Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed calendar year (CY) 2023 home health rule. Premier’s recommendations urge CMS to:
- Reject the proposed -7.69 percent permanent adjustment to the home health 30-day payment rate in CY 2023;
- Not implement any permanent or temporary payment adjustment until the next calendar year after the COVID-19 public health emergency ends, provide at least six months’ notice before doing so, and phase in any adjustment with a limit of no more than 1 percent per year;
- Revise its existing 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;
- Consider incentives and pathways to encourage the movement towards value-based care; and
- Consider additional perspectives for data collection as CMS looks to address disparities across CMS quality programs.