September 9, 2019

The Alliance submitted comments to CMS in response to the proposed updates in the CY 2020 Home Health Prospective Payment System. The Alliance noted concern with CMS’ proposal to reduce the Requests for Anticipated Payment (RAP), asking that CMS consider the cash flow requirements of new home health agencies who also have capitalization needs and smaller agencies and those in rural areas have a significant need for cash flow support. The Alliance also strongly opposed the removal of pain measures from the Home Health Quality Reporting Program (HH QRP) and the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS surveys). While CMS reports that elimination of the measure is in line with the agency’s broader efforts to address the opioid epidemic, the Alliance flagged that pain remains an issue that is important to patients served in the home health setting  and there is no evidence to suggest that the use of these measure is linked to opioid misuse. See the Alliance's full comments to CMS below.

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