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The Center for Medicare Advocacy (the Center), submitted comments this week regarding the 2020 proposed rules for Medicare home health care. The Center is pleased CMS plans to allow therapist assistants to perform maintenance therapy (therapist assistants are currently allowed to perform improvement therapy), recognizing equal coverage for beneficiaries who need safe and effective therapy to maintain their condition or slow decline.

However, the Center also urged CMS to place the interests of all Medicare beneficiaries at the heart of its payment and quality rules. How providers get paid and measured drives who gets access to care. Payment rules must truly reflect Medicare coverage laws, and advance Congressional intent. Unfortunately, the proposed, and already finalized, payment rules fall short of this standard. The proposed rule includes incentives for home health agencies to provide care for people with prior inpatient stays who need short-term care, and disfavors people with longer-term needs who begin home care from the community or an “outpatient” hospital observation stay.

We urge CMS to recall these payment rules and consider the collective impact of home health payment rules and quality measures on all Medicare beneficiaries. New rules should be proposed that encourage access to home health care for all people who qualify under the law, for all services covered under the law. This includes consideration of how traditional Medicare home health payments are subsidizing Medicare Advantage payments to home health agencies.

September 12, 2019 – K. Holt

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