In The News

Hospice from a Naturopathic Lens with CDPHE

Thursday, Nov 30  (2:00 –3:00pm MT)

Many fields of Western medicine have begun incorporating integrative therapies alongside more conventional practices, including within the field of hospice. Naturopathic doctors who have a background in both Western and integrative medicine are well-positioned to assist hospice teams and practitioners with a unique understanding of this shift as it relates to end-of-life and palliative care. This presentation, Hospice from a Naturopathic Lens, will discuss who naturopathic physicians are, the intersections of hospice care and naturopathic medicine, possible roles naturopathic doctors could play within hospice, various integrative therapies for common conditions, and finally, a short summary of the hospice survey process.

Presenter Information: Emily Keranen, ND is a health compliance inspector. Prior to joining the Colorado Department of Public Health (CDPHE), she worked as a physician in Arizona, with a focus on integrative thyroid medicine. In her spare time, she enjoys trail running, hiking, and triathlons. 

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CMS Final Rule Reins in 2024 Rate Reduction, But Brings Big Cuts Beyond

HomeCare News

WASHINGTON—The Centers for Medicare & Medicaid Services (CMS) issued its 2024 Home Health Prospective Payment System Rate Update final rule on Nov. 1, landing on more moderate cuts than initially proposed but still enacting rate reductions beginning in 2025 that would present “serious concerns for the home health community,” according to the National Association for Homecare and Hospice.

The final rule calls for a -2.890% permanent adjustment in payment rates to home health agencies in calendar year 2024, half of the full permanent adjustment of -5.779%. The proposed rule called for a slightly lower overall permanent adjustment of -5.653%. CMS said that because the new rule only calls for half of the full permanent adjustment to go into effect in 2024, Medicare payment to home health agencies will increase by .8%, rather than the original 2.2% decrease initially proposed.

“This halving of the permanent adjustment is in response to commenter concerns about the magnitude of a single-year significant payment reduction,” CMS wrote in its announcement of the rule. “CMS will have to account for the remaining permanent adjustment not applied in CY 2024, and other potential adjustments needed to the base payment rate, to account for behavior change based on analysis at the time of future rulemaking.”

But NAHC said the cuts would still come to 6.533% over 2023 and 2024—with more to come in future years.

“We continue to strenuously disagree with CMS’s rate-setting actions, including the budget neutrality methodology that CMS employed to arrive at the rate adjustments,” said NAHC President Bill Dombi. “We recognize that CMS has reduced the proposed 2024 rate cut. However, overall spending on Medicare home health is down, 500,000 fewer patients are receiving care annually since 2018, patient referrals are being rejected more than 50% of the time because providers cannot afford to provide the care needed within the payment rates, and providers have closed their doors or restricted service territory to reduce care costs. If the payment rate was truly excessive, we would not see these actions occurring.”

“The fatally flawed payment methodology that CMS continues to insist on applying is having a direct and permanent effect on access to care,” Dombi continued. “When you add in the impact of shortchanging home health agencies on an accurate cost inflation update of 5.2% over the last two years, the loss of care access is natural and foreseeable.”

NAHC is currently suing CMS, saying the basis for its payment assumptions is flawed, and also pushing Congress to pass the bill S 2137, which would block the final rule.

“We now implore Congress to correct what CMS has done and prevent the impending harm to the millions of highly vulnerable home health patients that depend and will depend in the future on this essential Medicare benefit,” Dombi said. “We urge the Congress to support this bill and enact it into law before the end of the year. The 2024 rate cuts must not take effect” Dombi added.

The new rule also finalizes CMS’s proposals to:

  • Rebase and revise the home health market basket
  • Revise the labor-related share
  • Recalibrate case-mix weights under the Patient-Driven Groupings Model (PDGM)
  • Update low utilization payment adjustment thresholds, functional impairment levels and comorbidity adjustment subgroups for 2024
  • Codify statutory requirements for disposable negative pressure wound therapy
  • Establish payment rules for lymphedema compression treatment and home intravenous immune globulin

The rule also updates requirements for how often and when providers of durable medical equipment prosthetics, orthotics and supplies (DMEPOS) must contact beneficiaries before dispensing resupply items…

Read Full Article

Find the final rule at:

Read a fact sheet on the rule at:


[Updated] CMS Finalizes 0.8% Home Health Payment Increase for 2024, Additional PDGM Cuts

Home Health Care News | By Andrew Donlan

The U.S. Centers for Medicare & Medicaid Services (CMS) released its CY 2024 home health final payment rule Wednesday.

