CMS should collect home health telehealth data, experts say

The Centers for Medicare and Medicare Services should collect data about telehealth use in home health to guide policymakers in setting reimbursement rates for providers, experts said during the Medicare Payment Advisory Commission’s September meeting on Friday.

CMS adjusted how the Medicare program pays providers under the home health prospective payment system in 2020 after Congress mandated changes to those payments in the Bipartisan Budget Act of 2018. Under the Patient-Driven Groupings Model, CMS moved from a 60- to 30-day payment unit and stopped basing payments on the number of therapy visits to curb their use.

MedPAC tried to examine the impact of those changes on home health, finding a 20% decline in in-person visits last year. The drop in in-person visits may have stemmed from the payment system no longer encouraging additional visits, according to a MedPAC analysis. But it’s unclear whether payment changes or the pandemic contributed more to the reduction.

“I’m not ready to draw a conclusion yet,” MedPAC Chairman Michael Chernew said.

CMS’ lack of data on telehealth use in home health complicates matters because the agency and MedPAC can’t determine whether Medicare beneficiaries went without assistance or accessed help through telehealth instead.

“It’s hard to know what’s going on without knowing about the telehealth visits,” MedPAC commissioner Dr. Lawrence Casalino said.

It’s likely a mix of both, but no exact figures are available, making it challenging to measure home health utilization. According to a MedPAC survey, 71% of home health agencies increased telehealth offerings last year. If MedPAC could have included telehealth visits in its analysis, the measured decrease in home health utilization probably would have been smaller last year, panel staff said.

Not only would collecting data on telehealth use in home health make it easier to determine whether CMS set payments correctly, it would also offer greater insight into the quality.

“There are some services that it seems like you could do quite well over telehealth and others that maybe not as much,” MedPAC commissioner Stacie Dusetzina said.

MedPAC won’t recommend that CMS require home health providers to report their telehealth use, but the commission may describe the benefits of such a requirement in its March 2022 eport.

A recent CMS analysis found that base payments under the new model were 34% above average costs in 2020, even though the agency had accounted for provider upcoding when it set the rates. Providers objected to CMS’ methodology and threatened to sue if CMS tries to claw back overpayments.

“This is really disappointing,” MedPAC commissioner David Grabowski said. “I thought this model would move us closer to right-sizing or encouraging high-value care. And it seems like maybe this is a step in the wrong direction.”