Premier Comments on Home Health Payment Proposed Rule

Premier submitted comments in response to the CY 2024 Home Health Prospective Payment System proposed rule. In our detailed comments, Premier urges CMS to:

• Advance payments that support home health providers given the current financial landscape and not move forward with payment cuts for CY 2024 while continuing to monitor the Patient Driven Groupings Model (PDGM);
• Continue its work, including the current request for information (RFI), to ensure home health aides are consistently paid wages that are equivalent to other care settings and commensurate with the impact they have on patient care;
• Revise the current definition of infusion drug administration calendar day to allow for reimbursement of home infusion professional services each day that an infusion drug physically enters the patient’s body, irrespective of whether a skilled professional is in the individual’s home;
• Ensure equitable and uninterrupted access to intravenous immune globulin (IVIG) therapy by implementing permanent coverage and payment of items and services related to the administration of IVIG in a patient’s home for a patient with a diagnosed primary immune deficiency disease (PIDD);
• Not adopt or make public the proposed Quality Reporting Program (QRP) measure - COVID–19 Vaccine: Percent of Patients/Residents Who Are Up to Date Measure; and
• Begin publicly displaying data for the measures: (1) Transfer of Health (TOH) Information to the Provider - Post-Acute Care (PAC) Measure (TOH-Provider); and (2) TOH Information to the Patient - PAC Measure (TOH-Patient) beginning with the CY 2025 HH QRP.