Guest Post: Nicole K.

Hello everyone,

Today the Home Care Alliance of Massachusetts has graciously allowed me to guest blog on some very important regulatory issues facing home care. I am a home care nurse working in quality and compliance for one the largest home care agencies in the state. Currently, I’m a student at the Yale School of Nursing in their Nursing, Management, Policy, and Leadership program. I am completing an internship here at the Alliance and I plan to end it with a trip to the NAHC “March on Washington” conference this week.

This is a very exciting and challenging time for the industry. Home care is viewed by many as a way to safely and effectively care for people, in a financially sound way. I want to make it THE way for patient-centered care.

As the state and nation look towards care redesign in health care, home care should be at the head of the table for this conversation. Yet at the same time, proposed and enacted federal regulation will do extreme and permanent damage to home care. Currently, the certified home care industry is frantically preparing for the implementation of the Face-to-Face rule that takes effect April 1st. As Bill Dombi from NAHC stated, ” this is the most important Medicare change affecting home care in the last 20 years.”

On a positive note, one of our New England legislators, Senator Susan Collins, is actively working to propel forward a bill that would create greater access to home care for our sickest patients. These are the patients that can’t easily visit a physician’s office due to serious and chronic medical conditions. Senator Collins’ Home Health Care Planning Improvement Act of 2011 (S.227) would allow nurse practitioners and physicians assistants, among others, to order home care. While in Washington, I plan on speaking to any legislator who will listen to me about the damaging impact of the Face-to-Face regulation as well as the importance of passing Senator Collins’ bill. I have also lobbied remotely via telephone and using HCA-prepared emails and you can too. It’s quick and easy and makes you feel good after it’s completed.

Now is the time for all of us who work in home care or have loved ones who use home care to lobby our elected representatives to advocate for the preservation of home care.

Thank You!

Nicole K.

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Lobbying Congress and/or Lobbying CMS?

Next week, Home Care Alliance members will be in Washington DC to make sure that our elected federal officials understand the role of home care in the health care delivery system and the strain on services being imposed by new federal rules, such as the face to face requirement.  We will also be seeking their help in carrying our message to those unelected federal officials who run the Medicare program for the Congress and the American people: the Centers for Medicare and Medicaid. With both enormous responsibility and authority, this federal agency can hugely influence who gets and who provides health care.

In advance of our meetings, the Home Care Alliance sent a letter to United States Secretary of Health and Human Services Kathleen Sibelius asking that she use her recently granted authority to at least temporary impose a “cooling off” period for new home health agencies in our states.   Included in the letter was the following:

  • ” CMS has sufficient data to indicate that rapid increases in the number of home health
    agencies has led to increases in utilization and spending beyond that which would be
    indicated by payment changes, growth in enrollees, or policy actions. The National
    Association for Home Care and Hospice collected data indicating that from 2001-2006,
    Medicare spending grew 2.5 times more in states where the number of home health
    agencies (HHA’s) increased as compared to states where the number of providers
    remained the same or decreased.
  • The proposed rules suggest that determining factors for moratoria include a trend of
    growth that is disproportionate relative to the number of beneficiaries or a rapid uptick
    in enrollment applications. The recent situation in Massachusetts satisfies both of those
    requirements. After virtually no growth between 2001 and 2006, our state has seen an
    increase of 27 certified agencies in the past four years – an increase of more than 20
    percent. This has occurred despite the fact that no area of the state is un-served or
  • This recent growth is driven by that fact that Massachusetts is one of only a few states
    that has neither state licensure nor certificate of need rules for new home health care.
    This ability to “take all comers” was further exacerbated by a CMS decision a few years
    ago to allow state Survey agencies to transfer their responsibilities for new Medicare
    home health certification to private accreditation agencies. Our experience is that these
    private surveys are less rigorous and that it has become much too easy for new agencies
    to become established without a full understanding of the complexity of Medicare
    compliance. In fact, we believe that several agencies received Medicare deemed status
    in the past five years have either been decertified or in danger of being decertified once
    the state makes an initial survey. All of this adds costs and no value to our system.”

Our agenda also includes – thanks to one of our most responsive elected officials Congressman Jim McGovern – a meeting to try to bring some reasonableness to the federal/state “TPL” fight over paying for home care.

Please continue to share your thoughts on both our current industry challenges and what you see as needed fixes.  When we are in DC, we are speaking for you.



Physician Face-to-Face Encounter Update: New Q&As

The Centers for Medicare and Medicaid Services (CMS) have posted new guidance regarding the physician face-to-face requirement in order for patients to receive Medicare home health services.

Questions & Answers have been updated periodically by CMS and a new round has just been made available.

The new Q&A’s include:

Also, if you are from a home health agency and have not already done so, please comment on a national Face-to-Face Encounter Requirement Survey. Your feedback on whether the report reflects the issues your agency is facing will be instrumental in the Home Care Alliance’s advocacy and meetings with federal elected officials taking place at the end of March. You can comment on this newsfeed post or email James Fuccione at HCA.

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Patrick Administration Postpones ADH Rate Cuts, Services Still in Jeopardy

Officials in Governor Deval Patrick’s Administration announced that rate cuts that would have taken effect today (Tuesday, March 15) to Adult Day Health, Adult Foster Care, and Day Habilitation Programs would be “postponed indefinitely.”

Those rate cuts amounted to a total of $10 million for the three programs, but there is still the danger of the much larger $55 million cut to Adult Day Health Services that would eliminate the “Basic” service category. A special advocacy day is planned for March 22 at the State House and any interested agencies offering Adult Day Health services are invited to attend. More information on the event is available here.

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Physician Face-to-Face Encounter National Survey: Please Comment

The Home Care Alliance will be traveling to Washington DC later this month to advocate on many issues of concern, including the physician face-to-face encounter requirement set to be enforced starting April 1.

Please see this summary of results from a nationwide survey and let the Alliance know if your agency is in line with how other home health providers from across the country answered.

The survey was conducted by the National Association for Home Care & Hospice (NAHC) and is important in helping HCA shape the message that will be delivered to our Congressional delegation and other key government officials.

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