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CMS Releases CY 2020 Home Health Proposed Rule

Yesterday afternoon, CMS released the CY 2020 home health proposed rule. LeadingAge is doing an analysis but wanted to pass along some initial information and high-level reaction. 

The proposed payment update is 1.3%, or $250 million, in aggregate. The rate updates also include adjustments for anticipated changes with implementation of the PDGM and a change to a 30-day unit of payment, the use of updated wage index data for the home health wage index, and updates to the fixed-dollar loss ratio to determine outlier payments. Note, that our concern with the behavior assumptions has grown as last year the effect was listed at 6.42% that has grown to over 8% in this proposal. 

CMS proposes to eliminate the need to submit a Request for Anticipated Payment (RAP) for every period/episode. They propose to reduce the RAP split-percentage payment to 20% (currently at 60% for an initial episode and 50% for subsequent episodes) for existing home health agencies (HHAs) beginning in CY 2020 with elimination of split-percentage payments for all HHAs in CY 2021. We heard from many of you last year with concerns about changes to RAPs due to cash flow issues. 

The full rule can be found here.

CMS fact sheet can be found here.

LeadingAge is conducting an analysis and seeking input from all members for public comments, due on September 9th. Feel free to contact Aaron Tripp at or 202-508-9433 with any questions.

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Our national partner, LeadingAge, is an association of 6,000 not-for-profit organizations dedicated to expanding the world of possibilities for aging. Together, we advance policies, promote practices and conduct research that support, enable and empower people to live fully as they age.