AHA Comments on the Calendar Year 2025 Home Health Prospective Payment System Proposed Rule

August 26, 2024

The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
Attn: CMS-1803-P
P.O. Box 8013
Baltimore, MD 21244-8013

Submitted electronically

Re: Medicare Program; Calendar Year (CY) 2025 Home Health Prospective Payment System (HH PPS) Rate Update; HH Quality Reporting Program Requirements; HH Value-Based Purchasing Expanded Model Requirements; Home Intravenous Immune Globulin (IVIG) Items and Services Rate Update; and Other Medicare Policies; 89 Fed. Reg. 55,312 (July 3, 2024).

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, including approximately 1,000 hospital-based home health (HH) agencies, and our clinician partners - more than 270,000 affiliated physicians, 2 million nurses and other caregivers - and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the calendar year (CY) 2025 HH prospective payment system (PPS) proposed rule.

The AHA is very concerned about ongoing access challenges for beneficiaries needing HH care, and the potential for CMS' proposed updates to lead to further disruption. HH agencies are vital to Medicare beneficiaries' recoveries, and they partner with acute care and other hospitals to ensure patients can receive the right care in the most appropriate setting. Hospitals rely on HH agencies for safe and timely discharge of patients and to avoid extended hospital stays. We already see the strain on HH operations - and other post-acute care providers - due to financial challenges, creating ripple effects throughout the continuum of care, including for acute and post-acute hospitals. Despite this, CMS proposes inadequate HH agency payment rate updates and further erroneous behavioral adjustments. We urge the agency to reconsider these proposals and take steps to ensure HH agencies receive payment updates that match their financial reality and enable them to continue to provide high-quality care to Medicare beneficiaries.

In addition, the AHA is concerned about the proposed changes for long-term care facility Medicare conditions of participation (CoPs) requiring ongoing respiratory virus data reporting. We do not believe CoPs are the appropriate lever to impose data reporting requirements, and the proposals are poorly defined.

We provide additional detail on these issues, as well as other proposals in the rule, below.

AHA Comments on the Calendar Year 2025 Home Health Prospective Payment System Proposed Rule