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Document ID: CMS-2010-0213-0004
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 23 2010, at 12:00 AM Eastern Daylight Time
Date Posted: August 5 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: July 23 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: September 14 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b1fa61
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This is comment on Proposed Rule

Medicare Program: Home Health Prospective Payment System Rate Update (CY 2011); Changes in Certification Requirements for Home Health Agencies and Hospices

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Regarding 424.550 (proposed exemptions) "A publicly-traded company is acquiring another HHA and both entities have submitted cost reports to Medicare for the previous five (5) years." I'm expressing concern over CMS’ exception extending only to publicly traded companies. Acquisition strategies are crucial to the economies of scale for home care agencies seeking growth opportunities. One reason is that home care agencies, through acquisitions, can reduce a number of administrative costs. For example, through the use of web-based collaboration tools an agency can extend a single department (such as human resources) to any number of agencies it acquires. This exception provides an advantage to publicly traded firms.