CMS Reveals Proposed Rule with Further Cuts to Home Health Care

After Medicare payment cuts to home health agencies amounting to an estimated $72.5 billion over a 10-year period, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule on the Home Health Prospective Payment System with further cuts reducing payments by $290 million.

CMS announced the rule in a press release, which estimates that approximately 3.5 million beneficiaries received home health services from nearly 12,000 home health agencies, costing Medicare approximately $18.2 billion in 2012.

The release continues that the proposed decreases reflect the effects of the 2.4 percent home health payment update percentage ($460 million increase), the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, and the non-routine medical supplies (NRS) conversion factor ($650 million decrease), and the effects of ICD-9-CM coding adjustments ($100 million decrease). In addition, the rule proposes routine updates to the HH PPS payment rates such as updating the payment rates by the HH PPS payment update percentage and updating the home health wage index for 2014.

The CMS proposal is based on a projected 2013 differential between cost and revenue (margins) of 13.63 percent, which is at “severe odds” with calculations by the National Association for Home Care & Hospice (NAHC) and MedPAC.

Using a larger database than employed by CMS, NAHC estimates the 2013 margin at 8 percent to 9 percent. NAHC is seeking clarifications and a full disclosure of its calculation data and methodology. At this point, NAHC believes that the proposal is based on an unsupportable calculation.

“The proposal places the 3.5 million Medicare beneficiaries receiving home care services at risk of losing access to care as nearly half of the providers of this vital service would be paid less than the cost of care. It is neither fair nor right and needs to be changed,” stated Val J. Halamandaris, president of NAHC.

The Home Care Alliance is working with NAHC and other organizations to analyze the full extent of the proposed rule and advocate against these additional cuts.

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Alliance Leadership Elected

The results of the 2013 election of officers and Board members for the Home Care Alliance of Massachusetts were announced at the Annual Meeting on June 21, 2013, at All Care VNA & Hospice, Lynn.

The following individuals were elected to officer positions:

  • President:  Beverly Pavasaris, President, Brockton VNA, Brockton
  • Vice President:  Jeanne Ryan, Executive Director, VNA & Hospice of Cooley-Dickinson, Northampton
  • Secretary:  Wayne A. Regan, Senior Vice President, MetroWest HomeCare & Hospice, Framingham
  • Elected to two-year terms on the Board of Directors:
  • Jann Ahern, Executive Director, South Shore VNA, Rockland
  • Maureen Bannan, Executive Director, Walpole Area VNA, Walpole
  • Holly Chaffee, CEO, Porchlight VNA, Lee
  • Theresa Larson, Regional Home Care Director, The Essex Group, South Dartmouth
  • Laurie Rubin, President, QualityWORKS, Holliston
  • Kathleen M. Trier, Executive Director and CEO, Community VNA, Attleboro

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Today’s ODF Cancelled

Centers for Medicare and Medicaid (CMS) sent notice yesterday that due to unforeseen circumstances, the June 26, 2013 Home Health, Hospice and DME Open Door Forum (ODF) is postponed until July 9, 2013. A separate notification with a full announcement and agenda will be sent prior to the July 9th call.

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OASIS-C1 is Here!

CMS has issued a Notice in the June 21st Federal Register announcing the proposed version of the OASIS–C1.  This draft of OASIS C-1 has 110 items and reflects changes to accommodate the need to enable the coding of diagnoses using the ICD-10-CM coding set which goes into effect October 1, 2014. The draft also reflects changes to address issues raised by stakeholders, such as updating clinical concepts and modifying item wording and response categories to improve item clarity; and to reduce burden associated with OASIS data collection by removing items not currently used by CMS for payment, quality, or risk adjustment. The draft also adds one new item M1011 (Inpatient diagnosis) at Recertification/Follow-up for the purposes of potential case-mix adjustment.

Comments on the draft OASIS-C1 must be received by August 20, 2013. When commenting,  reference the document identifier or OMB control number (OCN). To be assured consideration, comments and recommendations must be submitted in any one of the following ways:

  1. Electronically.

You may send your comments electronically to Follow the instructions for ‘‘Comment or Submission’’ or ‘‘More Search Options’’ to find the information collection document(s) that are accepting comments.

  1. By regular mail.

You may mail written comments to the following address:

CMS, Office of Strategic Operations and Regulatory Affairs,

Division of Regulations Development,

Attention: Document Identifier/OMB Control Number__ Room C4–26–05,

7500 Security Boulevard, Baltimore,

Maryland 21244–1850.

