The US Centers for Medicare and Medicaid Services, better recognized by the acronym CMS, is receiving heavy criticism from APTA and other agencies. The government agency, is seeking approval of probable flawed plans for its home health payment system. The changes have been interpreted as severely damaging current patient care.
Three specific concerns distinguish the most damaging wording of the proposal.
- Changes in home health (HH) payment environment. The potential result adversely affects physical therapists, their patients, and physical therapist assistants.
- Adoption of Home Health Grouping Model (HHGM), a new case-mix model. It removes physical therapy service-use thresholds from the mix
- Proposal reduces episodes of care to 30 days (currently 60).
CMS is requesting a 2019 startup date for the new proposal, which has a projected payment reduction for home health of $950 million.
Described as a system that undervalues the importance of rehabilitation, HHGM is also accused of making harsh financial incentives that result in an undesirable level of care. Developing increased effectiveness and smarter healthcare are important goals. The current proposal appears to be lacking that goal. APTA, individuals, and additional interested parties have sent a multitude of letters addressing concerns, particularly a determined focus on reducing Medicare spending.
CMS states the best interests of the people it serves are put first, yet the proposed plan and HHGM fail to uphold that claim. Social, behavioral, and environmental factors are missing from the framework along with compassion and concern for the people who require services.
Congress appears to be headed towards involvement in the proposed change, as it appears to exceed the legal authority of CMS. A criticism by APTA argues that CMS can only put into effect changes of a budget neutral fashion. In this case, the HH budget is going to be impacted significantly, which requires Congress to impose the changes. There’s also concern about the new model’s authorization before proper arguments, education, and studies are completed.
The proposed modifications regarding the Value-Based Purchasing Program and HH Quality Reporting Program are supported by the association. It’s the potential adversity of HHGM that causes the greatest concerns. The American Physical Therapy Association emphasized unfavorable issues in its letter to CMS, such as causing:
- new access issues for beneficiaries.
- new issues with program integrity.
- Provider compliance challenges.
Individuals and other interested parties are encouraged to contact CMS with questions, suggestions, and concerns regarding the proposed changes and their impact on the necessity of physical therapy in overall treatment.