Encompass Health Corporation (EHC)
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Earnings Call: Q2 2018

Jul 26, 2018

Speaker 1

Good morning, everyone, and welcome to Encompass Health's Second Quarter 2018 Earnings Conference Call. At this time, I would like to inform all participants that their lines will be in a listen only mode. After the speakers' remarks, there will be a question and answer period. Today's conference call is being recorded. If you have any objections, you may disconnect at this time.

I will now turn the call over to Crissy Carlisle, Encompass Health's Chief Investor Relations Officer.

Speaker 2

Thank you, operator, and good morning, everyone. Thank you for joining Encompass Health's Q2 2018 earnings call. With me on the call in Birmingham today are Mark Tarr, President and Chief Executive Officer Doug Coltharp, Chief Financial Officer Barb Jacobsmeyer, President, Inpatient Rehabilitation Hospital Patrick Darby, General Counsel and Corporate Secretary Andy Price, Chief Accounting Officer Ed Fay, Treasurer and Julie Duck, Senior Vice President of Financial Operations. April Anthony, Chief Executive Officer of our Home Health and Hospice segment also is participating in today's call via phone. Before we begin, if you do not already have a copy, the 2nd quarter earnings release, supplemental information and related Form 8 ks filed with the SEC are available on our website at encompasshealth.com.

On page 2 of the supplemental information, you will find the Safe Harbor statements, which are also set forth in greater detail on the last page of the earnings release. During the call, we will make forward looking statements, which are subject to risks and uncertainties, many of which are beyond our control. Certain risks and uncertainties that could cause actual results to differ materially from our projections, estimates and expectations are discussed in the company's SEC filings, including the earnings release and related Form 8 ks, the Form 10 ks for the year ended December 31, 2017 and the Form 10 Q for the quarters ended March 31, 2018 June 30, 2018 when filed. We encourage you to read them. You are cautioned not to place undue reliance on the estimates, projections, guidance and other forward looking information presented, which are based on current estimates of future events and speak only as of today.

We do not undertake a duty to update these forward looking statements. Our supplemental information and discussion on this call will include certain non GAAP financial measures. For such measures, reconciliation to the most directly comparable GAAP measures is available at the end of the supplemental information, at the end of the related press release and as part of the Form 8 ks filed yesterday with the SEC, all of which are available on our website. Before I turn it over to Mark, I would like to remind everyone that we will adhere to the one question and one follow-up question rule to allow everyone to submit a question. If you have additional questions, please feel free to put yourselves back in the queue.

With that, I'll turn the call over to Mark.

Speaker 3

Thank you, Chrissy, and good morning to everyone joining today's call. The 2nd quarter was another strong quarter for Encompass Health with solid operating and financial results in both segments. Consolidated revenue and consolidated adjusted EBITDA both increased 10.5% and adjusted earnings per share increased 39.4%. These solid results reflect the strength and sustainability of our business model that focuses on serving the most rapidly growing segment of the U. S.

Population. Doug will review the details of our financial and operating performance in just a few minutes. I would spend my time providing a brief update on our strategic initiatives and focusing on regulatory developments, including proposed rules for inpatient rehabilitation and home health. During the Q2, we continued to make significant progress on our key strategic initiatives. Beginning with growth in capacity, on May 1, we completed the acquisition of Camellia Healthcare, which added 18 hospice and 14 home health locations to our portfolio.

The integration of Camellia is on track. And as expected, training and other integration expenses impacted our cost of services and productivity in the 2nd quarter. We also opened 3 home health locations in Georgia, Alabama and Idaho and acquired 1 hospice location in Nevada. In our inpatient rehabilitation segment, we began operating our new 34 bed hospital in Shelby County, Alabama in April and began operating our new 38 bed hospital in Hilton Head, South Carolina in June. Later this year, we expect to open new inpatient rehabilitation hospitals in Murrells Inlet, South Carolina and in Winston Salem, North Carolina, with North Carolina being a new state for us.

We also remain focused on those strategic initiatives that help us ensure we consistently provide high quality, cost effective care and position us for success in the evolving health care industry. We continue making great progress in terms of collaboration, which is resulting in lower discharges to skilled nursing facilities and improved patient satisfaction in our overlap markets. Our clinical collaboration rate for the 2nd quarter was 33.2%, an increase of 460 basis points over the prior year and consistent with the increase we experienced in the Q1 of 2018. This provides us further evidence of the efficacy of our TeamWorks clinical collaboration initiative. We remain focused on achieving our near term objective of a 35% to 40% rate.

