Following is an excerpt from the article "Home Health Industry Contends Cuts Will Punish the Good Guys," which appeared in AIS' Report on Medicare Compliance:

The final rule that updates Medicare home health payment rates for 2012 cuts payments by $430 million, and removes incentives and excess compensation for unnecessary therapy, CMS says. But many home health agencies (HHAs) claim the changes will prevent them from making ends meet.

The PPS classifies patients into groups based on their anticipated use of resources, says Quashie.

"'Real' case-mix increases are associated with actual changes in patient conditions, whereas 'nominal' case-mix growth results from changes in coding or classification practices," explains Bajcsi.  "CMS sees case-mix adjustments as necessary to correct for this 'case-mix creep.'"

However, "CMS has faced criticism that its methodology underestimates the percentage of case-mix change that is real," Bajcsi notes.

"The home health industry feels that the problems that are being addressed here are not widespread, and are not across the board. They are limited to certain providers more prevalent in certain geographic areas," such as Florida and Texas where several criminal prosecutions have occurred, says Parker.

"The evolution of patterns of therapy utilization since the PPS began leaves doubt that appropriate care has been provided," Parker says. "So [CMS is] hoping that, if they scale back the increases across-the-board to the industry, that will have the effect of reducing home health reimbursement overall and will solve this therapy issue," Parker says.

Parker says CMS has made it a little easier for HHAs to comply with this requirement. Many of them "are having a really tough time with it, and it presents a barrier to getting paid," he says.

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