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News and Press: Industry News

Submit Comments to CMS on 2020 Proposed Rule By Sept. 9

Monday, August 5, 2019   (4 Comments)
Posted by: Kyle Simon

The Centers for Medicare & Medicaid Services (CMS) is accepting public comments regarding the 2020 proposed rule for Medicare home health providers until 5:00 p.m. ET on September 9, 2019.

The following policy changes are the most concerning provisions of the proposed rule:

  • An 8.01% reduction in reimbursement under the Patient-Driven Groupings Model (PDGM) under CMS's assumption-based behavioral adjustment to base rates to account for anticipated diagnosis coding and visit volume changes.
  • Phasing out Requests for Anticipated Payments (RAPs) over 2020 with total elimination of RAPs in 2021. Next year, CMS proposed reducing RAP payments from 60/50% to 20% for existing home health agencies, while new agencies would get no RAP payment. CMS claims that RAPs create fraud risks.
  • Starting in 2021, a Notice of Admission (NOA) must be submitted within five days of the start of care. For every day late, CMS plans to reduce base-rate reimbursements for the unit of care.

A full summary of the proposed rule can be found here.

Recommendations for Comments

Using the PDGM resources webpage and PDGM Action Plan webpage, be sure to review CMS's data that indicates the impact of PDGM on your agency – including your current profit margin and what it looks like once PDGM goes into effect and how that will affect your business and staff – and submit comments online by 5:00 p.m. ET on September 9.

HCAF and other industry organizations will provide more thorough comments on other problematic areas of the proposed rule. There is strength in numbers, so the more business-focused comments from providers, both large and small, are critical to giving CMS a full and clear picture of how devastating PDGM will be should it be implemented as proposed.

Last year, more than 1,200 comments were submitted in response to the now-scrapped Home Health Groupings Model. This figure was by far the most comments submitted from our industry in response to any proposed policy in recent memory. Let's put a dent in that number with as many of Florida's more than 900 Medicare-certified agencies submitting comments by the deadline.


Kyle Simon says...
Posted Tuesday, August 13, 2019
Thanks for weighing in, Margot! Please share these insightful comments with CMS. If you have any questions, I can be reached at
Indian River Home Care, Inc. says...
Posted Tuesday, August 13, 2019
Several of the new policy changes under PDGM will greatly effect the way we provide home health services today. I am the sole owner of a very small, 5 STAR rated Medicare Certified agency. We always provide care with the focus on patient outcomes. We provide care when necessary and do not provide care when it is not. If they need daily nursing visits to keep them out of the hospital, then that is what we do. PDGM will have a significant impact on our cash flow with decrease in RAP payment. I count on RAPs for payroll PDGM will have a significant negative effect on cash flow since most of our referrals come from community as we PREVENT hospitalizations, but accepting these referrals will provide us with less reimbursement then patients coming from the hospital setting. The 8% behavioral adjustment is penalizing the agencies that provide patient focused care and do not manipulate the system. The community deserves our care! Margot Kornicks, RN Indian River Home Care
Kyle Simon says...
Posted Wednesday, August 7, 2019
Seconded, Dan!
Dan Cundiff says...
Posted Tuesday, August 6, 2019
It seems a shame to financially hurt the low cost provider in the modern health care field. The real secret is reducing fraud, to save the system millions of dollars. CMS has the data, they know where the fraud is being accomplished. That seems to be a better strategy than simply reducing all the payments and driving effective, high quality providers out of the business.

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