Our rebranding and name change is also going well. On July 1, we completed the 2nd wave of transitioning our field assets to our new brand. At this time, approximately 40% of our hospitals and agencies have transitioned to the new brand, with our next wave scheduled for October 1. We also continued our work with the Post Acute Innovation Center to develop advanced analytics and predictive models to enhance clinical outcomes and reduce cost of care across a broader episode of care. We are actively using care management tools at our hospital in Tyler, Texas as part of the hip fracture pilot with CHRISTUS treating mother Frances.

We are continuing to onboard additional data to enhance the patient's longitudinal record and make other enhancements based on feedback from the Tyre project. We also continued our work to develop a 90 day post acute readmission prediction model to identify patients at risk for readmission across all post acute settings. Phase 1 of this project used IRF and home health data, while Phase II of the model development will incorporate acute and other post acute data sets into a longitudinal patient record. Turning now to the regulatory front. In April, CMS released its 2019 proposed rule for inpatient rehabilitation facilities.

If implemented as proposed, we estimate the rule would increase our Medicare reimbursement rates by approximately 1.2% in fiscal year 2019. The 2019 proposed rule also included a proposal to implement budget neutral changes to the patient assessment and case mix system for rehabilitation hospitals in fiscal year 2020, a system that would be based on data collected over a 1 year period from the new CARE patient assessment tool, which has been running concurrently with the established functional independence measure or FIM tool. We have worked individually as well as part of our trade associations to provide constructive feedback to CMS and Congress on this proposal and why it should not be implemented at this time. The proposed new functional assessment items were developed under the Impact Act. That law was enacted to collect clinical data and information to examine the feasibility of implementing new payment methodologies such as a post acute care prospective payment system and not to change existing site specific post acute payment systems.

We certainly appreciate the ongoing efforts of HHS and CMS to reduce regulatory burdens, which is why CMS proposed these changes. However, in this instance, the benefits of collecting only one set of patient assessment data do not outweigh the burdens of collecting 2 sets, as too little is known about the accuracy, the consistency or efficacy of the data and their ability to be used for payment policy purposes. We expect CMS to release the final rule for fiscal year 2019 soon. On July 2 this year, CMS published the 2019 proposed rule for home health. As part of this rule, we were pleased to see our 1st Medicare reimbursement rate increase in nearly a decade coming our way in 19.

The 2019 proposed rule includes a net market basket update of 2.1%, but as in prior years, it incorporates case mix re weightings that are redistributing payments based upon most recent changes in resource used by Payment Group. Based on our current patient mix, we estimate 2019 proposed rule would result in a 1.6% increase in our reimbursement rates for our home health business. In addition, we were pleased to see that CMS proposed to allow home health agencies to include the cost of remote patient monitoring as an allowable cost and cost reports, a cost many providers in the industry have borne for years. If implemented as proposed, these costs would be factored into a home health agency's cost per visit and thus the margin going forward. In addition to the payment update for 2019 and as required by the Bipartisan Budget Act of 2018, CMS is proposing to replace the current home health prospective payment system with a new system called the Patient Driven Groupings Model or PDGM.

Consistent with the directive of the Bipartisan Budget Act, PDGM includes 30 day payment periods and is intended to be budget neutral, albeit relying on assumed behavioral changes to achieve this status. We continue support the movement away from volume based payment mechanisms to those based on patients' needs and acuity. However, PDGM is very similar to HHGM in all respects with one exception, and we remain concerned that elements of it such as not accounting for the relative intensity of care between initial and subsequent 30 day periods could result in unintended consequences related to Medicare beneficiaries' access to care. As we've done in the past, we will continue to work individually and via our trade associations to provide constructive feedback to CMS, and we are hopeful CMS will seek additional industry input, perhaps by reconvening the Technical Expert Panel or TEF, which met only once in this process. It remains too early to assess potential impact of PDGM on our business in 2020.

Much is likely to change in the details of the rule, our approach to the business and our patient mix between now and 6.4% related to coding specificity and LOOPA classifications, which would be implemented as a reduction in payment in order to achieve budget neutral implementation of the PDGM. We will prepare ourselves for these assumed behavioral changes. In addition, and based on our 2016 data, assuming no changes to the rule, our approach to the business and our patient mix, which are all very big assumptions and all unlikely to transpire, the estimated impact to our home health business is an incremental 5.4% reduction. We have approximately 18 months in both the current and subsequent rule making processes to prepare for any resulting changes to the payment system. And as we have demonstrated repeatedly in the past, we are skilled at adapting.

