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 Volume 23.09

At the recent meeting of the Medicare Payment Advisory Commission (“MedPAC”), the staff presented to the commissioners the following:

  • Medicare margins have declined,
  • Medicare home health expenditures have declined,
  • The number of home health agencies has declined,
  • The number of Medicare program beneficiaries receiving home health services has declined, and
  • In-person visits per day have declined.

Even so, the staff has recommended to the commissioners that home health base payments be reduced by seven (7) percent.

As reported by Bill Dombi, President of NAHC, “When policymakers don’t receive accurate information, they risk making policy decisions that have unintended, yet negative, consequences on beneficiaries.”

On December 8, 2023, NAHC released Home Health Leaders: MedPAC Home Health Margin Estimates are Dangerously Flawed, Risk Misleading Policymakers.

Generally, NAHC makes the following arguments after the MedPAC staff presentation:

  • The presented data is misleading,
  • The data quality is poor,
  • The methodology is opaque, and
  • The results are not suitable for policymaking.

The MedPAC home health presentation is available here.  Final recommendations to Congress will be determined at the March 2024 meeting.  Additional information from the December meeting is available here.

There is no question that patient services are being impacted by reimbursement policies being implemented by CMS.


Many home health agencies operate on a December 31st year-end.  Accordingly, agencies should already be planning for the completion of the Medicare cost report that is due to the Medicare Administrative Contractor (“MAC”) on or before May 31, 2024.

The Home Health Agency Cost Report (CMS-1728-20) incorporated information that was previously not required.  Some information has been difficult for agencies to secure and, accordingly, has created preparation difficulties.  The quality of the cost report submission is important, especially given the continuous focus by CMS on payment rates.  Agencies should be having conversations with those responsible for cost report preparation to continuously improve the quality of the cost report submission.

The changes that were made in 2020 are briefly summarized here.