NAHC Letter to CMS – Withdraw the Home Health Group Model

The National Association for Home Care & Hospice (NAHC) and the Partnership for Quality Home Healthcare have written a letter to CMS Administrator Seema Verma, encouraging her to withdraw the proposed CY 2019 Home Health Groupings Model (HHGM) because the rule is likely to cause considerable disruption and possible loss of care for many home health patients.

The home health industry requires additional information in order to fully assess the impact of the proposed rule, with more complete data analysis, and scrutiny as to the legal and policy authority to make the rule, write authors William Dombi, President of NAHC, and Keith Myers, Chairman of the Partnership for Quality Home Healthcare.

CMS needs to convene a broader workgroup of stakeholders and, in consultation with these stakeholders, evaluate criteria that ensure that all the Medicare benefit is available to those who are eligible, and devote attention to educating all parties who order and provide the valued Medicare home health benefit. The sheer number of changes to the HH PPS incorporated in the proposed version of HHGM make current analyses of its impact difficult to adequately perform and would cause any unintended consequences of its potential implementation near impossible to isolate and address. We welcome the opportunity to engage with CMS on ways to craft rules that are “less complex” and “reduce burdens”, as stated in the Request for Information (“RFI”) contained in the proposed rule.