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PPS 2014 Final Rule – Was Your Voice Heard?


PPS 2014 Final Rule – Was Your Voice Heard?


Every year when the proposed PPS rules are released there is a surge in discussion about the future of home health. PPS 2014 promised significant payment reductions over the next four years compounded by the mandatory rebasing process. Anxiety about how many agencies might close and how the underserved patients would be cared for could be felt throughout the industry. I attended several state association meetings and conferences during those first few months and heard first hand the level of concern, fear and anger expressed by agency leaders.


When a proposed rule is released, there is a defined period of time to submit comments to CMS and PPS 2014 was no exception. It is our opportunity to communicate directly with those that write the rules and make our case for why some things need to be changed. Once the comment period closes, each and every one of them is reviewed and addressed by CMS in the final rule document.


Like many, I kept waiting to see what the final rule would contain. After several delays, the document was released late last month and being the regulatory geek that I am, I read it start to finish. The payment cut was not quite as bad as expected and there still were no changes to the Functional Reassessment rules so at first glance it didn’t seem too bad.


One thing in the rule struck me like a bolt of lightning – there were ONLY 84 TOTAL COMMENTS submitted to CMS!!! There are over 10,000 Medicare certified home health agencies in the country and ONLY 84 COMMENTS?? All the complaining about the pay cuts and the never-ending frustration about reassessment rules that don't make clinical sense and the best we could do was this?


My dad had a bumper sticker on his car when I was a kid and I thought about it with the copy of the rules still in my hand. Here it is –



The silence of our industry is deafening. If we do not take each and every opportunity to make our voices heard we lose the right to complain. We cannot rely solely on others to follow up. It is great that entities like the Home Health Section of the APTA submit comments BUT that is only 1 voice. Change will not happen if we don't get involved on an individual level.


Submitting a comment can be done by phone, email or traditional mail. It doesn't take travel or a meeting or money yet only 84 comments were submitted. I was talking with someone about this and the tone was “CMS doesn't listen anyway so what is the point?” We must keep in mind that silence is seen as agreement and support of decisions being made by CMS.


This is bigger than the home health specific payment rules. Health care reform is impacting all areas of care delivery. Looking at bundled payment options as an example, there are many that think it should be the hospitals that control the payment and the decision about post acute care. Does giving the check to the highest cost provider (with a less that stellar track record of making good post acute recommendations) even make sense?


The comment period for PPS 2014 is past, but we can change how we respond going forward. Below are 2 links anyone can use to send feedback to CMS.



If we don't stand up and advocate for our patients and our industry we will have no one to blame if we are left out of the new models of care.


Cindy Krafft, 12/4/2013


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