Finally, on May 29, CMS announced its intention to restart the pre claim review demonstration in home health no earlier than October 1, 2018. The new version of the pre claim review now called the Review Choice Demonstration or RCD differs from the original program. The Review Choice demonstration gives home health agencies 3 options to participate, a pre claim review, a post payment review and a minimal post payment review with a 25% payment reduction on all claims. We believe RCD is better than the previous program primarily by providing a way for providers to come off the program for good performance. Basically, if a provider achieves a 90% affirmation rate on pre or post claim reviews, a provider becomes subject only to periodic spot checks.

The program will be implemented in a staggered manner starting in Illinois, then expanding to Ohio and North Carolina and later to Texas and Florida. On a combined basis, our home health locations in these states represented approximately 47% of our 2017 home health Medicare revenue. We believe we're prepared for this demonstration and have been working with Palmetto, the MAC included in the demonstration, to better automate the review process as much as possible. Now moving to guidance. As a result of our strong performance in the first half of the year, we are raising our full year guidance ranges as follows.

We're increasing net operating revenues from a range of $4,110,000,000 to $4,210,000,000 to a range of $4,200,000,000 to 4,275,000,000 We're increasing adjusted EBITDA from a range of $845,000,000 to $865,000,000 to a range of $865,000,000 to $880,000,000 And we're increasing adjusted earnings per share from a range of $3.30 to $3.45 per share to a range of 3.45 dollars to $3.58 per share. With that, I'll turn it over to Doug.

Speaker 4

Thank you, Mark, and good morning, everyone. As Mark highlighted, Q2 was another strong quarter for our company as both of our business segments generated solid revenue and earnings growth and we leveraged our corporate G and A expenses. Our Q2 consolidated revenues and adjusted EBITDA both increased 10.5% over Q2 last year and adjusted EPS, which benefited from a lower effective tax rate, increased 39.4%. Cash flow generation remained strong in Q2 as well, driven by adjusted EBITDA growth and favorable working capital changes, primarily related to improved collection of accounts receivable. Adjusted free cash flow for the first half of twenty eighteen was $281,400,000 an increase of 10.8% over the first half of last year.

The strength of our free cash flow generation in the first half allowed us to fund the purchase of the Home Health Holdings rollover shares in Q1 and the Community acquisition in Q2, while still modestly reducing our leverage ratio to 3.0x at the end of the second quarter. The strength of our balance sheet and the consistency in our cash flow generation were factors considered by our Board of Directors in raising the quarterly cash dividend on our common stock to $0.27 per share and replenishing our common stock repurchase authorization to $250,000,000 These actions notwithstanding the prioritization of free cash flow utilization remains the high quality growth opportunities we see present in both of our business segments. Moving on to the segment results. IRF segment revenue increased 7.3% over Q2 2017 driven by volume and pricing growth. Discharge volume increased 5.2% with same store growth of 3.6%.

Net revenue per discharge increased 2.5%. The increase in revenue per discharge was higher than expected due to lower bad debt, which is now a component of revenue and favorable prior period price adjustments. Our revenue reserve related to bad debt in Q2 was 1.2% as compared to 1.6% in Q2 2017. As can be seen on Slide 21 of the supplemental slides, new prepayment claims denials in Q2 declined both sequentially and year over year. As we've discussed on prior calls, we attribute the reduction in ADR activity to the implementation of TPE across all MAX and the transition of our largest MAX contract from Cahaba to Palmetto.

We are very pleased with the year to date experience we have had with our MAX regarding ADRs, but we still do not have enough experience with Palmetto or TPE to assess the sustainability of the bad debt levels realized over the past several quarters. Additionally, we have still seen no progress on resolving substantial backlog of claims, which is approximately $160,000,000 for our company alone that are awaiting adjudication at the ALJ level. Accordingly, our updated guidance assumes bad debt revenue reserves of 1.6% to 1.9% for the second half of the year. IRF segment adjusted EBITDA for Q2 increased 7.2% to $223,500,000 driven by strong revenue growth and effective labor management. Expense ratios for the quarter benefited from the lower revenue reserve related to bad debt as well as the favorable retroactive price adjustments.

Q2 SWB as a percent of revenues declined 80 basis points to 49.9%. Labor productivity improved during the quarter, evidenced by a year over year decline in EPOB from 3.46 to 3.43. SWB also benefited from a reduction in expenses related to workers' compensation. Our group medical expense for the first half of twenty eighteen increased a modest 2.2% over the first half of last year. Given the favorable performance we experienced in group medical expense during 2017, which occurred without any significant changes to our program structure or beneficiary population, we entered 2018 assuming group medical expenses would be mean reverting and increase in a range of 8% to 12%.

In the first half of twenty eighteen, we continued to benefit a relatively low incidence of high dollar claims and the absence of any significant new pharma solutions. Nonetheless, we believe it is still prudent to assume an increase in group medical expenses for the second half of the year. Our other operating expenses in Q2 increased as a percent of revenues by 70 basis points. This was primarily attributable to an increase in contracted services. Recall that we touched upon this in our Q1 call as well as an increase in provider tax expense, which can be a bit unpredictable.