It comes with an estimated aggregate increase to 2024 home health payments of 0.8%, or $140 million, compared to 2023 aggregate payments. But that doesn’t tell the entire story, with sharp rate cuts also finalized.

“The $140 million increase in estimated payments for CY 2024 reflects the effects of the CY 2024 home health payment update percentage of 3.0% ($525 million increase), an estimated 2.6% decrease that reflects the effects of the permanent behavioral assumption adjustment ($455 million) and an estimated 0.4% increase that reflects the effects of an updated FDL ($70 million increase),” the final rule reads. 

CMS is finalizing a permanent prospective adjustment of -2.890% to the CY 2024 home health payment rate, short of a -5.1% adjustment proposed in June.

A -3.925% permanent rate adjustment was already implemented in 2023.

The agency had proposed a 2.2% aggregate decrease in 2024 in June. The full fact sheet on the final rule can be viewed here.

The Nuts and Bolts

While a 0.8% increase in aggregate payments – compared to the 2.2% decrease proposed – is positive news in the near term, CMS is not backing off its desire for permanent, negative adjustments. The agency continues to maintain that it overpaid home health agencies during the first three years of the Patient-Driven Groupings Model (PDGM), too.

The permanent prospective adjustment of -2.890%, while smaller than the 5.1% proposed, is something that providers and advocates hoped CMS would do away with completely.

CMS is suggesting that home health agencies have been overpaid by about $3.5 billion from 2020-2022, which means clawbacks are still on the table. Specifically, CMS believes it overpaid by $873 million in 2020, $1.2 billion in 2021 and $1.4 billion in 2022. 

“A permanent prospective adjustment of -1.767% to the CY 2024 30-day payment rate (assuming the -7.85 percent adjustment was already taken) would be required to offset for such increases in estimated aggregate expenditures in future years,” CMS wrote in its rule. 

Read Full Article

Partnership for Quality Home Healthcare

FHP Strategies Final Rule Assessment


[UPDATED] CMS Finalizes Hospice Special Focus Program, 36-Month Rule

Hospice News

The U.S. Centers for Medicare & Medicaid Services (CMS) has finalized its 2024 home health rule, including the implementation of a hospice Special Focus Program (SFP).

The rule also finalizes the proposed “36-month”rule for hospice providers. The requirement mirrors a regulation that has existed for several years for home health agencies. The final rule forbids any change in majority ownership during the 36 months after initial Medicare enrollment, including acquisitions, stock transactions or mergers.

Despite comments from stakeholders in the hospice community, CMS decided to proceed with its proposed algorithm for selecting providers for the SFP.

“We proposed to identify a subset of 10% of hospice programs based on the highest aggregate scores determined by the algorithm. The hospices selected for the SFP from the 10% would be determined by CMS,” the agency indicated in the final rule. “To identify ‘poor performance,’ we have identified several indicators, namely, survey reports with Condition-Level Deficiencies (CLDs) and complaints with substantiated allegations, and CMS Medicare data sources from the Hospice Quality Reporting Program (HQRP) (Medicare claims and Consumer Assessment of Healthcare Providers and Systems (CAHPS®).”

CMS will also examine hospices’ performance on certain Conditions of Participation (CoPs) that the agency says “directly contribute to the quality of care delivered to patients, their caregivers, and families,” according to the final rule.

Though each of the 23-hospice specific CoPs will continue to have equal weight when it comes to Medicare certification and enforcement decisions, CMS is giving “special attention” to 11 CoPs. The agency contends that a condition-level deficiency on any of these rules may indicate that a hospice is providing poor quality care.

While the hospice community has generally embraced the concept of the SFP, some raised questions about this methodology.

