HH CY 2011 AHA Comment Ltr final 9.14.10x

September 14, 2010 Donald Berwick, M.D. Administrator Centers for Medicare & Medicaid Services Hubert H. Humphrey Building 200 Independence Avenue, S.W., Room 445-G Washington, DC 20201 RE: CMS–1510–P; Medicare Program; Home Health Prospective Payment System Rate Update for Calendar Year 2011; Changes in Certification Requirements for Home Health Agencies and Hospices; Proposed Rule Dear Dr. Berwick: On behalf of our more than 5,000 member hospitals, health systems and other health care organizations – including approximately 1,200 hospital-based home health agencies – and our 40,000 individual members, the American Hospital Association (AHA) appreciates the opportunity to comment on the calendar year (CY) 2011 proposed rule for the home health prospective payment system (PPS). Our comments address AHA’s two overarching concerns with the proposed rule: 1) the significant, across-the-board cuts intended to adjust for coding and documentation; and 2) the proposed requirements pertaining to a face-to-face examination of the patient by the physician prescribing home health services. The overall fiscal impact of this proposed rule – negative 4.71 percent – is too severe for hospital-based home health agencies. Hospital-based agencies often serve sicker patients who are medically able to transition from the hospital to home, but are difficult to place in the community due to their need for more involved, and often more costly, home ...