Moving now to our home health and hospice segment. Q2 revenues increased 23.5% with home health up 19.1% and hospice up 67.5%. Revenue growth for the quarter was aided by the acquisition of Camellia, which we completed on May 1. Segment revenue growth was driven by volume as home health revenue per episode declined 0.2%. Pricing was somewhat better than expected, however, as the impact of Medicare reimbursement rates was partially offset by the favorable resolution of a prior period ZPIC audit.

Home health admissions for Q2 increased 10.4% with 5.1 percent in same store and episodes increased 17.5% with 11.1% same store growth. Please recall that home health is comping against the 13.3% same store admissions increase in Q2 2017, which benefited from improvements in the former Caresouth agencies. Hospice admissions increased 61.3% in Q2 with 35.2% same store growth. We continue to seek opportunities add scale to our hospice business and the Camellia acquisition is a nice step in that direction. Home Health and Hospice segment adjusted EBITDA for Q2 increased 26.8 percent to $41,600,000 Cost of services as a percent of revenue increased 50 basis points primarily due to merit increases, changes in patient mix and Camellia integration expenses.

Support and overhead costs as a percent of revenue decreased by 120 basis points primarily due to operating leverage on revenue growth. And now we'll open the call

Speaker 5

to the same store IRF discharges, which have averaged around 4 percent over the last three quarters. Just hoping you could maybe give us additional color on what is driving that and then put it into the context of the longer term target of 2%. Yes, so just any comment on that would be helpful.

Speaker 3

Yes, I'll start first and then ask Barb Jacobsmeyer to weigh in with her insights. So we've been very pleased with the execution of our sales and marketing teams across the portfolio of our hospitals. I think that they've done an excellent job in articulating the value proposition, particularly when it comes to focusing on the outcomes that we achieve with particularly high acuity level patients in our hospitals. We've talked a lot about the stroke population and our ability over the years to shift away from the lower acuity patient and be able to deliver excellent outcomes on the stroke population. I think those are all really gaining traction and allow us to take market share from not only other IRFs in the marketplace, from also those SNPs that historically had been the recipient of a number of these referrals.

But I'll ask Barb to weigh in as well. Yes.

Speaker 6

You'll notice that we had a nice increase in our Medicare Advantage growth. And to Mark's point, a lot of that is us going out and talking about the value proposition and our ability to not only get the patients home, but make sure that they remain at home, which prevents those readmissions. So we're helping us to be able to not only have our sales force out there with the referral sources at the acute care hospitals, but also with the payers that are ultimately approving these admissions.

Speaker 4

Matt, we've been reluctant to change the target for I shouldn't say the target for the expectation with regard to discharge growth based solely, for instance, on the demographic tailwind that we pointed to because as we've described before, the average age of the patients that we're treating in our IRFs is 76 and the Vanguard baby boomer generation has just turned 72. So although we believe we are starting to benefit from that demographic trend, we think that the bulk of the impact is still in front of us. That said, we were very pleased with the same store discharge growth and the total discharge growth we experienced in the first half. And every quarter will give us another data point as we think about what the true long term expectations ought to be.

Speaker 5

Okay. Thanks for those comments. And sticking here with IRFs, and Barb, maybe I'd ask you to comment, you're about 1 year out from the announcement of the post acute innovation center and obviously you've given us nice updates on the Tyler, Texas pilot. Could you just maybe give us an update again with what's going on there and then plans for further pilots? I know that's something you've discussed in the past.

Just another update Barb would be helpful on that.

Speaker 6

Sure. So we continue to work to increase the data analytics that we have, not only as we look at narrowing the networks of the downstream providers that we use from our IRF settings, but also as we look to help the acute care hospitals determine the best setting for the patients to go to, looking at what is the potential that patient's readmission so that if maybe they would have thought in the past that that patient would go to skilled, it may make more sense with the physician supervision at the IRF setting if they can prevent a readmission for those patients to receive the care to IRF setting. So we're continuing to dialogue with additional acute care hospitals like we did with Trinity Mother Frances to offer the ability to help them with their post acute navigation.

Speaker 7

And Matt,

Speaker 4

as you might expect, this concentration is going to start primarily first with our existing joint venture partners.

Speaker 3

So Matt, I'll just run it real quick. We're very pleased with the progress we're making there in Tyler. And as you know, as we've discussed, longer term we see the ability not only to roll this out to other marketplaces, but also to have cover a number of different assets or facets of but cover a number of different assets or facets of care.

