As the “debate” continues in Washington over the debt ceiling and capping government spending, home care nurses added their voices to those speaking against propoals that would cut Medicare funding and impose co-payments. What is at stake are proposals by: 1) The National Commission on Fiscal Responsibility and Reform that would impose a uniform 20 percent co-pay and a uniform overall deductible of $550 for all Medicare services combined, including home health care; or 2) the Medicare Payment Advisory Commission (MedPAC) which recommended a home health copay (as much as $150 per episode) for episodes not preceded by a hospital or nursing home stay as a means to encourage beneficiaries to control utilization of care.
Congressman James P McGovern (D-MA) a long time champion of home care spoke to the nurses saying: “It is important that members of Congress understand that you are part of the solution,” McGovern said. McGovern said that keeping a person at home is cheaper and patients are ultimately happier.
Home Care Alliance Board member Elaine Stephens, of Overlook VNA, represented Massachusetts at the nurses rally that also included remarks from National Association for Home Care President Val Halamandaris and Max Richtman, executive vice president and acting CEO, of the National Committee to Preserve Social Security and Medicare.
To send a message to Congress to keep home care cuts out of debt ceiling discussions, go to the Alliance’s advocacy page.
A new report from the Office of Inspector General has found that Medicare spending on hospice care for nursing facility residents has grown nearly 70 percent since 2005. Many hospices had a high percentage of their beneficiaries residing in nursing facilities, and most of these hospices were for-profit. Compared to hospices nationwide, these high-percentage hospices:
- received more Medicare payments
- had a longer average length of stay
- served Medic are patients whose diagnoses required less complex care
- served more patients who already lived in nursing facilities before they elected hospice care.
A previous OIG study published in September, 2009, concluded that Eighty-two percent of hospice claims for beneficiaries residing in nursing facilities did not meet Medicare coverage requirements.
The OIG report notes that Medicare currently pays hospices the same rate for care provided in nursing facilities as it does for care provided in the home, but nursing facilities are staffed with professional caregivers and are often paid by third party payers, such as Medicaid. These facilities are required to provide personal care services, which are similar to hospice aide services that are paid for under the hospice benefit.
The OIG concluded that some hospices may be seeking beneficiaries with particular characteristics, including those with conditions associated with longer but less complex care. Such beneficiaries are often found in nursing facilities. By serving these beneficiaries for longer periods, the hospices receive more Medicare payments, which can contribute to larger profits.
The OIG report recommends that CMS (1) monitor hospices that depend heavily on nursing facility residents and (2) modify the payment system for hospice care in nursing facilities. CMS concurred with both of our recommendations. It also agreed that the current payment structure may provide incentives for hospices to seek out beneficiaries in nursing facilities, who often receive longer but less complex care
The OIG website has a special page devoted to Medicare hospice issues. The page includes links to the new report, a podcast interview with Jodi Nudelman, the Region II Inspector General for Evaluation and Inspections, and several other OIG studies of hospice issues. This is the first in a series of three studies by the OIG of hospice services to nursing facility residents. Additional studies will examine the marketing practices of hospices that focus on nursing home residents and the business relationships of such hospices with nursing facilities.
Return to www.thinkhomecare.org.
At its July meeting, the Massachusetts Quality and Cost Council (QCC) put on its agenda for the coming year a plan to place CMS Home Health Compare data on its consumer education website. The state’s My Health Care Options website was established by the Mass QCC as a resource for patients and families looking to make informed health care choices. The majority of the data on the site to date have been on hospital and medical practice quality and costs, with a new update of these data posted in January 2011.
Home health care was identified in the QCC’s Three Year Reporting Pla as “a vital service to the aging population and an important area of information for consumers.” The Council is exploring options to download the CMS data in a consumer friendly format, as opposed to simply placing a CMS website link. The costs and feasibility of this are being reviewed prior to the Council’s next meeting.
Are consumers or other referral sources using CMS data now? Will it get more visibility on the state’s website? What are your thoughts?
The Centers for Medicare and Medicaid Services (CMS) has provided new guidance and updates on their Community-Based Care Transitions Program.
New panel review dates for submitting applications beyond August 18th have been posted and are as follows:
- October 6 & 7, 2011 – Applications must be received by September 6th to be considered for this review.
- November 15 & 16, 2011 – Applications must be received by October 14th to be considered for this review.
- November 30 & December 1, 2011 – Applications must be received by October 28th to be considered for this review.
Secondly, more than a full page of new guidance has been added to the program’s Question & Answer section. Below are a few examples:
- Q: How shall we anticipate to cover up front costs? I heard that CBOs would be paid a per eligible discharge rate that is determined by target population, interventions proposed, anticipated volume and expected reduction in readmissions (cost savings) Can you give a concrete example of how this payment methodology would work?
