For the reason that launch of the US Facilities for Medicare & Medicaid Providers’ (CMS) proposed cost rule, house well being stakeholders have been sitting of their respective “battle rooms” attempting to navigate the proposal.
As suppliers equipped for the revealing of the proposal, many knew that CMS’ evaluation of whether or not the Affected person-Pushed Groupings Mannequin (PDGM) led to larger, decrease or equal spending in comparison with the previous cost mannequin could be a significant component, in keeping with William A. Dombi, the president of the Nationwide Affiliation for House Care & Hospice (NAHC).
Many are pushing again towards CMS’ methodology for assessing price range neutrality, with organizations reminiscent of NAHC expressing their considerations even previous to the discharge of the proposed rule.
“Once we discovered on Friday that CMS selected to make use of the identical methodology, which had been roundly condemned by anyone who had evaluated it, we needed to conclude the CMS had successfully declared battle towards house well being,” Dombi mentioned. “I do not imply that in an emotional sense, however in a sensible sense, the place the end result of this proposal may very well be terribly — not simply disruptive — however devastating to the house well being care group.”
He made these feedback throughout NAHC’s newest webinar on Thursday.
Total, the proposed rule comes with a lower to cost charges by 4.2%, or $810 million much less in comparison with 2022 charges.
“CMS solely will get to that [$810 million] by including within the inflation replace, so the inflation replace for 2023 is a meager 2.9%,” Dombi mentioned.
The proposed rule additionally features a 7.69% PDGM budget-neutrality adjustment.
“It is beginning to see on this interval of excessive inflation, this super change within the stage of the bottom cost charges,” Dombi mentioned.
Together with the adjustments within the cost fee, CMS principally maintained the identical PDGM case-mix mannequin however, like final yr, the company recalibrated all 432 case-mix weights. CMS additionally recalibrated the LUPA thresholds for the primary time since 2020.
Dombi famous that CMS realized the significance of protecting “some stage of stability” for suppliers of providers as a result of adjustments made to final yr’s wage index.
“Like they’ve finished of their proposal for expert nursing services, hospitals, hospices, and all different supplier sectors the place there’s a wage index relevant, CMS proposes to institute a everlasting 5% cap on any damaging wage index adjustments that might mirror adjustments in workforce prices,” he mentioned.
Moreover, CMS modified the outlier fixed-dollar loss to 0.44, which might then change the variety of outlier episodes.
“CMS does make these modifications for functions of staying inside the 2.5% of the Medicare spend as a price range for outlier spending,” Dombi mentioned.
The house well being business is at the moment getting ready for the nationwide growth of the House Well being Worth-Based mostly Buying (HHVBP) Mannequin.
In CMS’ proposal, the beginning date of Jan. 1, 2023 stays the identical, however there are some modifications on the standard reporting. This consists of the requirement that OASIS should be finished for all sufferers — no matter payer supply.
Shifting ahead, NAHC is leaning into its advocacy efforts for the house well being business with a view to activate adjustments forward of the ultimate rule.
“This isn’t a proposal that we are able to simply really feel comfy and relaxed with to maneuver ahead with,” Dombi mentioned. “This can be a rule which goes to require a big quantity of advocacy efforts from all of us, with a view to find yourself with an alternate final result than what we see proposed right here by CMS.”