NAHC Submits Comments to CMS on Proposed Home Health Cost Report Changes

The National Association for Home Care & Hospice (NAHC) and the Home Health Financial Managers Association (HHFMA) submitted comments on the Centers for Medicare & Medicaid Services (CMS) proposed changes to the home health cost report (Form CMS-1728-19) and cost reporting instructions.

On April 16, 2019, the CMS published notice in the Federal Register of plans to revise the existing home health freestanding cost report forms and instructions. CMS also posted online several documents related to the proposed cost report revisions, including the proposed forms and instructions, a crosswalk of the proposed changes, and a document outlining CMS’ justification for making the proposed changes.

Following are comments and recommendation submitted on several of the key areas proposed for revision.

  • Requested the effective date be six months after the cost report changes and instructions have been finalized, rather than the proposed January 1, 2020 effective date.
  • Recommend CMS permit the agency’s designated “Authorized Official” to sign the cost report rather than limit the signature requirement to the agency’s Chief Financial Officer or the Administrator
  • Recommend CMS modify the instructions for Worksheet S-3, Part I  to clearly indicate how Medicare Advantage and Medicaid Managed Care census statistic should be reported
  • Clarify instructions on Worksheet S-3, Part IV with the implementation of the Patient Driven Grouper Model
  • Highlighted concerns regarding a new worksheet (Worksheet S-3, Part V) which captures salaries, fringe benefits, paid hours, and then computes an average hourly wage by occupational category.
  • Clarify instructions for a new general service cost center for remote patient monitoring and telehealth reporting.
  • Request CMS explain how it plans to use the information reported on Worksheet A-7- Analysis of Changes in Capital Asset Balance.
  • Clarification needed on several cost reporting items regarding home health agencies with HHA-based hospices
  • Recommend CMS maintain Worksheet F-2 (Fund Balance / Equity Rollover) in the revised cost repot
  • Noted inconsistency between Worksheet A and Worksheet O

CMS will issue another information collection notice on the cost report changes which provides, another, a 30 day comment period. There is no scheduled time frame for when CMS will issue the second notice, other than some time after they have reviewed the comments submitted in response to the first notice.

Source: NAHC