With that distance comes expense, and elderly patients using home health are left with significantly higher medical costs. In 2000, Congress began to combat this price differential through Medicare’s implementation of a rural safeguard. The safeguard protects older patients with poor health in rural areas who depend on home healthcare services by covering the higher costs of travel and staffing.

This safeguard has protected older Americans for 17 years, but is now set to expire on Dec. 31, 2017. On the eve of the safeguard’s expiration, we must remember how important it is to not let rural locations hinder any American’s chance at maintaining good health.

This issue is crucial to our nation’s rural seniors, and it’s critical that we communicate its value to lawmakers in Congress to ensure it is extended.

Urging your lawmaker to support the rural safeguard extension is simple. Write a letter to your lawmaker or ask for their support in your local newspaper by visiting our Action Center:

Father’s Day: A Reminder of the Importance of Spending Time at Home with Family

With Father’s Day approaching, the important role family plays in an individual’s daily life, particularly as a person ages, becomes impossible to overlook. As American families grow and seniors transition from the role of parent to grandparent (or even great grandparent!), the ability to celebrate comfortably with family becomes more and more central. On holidays like this one, spending time at home with loved ones is often a priority in maintaining a happy quality of life.

Whether it be watching a young grandchild run in the yard or enjoying a meal with a beloved son or daughter, seniors want to be able to spend time with the families they have spent their lives building. And with the help of the Medicare skilled home health services, this becomes possible for millions of older Americans as they age.

America’s fathers and grandfathers should have the choice to age at home, so they can spend holidays in the homes where familial memories were created, not in unfamiliar environments such as hospitals or nursing facilities. The Partnership will continue to work to ensure access to quality home healthcare for seniors so they can spend special days like this in the comfort of their own homes!

Older Americans Month Highlights the Importance of Home Healthcare

May is Older Americans Month, a time to celebrate the contributions older Americans make in their communities. The theme this year is “Age Out Loud.” It’s a time to empower America’s seniors to speak up about what it means to get older.

More than ever before, older Americans are working longer, pursuing new opportunities, and living more independent lives. For many, being able to remain at home when recovering from illness or injury is crucial to maintaining that independence. As we encourage seniors to speak out this month, we must remember what they have already told us. Data show 89% of seniors want to age in place! And thanks to Medicare home healthcare, more than 3.5 million older Americans are now able to do just that.

Yet, there is still much work to do to ensure that Medicare home health remains a viable option for America’s seniors. This year, the Partnership will continue to work with Congress and the Administration towards realizing our 2017 priorities. We will press CMS and Congress to improve the Pre-Claim Review Demonstration before it is applied to home healthcare delivery, so patients who need home healthcare aren’t improperly denied or delayed care. We will work to streamline existing face-to-face documentation rules so physicians and home health providers aren’t burdened with unnecessary paperwork, and we will fight to extend the Medicare rural safeguard payment so patients in remote communities don’t lose access to vital services.

Older Americans Month is a perfect time to reflect on how the culture of aging is changing, and how more seniors are living healthier, happier more dignified lives. This month, let’s remember how vital home healthcare is to maintaining that dignity, and have a conversation about how to strengthen it for everyone.

New Study Shows Why We Need to Expand the Home Health Rural Safeguard

A new study by the Moran Company uncovered the many challenges home health beneficiaries in rural areas face in accessing care.

The study found significant disparities between rural and urban home health beneficiaries:

  • In 2014, seniors living in rural areas were 15% less likely to receive home health services.
  • Medicare home health beneficiaries in rural areas are older, have a lower income, and live with more chronic conditions than the general Medicare population.
  • Medicare home health beneficiaries in rural areas are 17% more likely to be below 200 percent of the federal poverty line.
  • Rural Medicare patients live twice as far from their doctor compared to beneficiaries in urban areas.

Another factor compounding these disparities is the high cost of providing home health services to patients living in rural communities. According to a study by Ability, the cost of providing Medicare home health services is 36% higher per parent episode in rural areas than in urban areas – mainly due to the long distances providers must travel to reach patients in their homes. This presents a challenge for providers, who ultimately bare the higher cost of delivery.

Historically, the Congress has rightly understood these challenges and since 2000 has provided safeguard “add-on” payment to the reimbursement rate for Medicare home health services delivered in rural areas. This “rural safeguard” covers those extra costs so beneficiaries in rural areas have their home health needs met.

Unfortunately, the safeguard is set to expire at the end of this year, which is why home health providers are urging Congress to renew the program before time runs out. In the coming months, the Partnership will work diligently with lawmakers, patients, and stakeholders to ensure that home healthcare remains accessible to older Americans living in rural areas.

To learn more about Medicare’s rural home health population, click here.

Good News: CMS is Re-thinking the Home Health Pre-Claim Review Demonstration

On March 31, the home health community received some good news from the Centers for Medicare & Medicaid Services (CMS)!

CMS announced that it would stop the planned implementation of a Pre-Claim Review Demonstration (PCRD) in Florida, which would have applied new, mandatory regulatory requirements on all home health agencies operating across the state on April 1 and pause the PCRD program currently underway in Illinois for at least 30 days, which has made the delivery of timely home healthcare difficult since implemented in August 2016.