Speaker 4

I will say that with regard to extrapolating this and that is certainly in our near term plans, we're applying the same philosophy that we have to virtually every other strategic initiative we've pursued, which is getting it right is better than getting it fast.

Speaker 1

And your next question comes from Matthew Gillmor with Robert Baird.

Speaker 8

I wanted to ask about the organic bed additions for the IRFs and how that's impacting the volumes. And I think you all target something like 100 beds to add to existing facilities and last year you did above that 100 $66,000,000 and the question really is given the strong volume trends and it seems like those beds are filling up. Is there an opportunity to increase that target and how would you go about assessing that?

Speaker 4

Yes. So there's no doubt that the organic bed additions bed additions are helping with the discharge growth. But as some of our colleagues here are quick to point out, the bed additions, the organic bed additions where we do a bed expansion, that's in response to demand that exists in a market. So that occurs because our folks in the field are doing the right things to sell our value proposition. The demand exists and we're able backfill with that.

As we've mentioned previously, we do a constant assessment across our entire portfolio of occupancy levels and perceived changes on a market by market basis in the competitive dynamic to determine where there are opportunities for bed expansions. The ability to do a bed expansion in a specific market is also influenced by things like whether or not there are certificate of need or license requirements associated with that and whether or not there are any physical constraints on the plant which we're operating. We think the existing target of about 100 beds per year for right now is the right one, but we also believe that as we start to see the benefits of this increasing demand for our services because of the demographic tailwind that that number could go higher in the future. All the

Speaker 3

de novos that we build have the potential. We build them with the intent of having the potential to add that. So we construct accordingly, buy enough land that would accommodate that expansions as well. So as Doug said, we are constantly evaluating opportunities for this, both near term and long term.

Speaker 4

If you look back over the last 10 years, in spite of the fact that we've been increasing our capacity in the IRF segment, the overall supply of licensed IRF in the U. S. Has been relatively flat and that just doesn't align with what we see happening demographically. So, we do think there are going to be opportunities for further capacity expansions in the future.

Speaker 8

Got it. Thanks. And as a follow-up, I did want to ask about the group remodel changes on the home health side for 2020 and I appreciate all the comments Mark made. And I the question I had was, as you think about the rate impact that you talked about, I think you said a little over 5%. Do you have a number or maybe some sort of indication you could give us in terms of

Speaker 7

how much of that could be offset through evolving your patient mix?

Speaker 8

Just wanted to sort of understand what your mix? Just wanted to sort of understand what your ability was to offset it with changing the mix?

Speaker 3

I'm going to let April, Anthony weigh in on that.

Speaker 9

Yes. It's probably just a touch early to have the details. We're still working through our modeling with the rule just coming out in early July to understand the full impact on a kind of diagnosis by diagnosis, patient by patient basis. But our anticipation based on our study of the rule so far in our initial indications is that as we can increase our percentage of referrals from acute care hospitals, That will be a key mitigating factor because if you look at the inherent elements of the rule of post discharge patient from a hospital receives notably more reimbursement than the patient coming out of the community. And so we think the continued growth in that program, the good news is our sales force has been doing a strong job growing that percentage of our population.

And so I think over the course of the next 18 months, we have a lot of opportunities to continue to expand that. The other area of concern to some extent is the significant decrease in reimbursement that we're seeing in some of the therapy not all therapy episodes, but particularly some of the high volume therapy patient needs. And so in those instances, we're going to have to really look at our care planning approach and determine if there are other ways that we can supplant the effort of the therapist with more nursing or aid services and find a better way to sort of balance some of that care. Like I say, at this point, we would have to be pretty general in our responses, but we think over the course of the next few weeks, we will continue to have more and more information to be able to get at a much more granular level of response.

Speaker 1

And your next question comes from Kevin Fischbeck with Bank of America.

Speaker 7

Good morning, Kevin.

Speaker 10

Good morning. Actually, this is Joanna Gajuk filling in for Kevin today. Thanks so much for taking the questions here. So actually, I want to stay on the topic of the groupings model proposal. And I appreciate a comment about it's too early and you have given us some of the ideas around, I guess, changing a little bit referral sources, maybe focus more on the acute and the therapy, I guess, provision.

So on that front, because we also worry a little bit about the labor cost, right? So now I guess if you might need fewer therapists, that's, I guess, good, but then you might need more of these additional home health aids or other forms. So can you talk about how that would kind of change the labor cost dynamic for the home health business given that you might be changing, I guess, the type of care providers that you might have acquired going

Speaker 9

forward? Certainly, if our mix shifts a little bit more toward nursing and away from therapy, it will inherently drive our costs down. Our cost per visit for nursing is notably cheaper than our cost per visit for therapy. Frankly, it's one of the issues that we're bringing forth to CMS in our comments is that we believe the way they have allocated costs between disciplines by using cost report data instead of using Bureau of Labor Statistics data is resulting in a flaw in their model. And it's one of the things we'll be pointing out in our comments likely both this year and possibly the opportunity to do so again next year if it's not fully resolved.

