NAHC Newsroom

Press Release | Advocacy, Home Health, Legislative, Medicare

Important Statement on Medicare Home Health Final Rule

October 31, 2019


Media Contact: Thomas Threlkeld
Director of Communications


Statement of NAHC President William A. Dombi Regarding the Medicare Home Health Rule Issued Today

PLEASE NOTE: The National Association for Home Care & Hospice (NAHC) will present a webinar explaining all important aspects of the Medicare Home Health Rule on Wednesday, November 6, 2019 at 3:00 PM Eastern. Register here.

(October 31, 2019) CMS late today issued the Final Rule for the 2020 payment model, PDGM, including rates of payment that would start January 1, 2020. The new payment model had been finalized in its design in the 2019 rulemaking cycle. The Final Rule offers some minor tweaks in the payment model and sets out 2020 payment rates. The rule also includes unrelated adjustments in other rules affecting home health, including the 2021 home infusion therapy benefit, quality measures, and the Home Health Value Based Purchasing Demonstration program.

NAHC is greatly heartened by CMS’s modification of the 2020 payment rates to reflect a much more realistic view that any behavior changes in coding or service utilization would not occur instantaneously and in full starting January 1, 2020. In reducing the 2020 adjustment from 8.39% to 4.36%, CMS has given the home health community a chance to safely transition to the dramatically new payment model. NAHC extends its thanks and appreciation the CMS for its thoughtful consideration of the community’s comments in the rulemaking process. We will be working with CMS closely to assess actual behavior changes throughout 2020 and to help develop the standards for determining whether future adjustments may be justified.

The Bipartisan Budget Act of 2018 requires that the home health payment model reform be budget neutral. While it permits behavioral adjustment to payment rates, NAHC believes that assumption-based rate calculation should not occur because of the high risks of error and the creation of an incentive to change behavior solely to maintain Medicare revenues. Instead, NAHC supports adjustments only after actual behavioral changes have occurred. The modifications made by CMS in the behavior adjustment are still based on assumptions, but the revised assumptions are a definite improvement over the proposed ones.

NAHC supports sensible payment reform. While the PDGM payment model reforms include sensible changes, the behavioral adjustment remains a concern, albeit to a reduced level. There is bipartisan, bicameral legislation pending, S. 433 and HR 2573, that can help resolve these concerns fully. A NAHC “thank you” goes out to the sponsors of these bills as they also weighed in with CMS to secure the important and crucial change in the behavior adjustment in the rulemaking process.


About National Association for Home Care & Hospice (NAHC)

The National Association for Home Care & Hospice (NAHC) is the voice of home care and hospice. NAHC represents the nation’s 33,000 home care and hospice providers, along with the more than two million nurses, therapists, and aides they employ. These caregivers provide vital services to Americans who are aged, disabled, and ill. Some 12 million patients depend on home care and hospice providers, who depend on NAHC for the best in advocacy, education, and information. NAHC is a nonprofit organization that helps its members maintain the highest standards of care. To learn more, visit