LeadingAge submitted comments on the CY2024 Home Health Proposed Payment Rule on August 29, 2023, detailing the devastating impact that the Centers for Medicare & Medicaid Services’ (CMS) proposed cuts would have on our mission-driven home health members. Highlighting the current state of the aging services sector, we explained how continued payment cuts would only continue to decrease access to care.

In a press release, LeadingAge President and CEO Katie Smith Sloan said: “We emphasize the continued and, frankly, troubling, inconsistencies between the Administration’s rhetoric championing home and community providers and its actions, which contradict that.

If the CY2024  rule is implemented as proposed, CMS will have reduced home health payment permanently by nearly 10% over the past two years. These cuts come when demand for our nonprofit, mission-driven members’ services is growing. The situation is unsustainable. Referral rejection rates are soaring. Labor shortages plague the sector; wage and other operational costs are rising. Home health providers, unlike employers in other sectors, are reliant on Medicare and Medicaid dollars for the bulk of their revenue. In this context, any reduction is burdensome. A nearly 10% reduction over two years will be devastating.

She added: “On issues of equity – another Administration priority – it is worth noting that the home health benefit is particularly meaningful for underserved populations. Relative to the Medicare population as a whole, the home health benefit serves an older, sicker, more diverse, and poorer population. In the words of a member: “We will be the last ones there serving the poorest and most underserved in our communities…but each year of cuts makes it harder for us to continue to do that and remain in business. ”

Our comments included a response to the request for information on home health aides and underscored our workforce agenda, while also explaining current challenges to utilizing home health aides in Medicare home health.

The rule also included hospice provisions. We made substantial comments on the proposal around a hospice special focus program and asked that CMS revisit its algorithm before implementation. CMS made several other program integrity-related proposals in this rule that we supported.