A: Because this program seeks to build off of earlier care transitions initiatives and requires applicants to have a track record in the delivery of care transition services we are not paying “start up” costs. CBOs will be paid on a monthly basis for services delivered in the previous month. This payment will be whatever the agreed upon per eligible discharge rate is multiplied by the number of eligible beneficiaries served in the previous month. Please refer to the budget worksheet available on our program webpage for additional guidance on developing the per eligible discharge rate.
A: These are the patient experience measures that CBOs will be required to collect and report during the program. We will provide the instruments to awardees at the time of award.
The Home Care Alliance has also made a webinar available on the experiences from a previous CMS care transitions demonstration program that worked through 14 QIO’s across the US. The webinar focuses on, among other things, drawing from the Home Health Quality Improvement campaign’s Best Practices Intervention Package.
More info from this newsfeed on care transitions is available here.
Return to www.thinkhomecare.org.
Governor Deval Patrick signed the state’s fiscal year 2012 budget amounting to $30.6 billion with a victory for home health.
Language that would move MassHealth one step closer to reimbursing home health agencies for telehealth services was included in the “MassHealth Managed Care” line item:
…for purposes of long-term health care cost savings and enhanced patient care, the commonwealth may recognize telehealth remote patient monitoring provided by home health agencies as a service to clients otherwise reimbursable through Medicaid
The key word in this language is “may.” MassHealth is not directly instructed in the budget to reimburse for telehealth (as if the word “shall” was used), but it presents the state with the option to do so, which means that continued advocacy will be required to push the state towards that end. This is a solid victory for the Alliance’s budget advocacy thanks to the hundreds of emails that were sent from the HCA website’s Legislative Action Center and to the office of Senator Richard Moore.
Another item of interest is in regards to Adult Day Health where the Governor approved a budget that makes “no changes prior to December 31, 2011 in the clinical eligibility or level of reimbursement paid to providers of adult day health services for basic and complex levels of care.” The budget also imposes a temporary moratorium on enrollment of new Adult Day Health providers until such time that a study is completed by the Executive Office of Health and Human Services. The study, due to the Legislature by December 31, 2011, will provide a basis for new licensure and rate structure and also will provide a needs assessment of ADH services going forward.
For more information, the full budget is available on Mass.gov.
Return to www.thinkhomecare.org.
As part of the Home Health PPS Update for Calendar year 2012, CMS also made some minor technical changes to the therapy assessment language found in the prior PPS update for 2011.
Currently the regulation reads that the qualified therapist from each discipline must provide the therapy service and functionally reassess the patient…during the visit which would occur close to but before the 19th visit per the plan of care. The regulation will now read “…during the visit which would occur close to but no later than the 19th visit per the plan of care.
Additionally, CMS clarified when occupational therapy is considered a “dependent” service and when it is considered a “qualifying” service.
It is a dependent service when the beneficiary initially qualifies for the home health benefit beginning the first episode of care. That is, the beneficiary’s eligibility for the home health benefit is established by virtue of a need for intermittent skilled nursing, speech language pathology or physical therapy. Then they are entitled to SN, PT, ST, HHA, MSW and OT.
When occupational therapy is the sole skilled service being provided in subsequent episodes after the benefit has been established it is considered a “qualifying service.”
The debt ceiling negotiations are accelerating in Washington and a deficit reduction deal could be imminent. Clearly, from news reports, we know that Medicare cuts are under serious consideration, including the imposition of a home health co-payment.
The Medicare Payment Advisory Commission (MedPAC), the National Commission on Fiscal Responsibility and Reform, and the Congressional Budget Office have all supported a copayment as a deficit reduction measures. Also on the table, as reported in today’s Boston Globe, a substantial cut to medical education funding for Massachusetts teaching hospitals. Given the clear evidence that imposing copayments can lead to delaying accesses to needed services (adding costs longer term), home health must send a message to their Senators and Representative urging them to oppose a home health co-pays in deficit reduction negotiations.
Given that these decisions may be made as early as next week, we are asking that you contact our federal officials, especially Senators Kerry and Brown today.
You may send a message using the NAHC Legislative Action Network (NAHC LAN). To oppose home health co-pays and payment cuts, click here. The sample messages found on the NAHC LAN should be personalized to provide members of Congress with your background and the potential impact payment cuts and co-pays would have on senior and disabled Medicare beneficiaries and their families in your state and district.
We suggest also weighing in by phone. When calling, ask to speak to the staffer who handles Medicare issues. You may obtain contact information for your Senators and Representative here: Contact Your Elected Officials. For a sample phone message, click here.
Return to www.thinkhomecare.org.