(Alexandria, VA) – The National Alliance for Care at Home (the Alliance) has submitted comments in response to the Centers for Medicare & Medicaid Services’ Calendar Year (CY) 2027 Home Health Prospective Payment System Rate and Durable Medical Equipment, Prosthetics, Orthotics, and Supplies Competitive Bidding Program Updates proposed rule. The letter notes that the Alliance appreciates that, for the first time since CY 2022, CMS proposes a full annual payment update, does not propose to apply a new permanent adjustment, and acknowledges that behavior changes reflected in CY 2023 and later claims are attributable to confounding factors rather than to the Patient-Driven Groupings Model (PDGM). However, the comment also emphasizes that these decisions do not undo the harm already built into the payment rate, nor do they do enough to protect access to care across the country.
The letter states that four consecutive years of permanent adjustments have reduced the 30-day rate by 9.37% or over $1.5 billion annually. CMS also proposes to continue the –3% temporary adjustment, collecting approximately $500 million against a calculated balance of $4.9 billion. The Alliance estimates the permanent adjustments will produce aggregate reductions of $18.9 billion from CY 2020 through CY 2030.
A single positive update does not restore a base rate reduced by 9.37% that will continue to be cut by roughly 3% annually for the next decade. The confounding factors CMS correctly identified for CY 2023 and later were present earlier, and the methodology that produced the adjustments still embedded in the rate remains flawed. Unequivocally, more must be done to defend access to home health in the face of years of payment cuts paired with rising costs and increased demand.
The letter also details the Alliance’s recommendations related to the broad set of enrollment proposals impacting the entire Medicare provider and supplier community. The Alliance supports CMS’s goal of removing bad actors from the program, yet expresses concern that many of these proposals do not distinguish bad actors from legitimate providers operating in good faith. As proposed, CMS could deny or revoke a legitimate provider’s enrollment based on a neighbor’s conduct, a shared address, a vendor relationship, or an innocent administrative error. Revocations should be weighed carefully considering the impact they have not only on the provider, but also beneficiaries served.
The Alliance is committed to ongoing collaboration with CMS to achieve a payment system that supports the true cost of delivering high-quality care in the home and provider enrollment and program integrity measures that distinguish between bad actors and providers operating in good faith. Demand for care at home is rising, and studies show home-based care is the preferred option for those who need it. The Alliance urges CMS not to finalize the proposed temporary adjustment for 2027 and to provide a sufficient rate update that supports quality care delivery. The Alliance also urges CMS to remove provider and supplier enrollment proposals that will have serious and deleterious impacts on beneficiaries and providers alike.
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About the National Alliance for Care at Home
The National Alliance for Care at Home (the Alliance) is the leading authority in advancing care in the home. We envision an America where everyone has access to the highest quality, person-centered healthcare wherever they call home. Through advocacy, education, and convening, we connect providers and stakeholders to strengthen care delivery across the home-based care continuum — spanning home care, home health, hospice, palliative care, and Medicaid home and community-based services. Learn more at www.AllianceForCareAtHome.org.
Press Contact
communications@allianceforcareathome.org
Hannah Kristan | 202-355-1647