The revised instrument, a table that compares the OASIS-C (Current Version) to the OASIS-C1 (Proposed Data Collection), and the supporting documentation can be found on CMS Paperwork Reduction Act (PRA) listing page, click here and scroll to CMS-R-245.

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President’s Remarks at Annual Meeting 2013

The following are the remarks of Home Care Alliance President Beverly Pavasaris to the members at the 2013 Annual Meeting.

medicare discharges
Discharge Disposition, Massachusetts Medicare Beneficiaries, 2012

Welcome to the 2012/13 Annual Meeting.  It’s both a pleasure and an honor to be serving in a second year as Alliance President .  This year I am pleased to say we had tremendous interest  from the membership  in serving on the Board.  I am delighted to welcome our new Board members,  all of whom are already leaders in their own organizations and anyone of whom could be prepared to take the helm of the Alliance if asked.  I also extend my thanks to those Board members who will be continuing on for another year, your advice and counsel have been welcome. And,  I would like to recognize Joanne Kramer, VNA Care Network; Kathleen McDonough, Community Health Network and Bob Tonti, VNS of Marthas Vineyard, who are leaving the Board. Thank you for your service.

As we end one Alliance fiscal year and embark on another, let me just give you a few  facts and figures on home care today in Mass.  Firs, on the Home Care Alliance:

We have 208 Agency, 54 Allied and 12 individual members

The average size of non-certified member agency:  $1.4m

The average size of certified member agency:  $8.8m

The increase in Alliance total dues , FY09 – FY12:   25%

Total revenue of members:  Has  now passed one billion dollars!

*         $895million (certified)

*         $155 million (non certified)

Just a few facts on the non-certified home care business.    These come from a survey that we co-marketed with the Home Care Association of America.  The first slide shows our state’s average per hourly billing rates compared to national northeast and industry leaders.  No surprise we are slightly higher .

The next shows our turnover rates, which to our credit are remarkably lower.  I am not sure if these two are linked but certainly the fact that turnover rates that are almost 20% lower than the  national are a credit to us as employers and a benefit to our patients.

Just a few facts on the Medicare certified business. This chart, which is Medicare data based,  shows that  almost 25% of Medicare beneficiaries leaving hospital are referred for home health services.  This number, to our credit , is almost 8% higher than the national average of just under 17%.  By the way, this also means  in our state that we have far fewer people who are reported going home with no services.  The national number according to Masspro Medicare data is 51%

This second to last slide just gives you a different look at some similar data that show that per capita use of home health in Mass is higher than the national average – and the highest by the way, in New England .. The closest to us   is Connecticut where the use per 1000 beneficiaries is 109.  The highest per capita usage –is 144, which no surprise is the number for Florida, TX and LA.

My final slide comes from a home care chart book that a subcommittee of our Board has been working on with some facts and examples about how home health delivers value in health care today.  This slide set will soon be posted to our website for all members to download and adapt as they would like.  I hope that you will find it useful.

Again thank you all for joining us here today and for standing up for home care by being active members in the Home Care Alliance.  As always, I and the other Board members welcome your feedback.

CMS Competitive Bidding Program Starts July 1st

Starting on July 1, 2013, Medicare is scheduled to expand the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program to some areas in Massachusetts (Boston-Cambridge-Fall River-New Bedford- Quincy- Springfield-Worcester)  This program changes the amount Medicare pays for certain DMEPOS, and makes changes to which suppliers Medicare will pay to supply these items to Medicare beneficiaries.

To find out if a supplier is a contract supplier for the program check on the CMS DMEPOS Competitive Bidding Website for the “Supplier Directory” or by calling 1-800-MEDICARE (1-800-633-4227).

The eight product categories that are included in this program are:

1. Oxygen, oxygen equipment, and supplies;

2. Standard (power and manual) wheelchairs, scooters, and related accessories;

3. Enteral nutrients, equipment, and supplies;

4. Continuous Positive Airway Pressure (CPAP) devices, Respiratory Assist Devices (RADs) and related supplies and    accessories;

5. Hospital beds and related accessories;

6. Walkers and related accessories;

7. Support surfaces (Group 2 mattresses and overlays); and

8. Negative Pressure Wound Therapy pumps and related supplies and accessories.


For more information, CMS also published a Tip Sheet What You Should Know if You Need Medicare-covered Equipment or Supplies”

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