Hello, everyone, and welcome to our Monday Minute.

Today we’re going to discuss the 2023 Home Health Proposed Rule. This rule has been very unsettling to many. It includes a 2.9% increase in the base rates based on inflation and the market basket, which is in my opinion, a joke. We all know that, given the current situation with inflation and the market basket that 2.9% doesn’t even begin to scratch the surface. To make things even worse or add insult to injury, they are now saying they are going to apply the adjustment, behavioral adjustment, that they had originally proposed at the beginning of PDGM.

They are now saying that the adjustment is over 7%, and that 7% behavioral adjustment combined with the 2.9% increase, and one other adjustment, we’re basically looking at a 4.2% decrease in the overall rates for Home Health moving into 2023.

I don’t have to tell you how upsetting it is that we are facing a decrease of 4.2% in our rates.  When we are currently dealing with the lack of staff, the retention of staff, gas prices, which directly impacts home health agencies, inflation, the cost of living, I just can’t contain how to feel about this. We are in a crisis situation where it is more important than it’s ever been before that you comment before this final rule is released, and that you make sure your voice is heard. Having just the state associations and the national association comment on this rule is not going to get it. We as individual entities in the home health industry are going to have to participate in advocacy surrounding this rule.

In addition to the rate situation, they are also proposing that the baseline year for the Value-Based Purchasing model, to be implemented in 2023, be changed to be 2022 instead of the originally finalized year of 2019. They have in this rule updated the definition of the model baseline year and the agency baseline year, the model baseline year being the baseline year that will be utilized for the benchmarks and achievement thresholds, while the individual agency improvement thresholds would be based on the agency’s baseline year. If they do change the baseline year to 2022, then everyone’s model baseline and individual agency’s improvement baseline years will both be 2022. That will, of course, be for any agency that was Medicare certified prior to January 1, 2022. Anyone who becomes Medicare certified in 2022 would not participate in Value-Based Purchasing until they have had one full calendar year of activity. If they have Medicare certification in 2022, they would have the full year of 2023, of operation, and they would begin to participate in Value-Based Purchasing in 2024.

There are multiple things included within this rule. We will be releasing a detailed blog over the next couple of weeks with some of the more definitive information regarding this rule. For the purposes of this Minute, I wanted to make sure you understood that there is a rate decrease being proposed for home health and that we as an industry must speak up, and we are expecting that all agencies will. We will include in this Minute, the link to the final rule itself, which also contains the link where you can comment online.

We want to thank you all for participating today, and for continuing to care for patients in this extended Public Health Emergency. We appreciate the fact that you are still out there taking care of patients regardless of the situations that we are now having to battle, now inclusive of a possible rate reduction. Please make sure that you stay close to your state and national home care and hospice associations and participate in all of the education that they have available to you. Make sure to pay attention to their advocacy that is continuing both at the state level and national level, but specifically today as it pertains to this proposed rule. Thank you again and if HPS can ever assist, please don’t hesitate to let us know.