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Press Release | Home Health, Medicare, Policy

NAHC Comments on the CY 2023 Medicare Home Health Services Proposed Rule

August 16, 2022
Media Contact: Thomas Threlkeld
Director of Communications, NAHC

NAHC Comments on the CY 2023 Medicare Home Health Services Proposed Rule

WASHINGTON, DC, August 16, 2022 – Today, the National Association for Home Care & Hospice (NAHC) submitted its formal comments on the CY 2023 Medicare home health services Proposed Rule, which includes 2023 payment rates, along with a variety of other changes affecting the value-based purchasing demonstration program and the collection of quality-of-care data.

“The proposed rule is the most impacting of policy actions by CMS (Centers for Medicare & Medicaid Services) in years,” said William A. Dombi, President of NAHC.  “The proposed payment rate cut of 7.69 percent would send 51.5 percent of all home health agencies into financial deficit in 2023. That would place over three million of the most vulnerable Medicare patients and the five million of Medicaid, VA, and Medicare Advantage patients they serve in real jeopardy of losing care. Medicare would also lose the value that home health services brings to health care overall, likely increasing care costs through extended hospitalizations and higher use of institutional care to fill in the gaps,” added Dombi.

The comments submitted by NAHC argue that:

  • More than 300,000 Medicare beneficiaries have lost access to home health services in recent years, with over 1000 HHAs have closing, and Medicare spending in 2020-2021 at its lowest point since 2010.
  • Congress required that CMS institute a budget neutral payment model in 2020. That model underpaid home health agencies by 2.5-3.2% in contrast to the 6.9% overpayment alleged by CMS.
  • CMS’s evaluation as to whether the new payment model was “budget neutral” is fatally flawed in its methodological approach and is inconsistent with comparable evaluations CMS applied in other sectors.
  • CMS’s evaluation methodology is at odds with the clear mandates established by Congress in 2018 in all respects.
  • CMS compounds the risks to patient care by adding new, unnecessary costs while failing to adequately recognize the significant labor and transportation cost inflation that has hit home health services.
  • CMS is pulling resources from home health care at a time it is depending on that care to reduce Medicare spending on hospitalizations and other care.

“We sincerely hope that CMS will recognize that its proposal is off the mark and take all necessary corrective steps in the issuance of a Final Rule this fall,” said Dombi. “CMS should be supporting health care at home, not tearing down its foundation.”

Bipartisan legislation, the Preserving Access to Home Health Act of 2022 (S. 4605/H.R. 8581), is currently pending in the United States Senate and House of Representatives, would suspend any payment rate reductions, thereby allowing CMS additional time to reconsider its proposed actions.

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