October 31, 2022 Washington, DC — Comment on CMS’s CY 2023 Home Health Payment Rate Update Final Rule from Katie Smith Sloan, president and CEO, LeadingAge, the association of nonprofit providers of aging services: 

“CMS has rightly recognized the challenging operating environment providers are currently navigating and reduced payment cuts from the 7.69% proposed in June to the 4% announced today. That, along with the 4% market basket update that addresses rising costs of providing services, indicate CMS is cognizant of current realities. We appreciate that – but at the same time, we remain concerned. 

While in today’s final rule CMS has amended its initial proposal, the agency has made clear that future cuts and clawbacks are on the horizon. The behavioral adjustment methodology CMS used is problematic, as explained in our Aug. 16 comments to CMS, and we are concerned about its impact on our mission-driven, nonprofit providers. 

Rather than impose across-the-board reductions on all providers, a more targeted approach is needed to devise and deliver fair payment policy. We are committed to collaborating with CMS and all stakeholders to achieve a methodology that does so. 

In the meantime, we will redouble our support of and advocacy for passage of the Preserving Access to Home Health Act of 2022. Without more resources, providers’ challenges to recruit, hire and retain staff in a very tight labor market will continue. We reiterate: without staff, there is no care. The final rule does not go far enough in helping to address the current crisis in access to care.” 

We represent more than 5,000 nonprofit aging services providers and other mission-minded organizations that touch millions of lives every day. Alongside our members and 38 state partners, we use applied research, advocacy, education, and community-building to make America a better place to grow old. Our membership, which now includes the providers of the Visiting Nurse Associations of America, encompasses the continuum of services for people as they age, including those with disabilities. We bring together the most inventive minds in the field to lead and innovate solutions that support older adults wherever they call home. For more information visit leadingage.org.