But we think there's a pretty significant kind of misallocation of resources. And so we certainly think that there are opportunities to improve some of those elements through the rulemaking process. But if in fact the answer has to be that we move to a more heavily nursing and aid based utilization of services, we certainly understand that that economically is a more cost effective approach if we can accomplish those outcomes with those lower cost discipline. And we haven't had a supply issue in those disciplines. Really, we haven't on the home health side, we really haven't had a significant supply issue in any of our disciplines, but definitely do not have a particular concern about our ability to increase our proportion of nurses and aids.

We seem to because of our culture of being a best place to work have had a good run of luck of meeting our needs from a staffing perspective on a global basis. There are always exceptions on a market by market basis, on a periodic basis, but not globally. Do we see any concerns there?

Speaker 10

Exactly. That's what I was getting at. So I know I understand the costs per, I guess, FDA will be lower when you have more nurses versus therapists. I was just thinking about whether there's any issues around shortages or things of that nature. But it seems like you are not expecting to have issues kind of finding this incremental home health aid to replace, I guess, if need be for the therapy provision.

So I appreciate the comment. And also any other, I guess, major pushbacks or major comments you plan to include in your response to CMS? I mean, any other major sort of surprises, disappointments with the proposal?

Speaker 9

Well, I guess I would say that the second thing that we think is most of most significant magnitude would be the assumed behavioral change that has been built into the model that's roughly 6.5%. We think that is we don't think, we know that is inconsistent with any prior year behavior that the industry has demonstrated. If you go back and look over the years, the average impact in any single year has been well below the 6 percent level, something more in the 2% to 3% range. And so we think it's a little bit disingenuous for Medicare to assume that in 1 year, the industry is going to react as significantly as a 6.5% kind of baseline adjustment would suggest. And so that will certainly be something that we comment on and propose an alternative approach that even if you do prospective adjustments that you need to phase them in, in a manner that's more consistent with what past industry behavior changes have looked like.

So something again in that 2% range. So we think that's probably the 2nd most significant or really the first most significant thing and then the use of cost report data rather than Bureau of Labor Statistics, probably the second from a magnitude perspective. There are a number of other unwieldy issues around questionable encounters and some of the coding classifications, but those are a little bit more nuanced than the first two that I mentioned.

Speaker 1

And your next question comes from Kevin Ellich with Craig Hallum.

Speaker 3

Kevin? Good

Speaker 11

morning, guys. Thanks for taking the questions. Going back to your comments about remote patient monitoring that would be allowed in the cost reports, wondering if that's factored into guidance or how what sort of benefit could we see in terms of how this would help with your margins next year?

Speaker 4

We haven't given any guidance for next year.

Speaker 11

True. But let's say the final rule is implemented as is, how big of a factor is this? Is it modest?

Speaker 4

I would say very modest.

Speaker 11

Okay. That's helpful.

Speaker 9

And then in reality, all it's really going to do is change future payment policy because the ability to include the cost of remote monitoring in the cost reporting, all that really does is inform CMS about the true total cost of care, which today they've been excluding those costs and that is a valid cost of care, albeit not one that has historically been allowed to be considered. And so when you hear MedPAC and CMS and others report the margin of the home health industry, there are these areas like remote patient monitoring that have historically been excluded from our cost base and yet very much a part of how we care for patients. And so there's no immediate impact. I think it simply informs the regulators, the CMS, MedPAC and others about the true cost of care by allowing us to report that in the cost report, but it will not have any immediate reimbursement effect.

Speaker 11

Thanks, April.

Speaker 4

So to some extent, it may take some of the inflammation out of MedPAC's reports on the trends in home health margins.

Speaker 5

Okay.

Speaker 11

Okay. And then as your leverage has come down a little bit and cash flow remains pretty strong, could you remind us about your capital allocation priorities? And given and also a little bit of color as to what you're seeing on the M and A front in terms of your pipeline? There's certainly been some high valuations for some hospice deals and wondering where you guys plan to allocate capital. Thanks.

Speaker 4

Yes. I think the capital allocation remains very consistent with the priorities that we have stated previously, which is we continue to believe that we have good core growth opportunities in both of our business segments. As Mark mentioned, we got 2 new hospitals opened up in the last quarter. We've got 2 additional openings slated for the balance of this year, and we think there are going to be opportunities to add capacity both in the forms of new hospitals and bed additions on a go forward basis. We'll continue to grow our home health and hospice business predominantly via acquisition.

