The home health care industry is not pleased with the 2020 proposed payment rule — and industry leaders are making sure the Centers for Medicare & Medicaid Services (CMS) knows.

Led by LHC Group Inc. (Nasdaq: LHCG) CEO Keith Myers, the Partnership for Quality Home Healthcare (PQHH) has sent a letter to CMS Administrator Seema Verma that outlines the industry’s several concerns. Myers currently serves as chairman of Washington, D.C.-based PQHH, a national advocacy organization whose members include Bayada Home Health Care, Elara Caring, Encompass Health and other home health titans.

“Now is the time to carefully evaluate any requirement or action that can improve the Medicare program payment model to ensure patients can be cared for in their home as an alternative to institutional services,” Myers wrote to CMS.

In the letter, PQHH and Myers specifically called attention to five recommendations related to CMS’s recent proposals and plans for the Patient-Driven Groupings Model (PDGM), the biggest payment overhaul in roughly two decades.

For starters, the organization is calling for CMS to consider the impact of PDGM’s proposed 8.01% behavioral adjustment, calling it one of the most significant reductions taken in the Medicare payment system and warning of its far-reaching negative consequences.

“We urge caution and ask for a more data-driven approach to rate reductions that are based on behavior changes,” Myers wrote.

The CEO and PQHH also expressed concern that the new payment model incentivizes reduced therapy services; PDGM moves away from paying for therapy on a per-visit basis. Nearly half of home health providers expect to decrease therapy utilization come 2020, a recent National Association for Home Care & Hospice (NAHC) survey found.

In general, therapy is closely linked to home health patients’ health outcomes and functional ability.

In its letter, PQHH also targets coding-related policy changes that may reduce benefits for homebound Medicare beneficiaries, according to the organization.

The Notice of Admission (NOA) requirement floated by CMS in its July 11 proposed rule is likewise a concern for PQHH, as such a requirement wouldn’t allow for adequate preparation time and would increase providers’ paperwork burden.

CMS is proposing to phase out Requests for Anticipated Payments (RAPs) in 2020, adding NOA instead. If finalized, CMS’s plans would mean home health providers would have to submit an NOA within five days of receiving a new patient — or suffer financial penalties with any delays.

“We are concerned that the NOA will require too much information in too short of a period of time. We encourage CMS to eliminate this and requirements that will be cumbersome and unnecessary, or seek least burdensome approaches, especially at a time when [home health agencies] are transitioning to a new payment model,” Myers wrote.

Lastly, PQHH and the CEO urged CMS to make sure other health care stakeholders outside of the home health care industry are equally prepared for PDGM.

“Implementing this new system requires assurances that all relevant stakeholders and partners are prepared,” Myers wrote. “While PQHH members are planning our readiness, it is our hope that CMS will proactively assist physicians, Medicare contractors and auditors, and hospital discharge teams to understand how to comply with these new requirements.“

PQHH, of course, isn’t the only industry association to rally against PDGM’s assumption-based behavioral adjustments or CMS’s RAP proposal.

NAHC President William A. Dombi recently touched on both issues during an interview with Home Health Care News, noting that the RAP phase-out, in particular, comes with a very high level of risk for providers.

“Each of these home health agencies has employees they have to pay. Payroll isn’t going to change,” Dombi told HHCN. “Agencies can’t say to staff, ‘We’re going to skip the next four, five or six weeks in paying you.’ They can’t tell staff they’re only going to get paid 20%, which is what CMS is proposing for RAPs in 2020.”

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