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 under served 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 –  see more