Here at the Partnership, we are incredibly grateful CMS responded to the concerns expressed by bipartisan lawmakers, home health providers, and advocates both in these states and across the country. We also want to applaud the thousands of advocates who collectively reached out to CMS and their lawmakers in recent months – your efforts truly made a difference!

We hope this decision will allow the home health community to work with CMS to strengthen the Medicare home health program by developing policy alternatives and through proper education and training. We welcome the opportunity to work with CMS to develop alternative, targeted reforms to reducing fraud and abuse without disrupting the care for our vulnerable Medicare patients.

Florida Lawmakers Urge Secretary Price, CMS to Reject Pre-Claim Review

This week, a bipartisan group of Florida lawmakers sent a letter to Health and Human Services Secretary Tom Price, MD urging him to reject the Medicare Home Health Pre-Claim Review Demonstration and replace it with a more effective program to tackle Medicaid fraud.

The letter, which was signed by twenty-seven members of Florida’s Congressional delegation, including Senators Bill Nelson (D) and Marco Rubio (R), called on CMS to put the breaks on PCRD ahead of its scheduled implementation date on April 1st. The program was first rolled out in Illinois last August and resulted in numerous technical issues and improper care denials across the state. Because of these issues, CMS initially delayed PCRD from taking effect in Florida and several other states for many months in order for it to be improved. However, it is clear that no serious effort was made to fix the underlying problems with PCRD during that time.

“We support efforts to combat Medicare fraud and protect taxpayer funds, but we are concerned that the PCRD’s current parameters are too broad to reduce fraud and improper payment rates,” the letter reads. “We encourage you to consider an alternative approach that would achieve these goals and ease the administrative burden and additional implementation costs for smaller home health agencies, and ensure timely patient access to services.”

The letter also raises the concern that Pre-Claim Review imposes onerous restricts on small home health providers, and was implemented without going through the formal rulemaking process.

You can read the full letter here.

PQHH’s 2017 Policy Priorities

As we move into 2017 and welcome a new Administration and Congress, the Partnership has outlined policy priorities for 2017. While it is hopeful that the new Administration will provide regulatory relief from multiple, duplicative programs detailed below, the Partnership will continue to press on with Congress to make critical changes.

Pre-Claim Review
Last year, the Centers for Medicare & Medicaid Services (CMS) introduced the Pre-Claim Review for home health demonstration project. Under the demonstration, home health agencies would need to receive approval from a CMS contractor before being reimbursed for providing home health services – even if those services were prescribed by a patient’s physician. While the original purpose of this demonstration was to address fraud, a combination of technical failures and contractor mismanagement has led to significant and unnecessary delays in home care delivery while doing little to tackle fraudulent claims.

Thankfully, CMS suspended pre-claim review in several states where it was slated to begin this year. However, the demonstration remains active in Illinois, the first state in which the program was implemented, and is scheduled to take effect in Florida early this year. In 2017, the Partnership will be renewing its efforts to pass the Pre-Claim Undermines Seniors’ Health (PUSH) Act, bipartisan legislation to delay pre-claim review for one year so CMS can determine how to strengthen the program and prevent care disruptions.

The Partnership also welcomes the opportunity to work with CMS simultaneously to address our concerns with pre-claim review and delay implementation of the program in other states.

Face to Face Requirement
Under current Medicare rules, patients who need home healthcare must have a documented face-to-face encounter with a physician to certify their eligibility for services. This is to ensure that patients are receiving care in the appropriate setting and providers are not billing Medicare for unnecessary services. However, overly complicated and burdensome requirements have resulted in unintended consequences like care delays and improper denials of services.

Data show tens of thousands of claims have been denied for care that is medically necessary and appropriate. While many of these claims are overturned on appeal, the initial denials make it difficult for home healthcare agencies to provide continued, uninterrupted care.

This year, we will work with our partners in Congress to develop legislation to streamline the existing face-to-face documentation rules to reduce the paperwork burden on physicians and home health agencies so that there are fewer improper care denials.

Rural Safeguard
According to recent data, the cost of providing Medicare home health services is 36% higher per parent episode in rural areas than it is elsewhere. This is primarily due to increased transportation and staffing costs, which make it difficult for home health agencies to balance their operating costs with reduced Medicare reimbursement rates. Medicare home health patients in rural areas are also older, on average, than the general Medicare population and are more likely to be dually eligible for Medicare. Therefore, ensuring continued access to home health services is critically important for rural beneficiaries.

Since the year 2000, Medicare had recognized this disparity and has provided a rural safeguard to ensure older Americans living in rural areas have access to home healthcare. Currently, the safeguard is set at a 3% add-on to the baseline reimbursement rate. However, this provision is set to expire at the end of 2017 if Congress doesn’t act to extend the safeguard.

We will make extending this valuable rural safeguard a top priority in 2017 so that America’s rural communities can rest assured that they will always have access to skilled care at home.