Each of the major national hospice industry organizations voiced concerns about the algorithm that CMS will use beginning in 2024, including LeadingAge, the National Partnership for Healthcare and Hospice Innovation (NHPI), the National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO).

In August, these organizations sent a joint letter to CMS asking to delay the program to allow for the development of a new methodology…

Read Full Article


Developmental Pathways Case Management Challenges

Hello providers,

Over the past several months DP has worked closely with the Colorado Department of Health Care Policy and Financing (HCPF) along with our neighboring case management agencies to plan and carry out the necessary steps associated with Case Management Redesign (CMRD).

As we have reached the scheduled November 1 transition date, we have identified pressure points or what we are calling “known issues” with the transition process, which are outside our local control.

As you may remember, CMRD includes dozens of inter-related projects that are owned and managed by our State partners at Health Care Policy and Financing (HCPF), which serves as our State Medicaid agency. These projects were often funded, at least in part, through nearly $530M in funds from the American Rescue Plan Act (ARPA) and are all intended to improve the long-term care (LTC) system for its members.

These projects encompass several ambitious and far-reaching goals that are intended to improve access to services.

  • This includes implementing an entirely new case management database, called the Care and Case Management (CCM) System.
  • The CCM system is a critical component of case management supports.
  • Unfortunately, as is often the case with big technology shifts, there have been system glitches requiring complex solutioning, as managed by a third-party contractor with HCPF called AssureCare.

These ongoing issues with the CCM system have made it very challenging to access full, complete case management records, resulting in data disruptions that are out of our control as your case management agency.

These disruptions are occurring simultaneously with the unwind of the Public Health Emergency flexibilities and through the planned CMRD transitions, which are required to occur before July 1, 2024, for the State of Colorado to maintain its federal funding for long-term care services.

DP along with other Case Management Agencies (CMAs) have met with HCPF multiple times to troubleshoot the database issues and will continue doing so. Of particular importance is our ability to provide seamless case management transition & ongoing supports in a person-centered, timely manner.

Known Issues Include:

1) Access to case management data:

Case managers may not be able to immediately access or update member information in the designated state database. This means individuals, families, and/or providers may be asked to repeat some information that is “on file” but not immediately accessible to our teams.

When this occurs, we identify the issue & work with the state to resolve it. 

2) Ability to create, update, or print service plans:

Sometimes case managers cannot create or update service plans. When this happens, we have to temporarily document supports in another way & work with the state to fix the issue.

This means that we may not have formal service plan information immediately available to share with individuals, families, and/or providers. 

3) Ability to submit prior authorization requests (PARs) for providers to authorize supports.

Case managers have been having issues both creating & submitting support authorizations (called PARs) in the state’s system, which creates the authorizations that allow providers to bill & be paid for services.

If we can’t upload PARs, providers may struggle with payment.

We are working with the state and providers to ensure, whenever possible, that services are not disrupted but some providers may pause services until the issue(s) are resolved.

4) Disruption in Medicaid eligibility related to the Public Health Emergency (PHE):

Some people are experiencing disruptions to their Medicaid eligibility following the end of the COVID-19 public health emergency (PHE).

The best resource for information about this is found on this website:

Individuals should contact their local county human services office and/or case managers immediately if they experience a disruption in Medicaid eligibility.

5) Disruption in provider billing:

Due to issues with submitting PARs (#3 above) and Medicaid eligibility disruptions (#4 above), some providers are not being paid for services they have provided.

This is extremely frustrating for all parties and we are working closely with our state partners to resolve billing issues as quickly as possible.

Resources From HCPF

Contact Information for DP

In closing,

We know transitions are hard and that complications like the ones listed above only make them feel harder.  While the issues listed above are not being experienced unilaterally by all members or all providers, we are collectively working tirelessly to get meaningful solutions in place as quickly as possible.

Rest assured, both CMAs and HCPF remain committed to fixing these system glitches and improving our collective overall service experience as providers supporting some of Colorado’s most vulnerable citizens. 

On behalf of our CMA partners at HCPF, we will continue to collaborate on shared solutions and will do all we can to support you and your provider agencies during this transitional time.

Thank you for your patience and understanding during these critical transitions,

Developmental Pathways

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