AHA Comment Letter to CMS on Home Health PPS Proposed Rule, CY 2023

August 16, 2022

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Submitted electronically

Re: Medicare Program; Calendar Year (CY) 2023 Home Health Prospective Payment System Rate Update; Home Health Quality Reporting Program Requirements; Home Health Value Based Purchasing Expanded Model Requirements; and Home Infusion Therapy Services Requirements

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 1,000 hospital-based home health (HH) agencies, and our clinician partners — more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the calendar year (CY) 2023 HH prospective payment system (PPS) proposed rule.

Our comments address multiple issues, including our concern about CMS’s proposed behavioral offset. The AHA strongly urges the agency to halt this proposed cut, which it states is necessary to ensure budget neutral implementation of the new HH PPS case-mix system. The offset was calculated using flawed assumptions and, at 7.69 percent, would be of an unprecedented magnitude. In addition, we are concerned about the inadequacy of the proposed market basket given the extraordinary inflationary environment in which we continue to operate. As such, we urge CMS to discuss further how it will account for these increased costs to ensure that beneficiaries continue to have access to quality HH care.

View the detailed letter below.