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AHA supports the new home health payment model, required by law and to begin in calendar year 2020, but opposes the prospective behavioral adjustment proposed for next year, the association told the Centers for Medicare & Medicaid Services today, noting the great difficulty in accurately projecting how providers will respond to major policy changes. Instead, AHA said the behavior adjustment should be based on actual experience, noting that the patient driven groupings model is “monumentally complex” and “renders impossible” any attempt by policymakers and stakeholders to accurately project patient use of HH services in CY 2020. The association said the proposed –8.01% behavioral adjustment “is unprecedented for a one-year offset, making it particularly inappropriate for prospective implementation.” Among other comments, AHA urged CMS to only adopt quality measures endorsed by the National Quality Forum, and to reconsider its proposal for HH agencies to collect certain standardized patient assessment data beginning in 2021.