When CMS finalizes the 2018 payment rule for home health agencies this month, we believe it is highly unlikely that the agency will finalize proposed cuts for 2019. Congress’s robust, public opposition to finalizing the Home Health Groupings Model (HHGM) proposal makes it far more likely—we place odds at 80 percent—that CMS will delay implementation of the HHGM beyond 2019.
Within the next few weeks, the Centers for Medicare & Medicaid Services (CMS) is expected to finalize the Home Health Prospective Payment System (HH PPS) rule for 2018. The proposed payment rule, published in July, includes a payment change for 2019 known as the Home Health Groupings Model (HHGM). The HHGM would change the unit of payment for home health agencies (HHAs) from 60-day episodes to 30- day periods of care, resulting in an estimated $950 million (-4.3 percent) reduction in Medicare payments for 2019.
The proposal has been met with intense criticism from the home health industry, which orchestrated a lobbying campaign to discourage CMS from finalizing the HHGM for 2019. Members of Congress have also communicated their disapproval of the proposal, including in the following letters to the Department of Health and Human Services (HHS):
- 174 bipartisan House Members writing on October 25, 2017
- 49 bipartisan Senators writing on September 26, 2017
- Senate Finance Committee Chairman Orrin Hatch (R-UT) writing on September 22, 2017
In our view, it would be highly unlikely for CMS to dismiss this level of bipartisan opposition to finalizing the HHGM for 2019. Therefore, we think it is far more likely—and place odds at 80 percent—that CMS will finalize a 2018 HH PPS rule that delays implementation of the HHGM beyond 2019 and seeks further input on its design.