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June 27, 2007
Ms. Leslie Norwalk, Esq.
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
ATTN.: CMS-1541-P
Re: Medicare Program; Home Health Prospective Payment System Refinement and
Rate Update for Calendar Year 2008; Proposed Rule, Federal Register, Volume 72,
No. 86, Friday, May 4, 2007
Dear Ms. Norwalk:
On behalf of our approximately 200 member hospitals and health care systems,
the Illinois Hospital Association (IHA) is taking this opportunity to formally
comment on the proposed rule establishing new policies and payment rates for
home health services for fiscal year 2008. IHA commends the Centers for Medicare
and Medicaid Services (CMS) for its thorough analysis and its refinements to the
Home Health Resource Groups (HHRGs) to better improve accuracy in patient
classifications and payments in this rule; however, the Association does have
some concerns with several of the provisions. Therefore, in accordance with
instructions in the rule, the Illinois Hospital Association presents the
following comments for your consideration:
PROVISIONS OF THE PROPOSED REGULATIONS:
Refinements to the case-mix model: CMS proposes to apply a 2.75%
reduction in payments for each of the next three years to account for the
historical increases in case-mix that were the result of coding improvements
and not the result of changes in patients’ severity of illness. Instead of
proposing such dramatic reductions, the Illinois Hospital Association urges
CMS to further analyze the change in case mix since the implementation of
the home health PPS. The proposed "behavioral offset" would be particularly
harmful to hospital-based, home health agencies that often treat the more
medically complex, post-acute patients not treated by community-based
agencies. In addition, many hospital-based agencies are rural providers;
payment reductions could have the unintended consequences of closure or
reduction in services for these facilities, which in turn, will reduce
access to these services for those rural beneficiaries.
Significant Change in Condition: CMS has proposed eliminating the
Significant Change in Condition (SCIC) adjustment primarily due to the
historically low volume of episodes that applied. The Illinois Hospital
Association would recommend that CMS withdraw this proposal for FY 2008 and
FY 2009 until the impact of the expanded listing of home health resource
groups (HHRGs) on this payment adjustment can be evaluated. While the
volume of SCIC episodes may be low under the current 80 HHRGs, it is
conceivable that this volume could increase under the proposed 153 groups.
Low Utilization Payment Adjustment: The Illinois Hospital
Association is pleased that CMS continues to examine improvements to the
home health PPS. According to the proposed rule, CMS is proposing an
increase of $92.63 in the payment for LUPAs (low visit utilization episodes)
to recognize the additional costs incurred by the agency on the first day of
care. The payment amount is based principally on CMS’ analysis focusing on
nursing and physical therapy visits for low utilization episodes. While
IHA supports the proposed increase in payment under these situations, it
encourages CMS to examine the presence of other home health service visits
(i.e., social service, occupational or speech therapy) to ensure that the
proposed payment amount recognizes all service costs incurred with these
initial visits.
Ms. Norwalk, thank you again for the opportunity to comment. The Illinois
Hospital Association also welcomes the opportunity to work with your agency in
the continued development and refinement of the Medicare payment system for all
providers.
Sincerely,
Thomas A. Jendro
Senior Director, Finance
Illinois Hospital Association
(630) 276-5516
tjendro@ihastaff.org
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