We were very pleased to be able to complete the Camilia acquisition on May 1. Again, that was roughly $145,000,000 transaction. There are others like that that are out there that will be a candidate to purchase. And as we've stated a number of times here recently, we also have a specific objective to increase the scale of our hospice business and that is likely to happen predominantly via acquisitions as well. So we think that there are good opportunities that are out there.

We feel like the development pipelines in both of our business segments remains sufficiently robust and that will be the top priority in terms of allocating both free cash flow and utilizing the leverage that's built into our balance sheet.

Speaker 1

And your next question comes from A. J. Rice with Credit Suisse.

Speaker 4

J. Rice:] A. J. J.

Speaker 12

Rice:] First off, just when I look at the way the guidance lays out, I think year to date you've been up EBITDA about 11%. And if I look at the second half outlook at this point, what it implies at the midpoint is about 1.5% increase. I understand what you're saying about continuing to be conservative in accruals around bad debts and health benefits. But I just wonder, is there anything is it basically let's just be conservative as we see the year unfold or is there anything that would make the rate of increase that you're seeing moderate to that degree in the back half of the year?

Speaker 4

A. J, you've hit on the 2 key assumptions, which is it was really beginning in the second half of last year that we started to see the substantial reduction in new ADR activity influencing the bad debt number on the IRF side. And that's because it was in July of last year that TPE was piloted and then ultimately rolled out. And it was in August of last year where the Cahaba contract was relapsed. And so we have made the assumption that we're not going to anniversary that favorable bad debt performance in the second half of the year.

That would be in contrast to the year to date trend. But as we have stated, we don't believe that we have enough data points right now to call the ball at a lower level. We'll continue to see how that trend develops with subsequent quarters. And then it's really kind of a similar story on group medical. Again, we came into this year anticipating that because 2017 medical expenses were essentially flat with the level that we had in 2016 that the odds were against us and we couldn't put together 2 years like that in a row, particularly a row, particularly without having made any significant changes in either the structure of our benefits program and really didn't see any changes in the underlying beneficiary population.

Well, for the first half of the year, we were up just over 2% for Group Medical. That could change pretty quickly, so our guidance assumes that we're going to get back into that 8% to 12% level of year over year increase for the back half of the year. And those are the 2 primary things that are set up in the guidance as headwinds.

Speaker 12

Okay. And then just quickly on maybe following up in a different way on the acquisition and commentary. First of all, obviously, you've had, I guess, Camellia for 2 or 3 months now. Any update? And is that trended as you've expected?

Any change in your thoughts there? And then when you think about acquisitions, is the in the home health and hospice areas, the PDGM proposal having any impact on the pipeline, either you're thinking about what you're willing to pay, people's desire to do something ahead of that, any flavor for that?

Speaker 9

Yes, let me take that second question first. So I don't think yet that we've seen PDGM affect the pipeline. I certainly think that it is possible as people begin to process the impact that that rule can have. We've had a few really small players who've kind of just used it as another reason to sort of throw a final straw in the haystack. But I do think that we will see some players that just begin to say the combination of regulatory challenges, reimbursement challenges, cash flow challenges, because there's going to be some changes from a cash flow perspective as well and how some of those 30 day reimbursement payments happen and so forth.

I think all of that could certainly yield to an expanded pipeline, but we haven't necessarily seen that materialize at this early stage.

Speaker 4

And then back up, A. J, on your first question, I think we've been really pleased with the 1st two and a half months here, almost 3 months now of the Camellia integration

Speaker 9

process. Absolutely. And I would just echo Doug's comment there that Camellia, I think we've been acquisitions always result in a few surprises. And I would say our surprises in the Camellia has been pleasant ones that we've been pleased with what we found and the quality of the leadership team. Certainly, we've been able to bring in some processes and enhance some efforts and work together to continue to professionalize the business to match up with our Encompass locations throughout the region.

But we are very pleased with where we are so far and feel like it's going to really be a strong part of our organization as they get fully acclimated to the Encompass way of operation operating.

Speaker 1

And your next question comes from Dana Hambly with Stephens.

Speaker 7

Just to follow-up on Camellia, could you give some rough direction on what you would expect the growth rate and the margin profile to look like and maybe just roughly speaking time to integrate that fully?

Speaker 9

Yes. So I mean, Camellia was a strong performer from a margin perspective when we acquired them. I don't necessarily think the enhancements that we're making are going to completely be margin driven. I think they're going to be more long term sustainable that they're going to be based with solid rest of the processes that allow them to continue to grow. But I don't necessarily anticipate that we're going to see big margin enhancement out of that business simply because it was high performer when we bought it.

