CMS has proposed changes to the HH QRP. Some comments/questions to this proposal include the following:
- Who is/are the ‘Measure Steward’ with home health experience?
- How much HH experience? Where, when and what kind of experience?
- Who is/are the ‘Ad Hoc Review Requester’ with home health experience?
- How much HH experience? Where, when and what kind of experience?
- On page 38389 you note that a similar policy was adopted for the Hospital IQR Program, the PPS-Exempt Cancer Hospital (PCH) Quality Reporting Program, the Long-Term Care Hospital Quality Reporting (LTCHQR) …
- But it must also be identified that all of these segments of healthcare have much larger expenditures on technology (infrastructure; IT, hardware, etc…) than exist in home health and as such this is already built into their reimbursement rates, whereas it is not built into the HH PPS rates.
- If this discrepancy is not accounted for, how can this be considered normal and reasonable?