Following are a couple of comments for CMS in regards to the changes they proposed for the LUPA Rate calculations for 2015:

Why would the LUPA Wage-Index Budget Neutrality Factor for 2015 be 1.0000 when the 60-day Rate Wage-Index Budget Neutrality Factor was 1.0012?  This would seem to indicate that the LUPA Rate calculation is being discounted 0.12% for 2015.

Wage-costs are wage-costs, whether or not a FULL or LUPA episode!  An agency’s staff are not paid a different rate for a visit associated with a FULL episode as opposed to a LUPA episode.