But we just think we're going to sort of create stability around that high performance and take some of the risk of volatility out of it with our approach to operations.

Speaker 7

Okay. And then my follow-up on the

Speaker 8

proposed IRF rule,

Speaker 7

I generally understand your opposition to the replacement of the functional independence measure. But could you help me understand a little bit better what the practical and financial implications would be if that proposal were to make it into the final rule?

Speaker 3

Yes, we don't know a lot about the financial implications, but let me talk about just the practical implementation of the tool. And first of all, we don't I want to make sure we're clear, we don't oppose the potential of having the CARE tool replace the FIM. What the whole point of having a CARE tool is one that is a common assessment tool across the various areas of post acute, which we support, but we support it under the pretense that it will be data driven, that the information that they collect from this tool, which we have been using in addition to the FIM tool now since October of 2016 roll out a new roll out a new assessment tool like the CARE tool takes a lot of education for entire nursing staff and therapy staff, which use it to assess every patient that comes in. There's a lot of nuances relative to the use and implementation of this and working an entire group of clinicians off of the FIM tool, which has essentially been in place now for a couple of decades. So we think that that's one of the areas that CMS

Speaker 7

has maybe underestimated the impact of

Speaker 3

rolling out a new in the industry, and just having a little bit of a in the industry. And just having a little bit over 1 year of data to change the entire system is like I said, it's too much too soon. So we'd like to see a couple more years of data collected, so that CMS can adopt a CARE tool that is fully based upon the data that's been turned in by the industry and really have a tool that is going to be applicable for the long term.

Speaker 4

And just following up on that, as a result, if the worst case were to happen and if the rule were to get implemented exactly as it is right now, with this becoming the basis for payment in 2020, the impact would likely be relatively short lived because with each providers such as ourselves, the data set that's informing the reimbursement mechanism is going to get better. And the underlying characteristics of the patients who today require rehabilitation services in an IRF setting and who will in the future is not going to change. So, it will resolve itself over a period of time, but the avoiding that kind of significant disruption potentially impacting Medicare beneficiary access to care in years like 2020 2021 is one of the primary objectives of the feedback that we're giving to both CMS and Congress.

Speaker 1

And your next question comes from DeForest Hinman with Walt, Hausen and Company.

Speaker 3

Hi DeForest.

Speaker 13

Hello, good morning. Couple of questions. I think in the release you mentioned that there was a retroactive price adjustment that impacted the Q2 results. Can you give us the size of that retroactive adjustment in that segment?

Speaker 4

Yes, the impact was about $2,000,000

Speaker 13

Okay. So not very big. And then on Slide 30 in the deck, just clarification for me, I read it a couple of times, but I just don't get it. You're saying that the June 30 valuation for those rollover shares is 195,000,000. Is that reflective of the ballpark 16% holding or is that $195,000,000 is reflective of 11.1%, which would be after that February transaction?

Speaker 4

It's the latter. Okay. Thank you.

Speaker 1

And your next question comes from Kevin Fischbeck with Bank of America.

Speaker 10

Hi, this is Joanna. Thanks so much. I have a follow-up actually on the IRF proposal, but I guess you were trying to answer the question because my concern was that CMS estimated a cut almost 2% cut for the for profits, but you're saying that you would view it more as a short term lift and over time it will work itself out? And my second follow-up question actually on the comment you made on the pre claim review demonstration that was instituted I guess by CMS. So previously you talked about incremental costs that you estimated back then to be $1,000,000 to $1,500,000 or so.

So any change to that? Is it do you include anything in your guidance for that?

Speaker 9

We don't have a firm start date yet. And because it's not yet defined when they would move into some of our larger markets of Texas and Florida, we have not yet put that into our estimates. We will do believe there would be some incremental costs. Some of the details of the proposal would have to come out before we'd really be able to pinpoint what that would be. But we think it will be relatively small for those first three states because we don't have huge volume in those states.

Texas and Florida is when it will start to add up for us.

Speaker 4

And part of what we're benefiting from here as well, Joanne, is that the scale of our home health and hospice business has continued to increase and the scale of those incremental costs to conform to this new demonstration probably aren't increasing much. So it's kind of getting to the point where the incremental level of cost may not be worthy of a specific call out.

Speaker 10

Makes sense. Thank you so much.

Speaker 1

And we have no further questions at this time. So I would like to turn the call back over to Crissy for any closing comments.

Speaker 2

If anyone has additional questions, please call me at 205-970-5860.

Speaker 1

Conclude today's Q2 2018 earnings conference call. You may now disconnect your lines.

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