The comment period for the proposed home health payment rule from the Centers for Medicare & Medicaid Services’ (CMS) ended Monday.

Among other changes, the rule introduced in July proposes the implementation of a new home infusion benefit and the elimination of Request for Anticipated Payments (RAPs). On top of that, it doubles down on the Patient-Driven Groupings Model’s (PDGM) behavioral adjustment, which could mean a 8.01% reimbursement cut for home health agencies.

While many commenters took aim at the widely opposed behavioral adjustment, a bevy of providers lauded CMS for the proposal of a new notice of admission (NOA) requirement.

Specifically, CMS has suggested requiring home health agencies to electronically submit a notice of admission within five days of taking on a new patient. The new requirement would start in 2021.

About one-third of all commenters said they support CMS’s move to add the NOA requirement. Many of those supporters were providers of therapy frustrated by frequent Medicare claims denials from CMS.

“I support the five day NOA requirement for home healthcare, thank you for proposing and considering it,” Patti Moulds of Gaspar Physical Therapy wrote. “For far too long we’ve had to pay back Medicare for services rendered by our hard-working private practice physical therapists!”

Fellow commenter Tracy LaPan, director of AR and credentialing at Bay State Physical Therapy, expressed a similar sentiment.

“This would drastically reduce the number of claims denials based on active home health episodes,” she wrote.

Meanwhile, Drew Giardina, the owner of an outpatient physical therapy clinic, also showed his support, expressing his opinion that the rule would have positive benefits beyond the home health world.

“I fully support the 5 day NOA proposal,” Giardina wrote. “I believe it is unfair for outpatient clinics to have to pay back money due to the [home health agencies] not filing paperwork efficiently, especially when the avenues are checked thoroughly to avoid this same issue and the information is wrong.”

However, industry leaders like National Association for Home Care & Hospice (NAHC) President William A. Dombi have publicly criticized the proposed NOA requirement — namely the penalties that could come with it.

“If you don’t do it on a timely basis, there is a penalty where you essentially lose one-thirtieth of your payment for every day that it’s late,” Dombi said.

Per the proposal, agencies that fail to submit a notice of admission within five days would receive a wage-adjusted 30-day period payment amount that is reduced by one-thirtieth for each late day.

Behavioral adjustments pushback continues

Another large portion of the comments came from home health providers who were critical of the newly proposed rule, especially PDGM’s behavioral adjustment.

With the behavioral adjustment, CMS is assuming it knows how agencies will behave when the new payment model takes effect. For example, the adjustment assumes agencies will automatically choose the reimbursement codes associated with the highest payout, or “up-code” — though there are hundreds of coding possibilities under the new model.

“CMS has not used behavioral adjustments in any other health care setting, including SNFs under PDPM, as a prospective tool for controlling cost,” a commenter from Franklin County Home Health Agency in Vermont wrote. “CMS is singling out home health and could affect access to patient care in the future.”

Others worried the behavioral assumption cut could put them out of business come 2020.

“I currently own a Medicare-certified agency and am terrified to start next year,” Elaine MacCollom wrote. “The cost of providing these services keep rising, and the expected decline in payments is to be at least 8%. I do not understand how this is fair in any way. There needs to be more research done before this is implemented.”

Cynthia Coutinho put it in even simpler terms.

“This legislation will create insurmountable difficulties for my home health agency,” she wrote.

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