Help Stop HHGM!

CMS’s Proposed HHGM Payment System Will Disrupt Home Health Payments and Access to Care

CMS is planning major changes for the way home care agencies are reimbursed for Medicare services, and the industry is pushing back hard. New Hampshire providers need to voice their concerns by contacting our Congressional Delegation and submitting comment letters to CMS.

The HHGM is a radical shift that will dramatically cut home health payments and restructure care delivery, and it’s an entirely untested model. It’s imperative that our Congressional Delegation and CMS hear from New Hampshire providers! Take Action today!

Summary of the Issue

When CMS released its proposed rule for the 2018 Home Health Payment Update, it also announced its plan to replace the HHPPS Case Mix System (HHPPS) with a new Home Health Groupings Model (HHGM) in 2019.  CMS’s intent is to align payments to patient needs and protect access to care for vulnerable populations.

HHGM would fundamentally change how home health providers are paid and how care is delivered.  Here are the key elements of HHGM:

  • No longer directly reimburse for the number of therapy visits.
  • Base reimbursement directly on patient care and case characteristics.
  • Include Non-Routine Medical Supply costs in the base rate.
  • Shorten home health episodes from 60 days to 30-day periods, while retaining 60-day standards for assessment and plan of care

The HHGM would redistribute payments away from medically-necessary therapy services that are currently producing savings in innovative payment models.  Patients would be forced to access institutional care rather than receive appropriate care in their homes.  The payment redistribution would vary significantly across states and regions.  According to a report by the consulting firm Dobson DaVanzo & Associates, 27% of agencies would experience a +/- 20% shift for the same cases under HHGM.  41% of agencies serving ACO-attributed beneficiaries would experience a +/- 20% shift.   Rural and small communities could be hit the hardest. While the HHGM proposal is supposed to be budget-neutral, CMS estimates it will remove $950 million in home health payments in 2019.

When HHPPS was introduced in the late 1990s, 15% of existing home health agencies closed, utilization dropped by 29% and payments were reduced by $8 billion in three years. If HHGM is implemented, a similar experience is expected.  The HHGM is an untested model on paper that could cause enormous disruption and unintended consequences for the Medicare home health benefit.

Take Action

What You Need to Do!

FIRST: Contact our Congressional Delegation and ask them to urge CMS to withdraw the HHGM policy from the proposed rule.

CMS should work with stakeholders in a more inclusive process that leads to policy changes that do not limit access to beneficiaries or diminish provider resources.

The solution is:

  • The HHGM policy must be withdrawn from the HHA CY 2018 Final Rule
  • HHGM must be revised in a true budget-neutral fashion
  • CMS should initiate a partnership with the industry and beneficiary stakeholders to a design a payment model that supports a patient-centered, quality-driven system.
  • HHGM should be phased-in over a multiple year transition beginning no sooner than 2020.

To contact our Congressional Delegation via email, go to the NAHC Legislation Action Network  Fill in your information and click “send email.”  This will send a pre-drafted email to Senators Shaheen and Hassan, as well as Congresswoman Kuster or Shea-Porter (based on your zip code.)  Or, write you own message in the email.  Please share this information with your agency’s entire team!

Another option is to call our Congressional Offices and leave a message:

  • Senator Jeanne Shaheen — 202-224-2841
  • Senator Maggie Hassan —  202-224-3324
  • Congresswoman Ann McLane Kuster — 202-225-5206
  • Congesswoman Carol Shea-Porter — 202-225-5456

SECOND: Submit a comment letter from your agency on the CMS Proposed Rule.

Urge CMS to withdraw the HHGM. Comment letters are due by 5pm on September 25thSubmit comments at

  • Click on “Comments due in next 7 days.”
  • On the left side of the page, click the boxes for “proposed rule” and “Food Safety, Health and Pharmaceutical”.
  • Scroll to the listing for “Medicare and Medicaid Programs: Home Health Payment Update.”
  • Follow the prompts and upload a pdf of your letter.

The Elevating HOME HHGM Advocacy Toolkit has a helpful Sample Comment Letter and additional resources.

HHGM Resources

Here are some helpful resources: