CliftonLarsonAllen LLP  

Minneapolis,  MN 
United States
  • Booth: 601

As our nation’s health care delivery model evolves, you need to adapt. Our CPAs, consultants, and advisors anticipate change, so you’re ready to respond to it. CLA will help you position your organization to thrive and grow as health care transforms.

CLA delivers integrated wealth advisory, outsourcing, audit, tax and consulting services to help clients succeed professionally and personally. Grounded in public accounting, our broad professional services allow us to serve clients more completely and offer our people diverse career opportunities. We believe professional relationships can be personal and those connections can last for generations.

As active members in this field, we're tuned into emerging topics, such as health care reform, changes in reimbursement, new regulatory requirements, and technology advances


A Bike is More Than a Bike

 Press Releases

  • Key insights

    • CMS released a relatively light rule this year due to COVID-19 and the novelty of PDGM.
    • There are no major changes to payments and CMS proposes a 2.7% market basket increase.
    • CMS proposes permanently extending certain telecommunications system flexibilities in effect due to the pandemic.
    • CLA can provide more information on how your home health agency is impacted under the proposed rule.

    Need help interpreting the rule?

    Talk to Our Team

    The Centers for Medicare and Medicaid Services (CMS) released the proposed calendar year (CY) 2021 home health prospective payment system rule (CMS-1730-P). Comments may be submitted through August 31, 2020. 


    Payment updates

    Market basket update

    CMS proposes a 2.7% market basket update and projects this to result in an overall increase of $540 million to home health payments in CY 2021.

    Low Utilization Payment Adjustment (LUPA)

    CMS would maintain the current LUPA thresholds for CY 2021 payment, since there is not enough data to update under the new PDGM model.

    Case-mix weights

    CMS proposes to proceed with the current case-mix weights for CY 2021, since there is not enough data to update those related to PDGM.

    Wage-index update

    CMS looks to adopt the revised Office of Management and Budget (OMB) statistical area delineations from OMB Bulletin No. 18-041 for the labor market delineations used in the home health wage index, effective beginning in CY 2021. CMS also proposes to cap any wage index decrease in excess of 5% for one year. [CMS has made this proposal across its other annual updates, such as the inpatient prospective payment system rule.]

    Standard 30-day period payment

    CMS does not make any behavioral adjustments or changes due to the newness of the PDGM and the ongoing COVID-19 pandemic. The national standardized amount for CY 2021 is $1,911.87.

    CY 2020 30-day
    budget neutral
    standard amount
    Wage index
    CY 2021 HH
    CY 2021 national,
    standardized 30-day
    period payment
    $1,864.03 X 0.9987 X 1.027 $1,911.87

    Source: CMS

    LUPA payments

    CMS provides a look at standard rates with the 2.7% update.

    HH discipline CY 2020 per-visit
    Wage index
    budget neutrality
    CY 2021
    CY 2021 per-visit payment
    Home health aide $67.78 X 0.9988 X 1.027 $69.53
    Medical social services $239.92 X 0.9988 X 1.027 $246.10
    Occupational therapy $164.74 X 0.9988 X 1.027 $168.98
    Physical therapy $163.61 X 0.9988 X 1.027 $167.83
    Skilled nursing $149.68 X 0.9988 X 1.027 $153.54
    Speech-language pathology $177.84 X 0.9988 X 1.027 $182.42

    Source: CMS

    Outlier payments

    CMS proposes no change to the fixed-dollar loss ratio and maintains 0.63 as finalized for CY 2020.


    Policy changes

    Telehealth/virtual health

    CMS proposes permanently implementing several flexibilities that took effect under the COVID-19 Interim Final Rule (85 FR 1920). [For additional information on this rule, read CLA’s Health Care Innovation and Insight blog post.]

    Those flexibilities include telecommunications such as telehealth or remote monitoring, as long as they are included on the home health plan of care. A description of how the technology will help to achieve the goals outlined on the plan of care without substituting for an in-person visit as ordered on the plan of care would be required. While not separately reimbursed, CMS also proposes a broader use of telecommunications technology to be reported as an allowable administrative cost on the home health agency cost report.

    Home infusion therapy services and suppliers

    CMS spends considerable time reviewing the statutory and regulatory history of this benefit along with policies and payments finalized in previous rules. This goes into full effect in January 2021. CMS proposes Medicare enrollment policies for qualified home infusion therapy suppliers.

    Home health quality reporting program

    CMS makes no changes. 

    How we can help

    We are on the front lines of regulatory, policy, and payment changes for providers across the continuum, which includes home health agencies. If you would like more information on how your home health agency is impacted under the proposed CY 2021 rule, or would like other information related to your home health agency, we can provide guidance to meet your specific needs.

  • Today's post is from Cory Rutledge, Principal and leader of CLA’s Senior Living Practice. He previews what we know to date about the single audit requirement related to COVID relief funds.

    The Department of Health and Human Services (DHHS) recently indicated that payments received via the Provider Relief Fund (PRF) will be subject to single audit requirements.  Unless you’ve previously been involved in a single audit, you may not know this term, understand these audit rules or ensure you’re in compliance.  We’re here to help.

    What is a single audit?

    Generally speaking, a single audit is a report required of Federal grant recipients that outlines the recipient’s compliance with the rules and regulations of the grant award.  The single audit is intended to create a level of assurance that the recipient has adequate controls in place surrounding the expenditure of Federal funds. The audit is required to be conducted by an independent public accounting firm hired by the auditee.

    To whom is this applicable?

    Simply stated, if you received over $750,000 in federal awards, which includes the PRF payments, a single audit will be required.  All health care provider types, including hospitals, clinics, skilled nursing facilities, dental groups, and various organizations serving Medicaid populations are included in this requirement. Single audits are required for for-profit, nonprofit, and governmental entities that meet the $750,000 threshold. Given the magnitude of payments being distributed from the PRF, there is a high probability a single audit may be required for your organization. 

    What we know

    To date, very few details have been released in terms of the specific compliance requirements that will need to be tested.  However, given what we know about other single audit requirements, we anticipate that DHHS will be interested in at least three components:

    1. Ensuring the recipient has adequate internal controls surrounding the receipt and use of the funds;
    2. Ensuring the recipient followed the terms and conditions of the funds received; and,
    3. Testing of lost revenue and qualified expenditures.

    What we do not yet know

    Plenty, but as time goes on, we expect specific compliance requirements to be determined and communicated. Rest assured that we are watching this very closely, and we will provide updated communication via the HI2 blog and thought leadership articles as soon as there is news to share.

    CLA can help

    CLA performs more single audits than any firm in the country.  Our experience in helping organizations navigate single audit requirements can give you peace of mind and allow you to focus your energy on your core business…especially during this challenging time.

    *The information for the firms above was pulled from the Federal Audit Clearinghouse for audits with fiscal year ends between January 1, 2018 – December 31, 2018.

    For organizations that need help preparing for a single audit, we are well equipped to help you in creating a comprehensive approach to evaluating, tracking and documenting internal controls and use of PRF funds in anticipation of single audit requirements.  Once the audit details are clarified, we can conduct your single audit – and our technology-forward audit approach allows us to execute the audit without ever stepping in your building! 

  • Congress has provided trillions in economic relief to help organizations get through the financial challenges brought on by COVID-19. These economic relief funds come with rules, especially for health care organizations. Tracking and monitoring is critical and can be very complicated, especially when funding is received from multiple sources.

    Track your economic relief fund expenses with confidence

    Ready to learn more?

    Contact us

    CLA has developed an expense-tracking tool that creates the foundation to organize spending in accordance with compliance and reporting initiatives coming soon.

    The CLA Economic Relief TrackingSM tool helps manage and account for the funds from various economic relief packages, including the Paycheck Protection Program (PPP), the Public Health and Social Services Emergency Fund (Provider Relief Fund), the Economic Injury Disaster Loan (EIDL) program, and the Main Street Lending Program. It also documents the thought processes at the time of using the funds, and provides a trail of information that will assist in responding to future reporting requirements.

    This tool is applicable and for use within all health care organizations, including hospitals and health systems, physician practices and medical groups, federally qualified health centers (FQHCs), and senior living organizations. Our short video below explains how the tool can help:


    The fee for the tool, which includes a training video, is $750. If you’d like to learn more, complete the form below.


  • Health Care Transaction Services - Advisory
    Enhance the efficiency and value of every health care deal at each stage of the transaction....

  • A Unique Approach:

    CliftonLarsonAllen’s integrated financial, tax, operational,
    human resources, and information technology teams have deep
    health care knowledge. This helps us develop a full picture of
    your business and the potential acquisition. We will help you
    understand the full performance potential of the merged entity.
    In addition to outlining the sustainability of historical earnings,
    cash flows, and quality of assets, we also support your purchase
    agreement negotiations, integration challenges, and business
    performance opportunities.

    How we can help:

    We serve as an advisor on more than 100 transactions
    each year. Our health care transaction services include:
    • Private equity and venture capital services
    • Strategic affiliations
    • Health care payment reform analysis
    • Operations and performance improvement
    • Revenue cycle assessments
    • Sell-side, buy-side, operational, and IT due diligence
    • Valuation and financial modeling
    • Transaction tax support
    • Working capital targets and improvement
    • Post-merger integration
    • Purchase price dispute resolution
    • Business succession planning
    • Health care executive search
    • Customized Accounting Solutions Team (CAST)

    Deal Flow:

    CliftonLarsonAllen serves approximately 7,000 health
    care clients and more than 250 private equity, venture
    capital, family offices, and other private capital
    sources. With appropriate consents, we routinely
    approach this client base to identify potential
    acquisition targets and referrals — connecting buyers
    and sellers, and assisting in all stages of the process.

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