Alliance Submits Comments on PPS Rule

The Home Care Alliance of MA today submitted comments to CMS on the proposed rule setting Medicare home health rates for 2014. CMS has proposed cutting rates by 3.5% for each of the next four years.

Citing data concerns, inadequate allowances for increasing regulatory costs and operating margins, inequities in the proposed wage index, and an incomplete analysis of the impact on both agencies and Medicare patients of CMS’s proposal to cut rates for each of the next four years, the Alliance urges CMS to go back to the drawing board on 2014 rates.

The Alliance’s comments are available here.

Comments to CMS on the proposed rule are due TODAY at 5:00 p.m., and can be submitted online at  Enter “RIN 0938-AR52” in the search box to find the proposed rule.

Join Us For NEHCC 2014 At The Boston Park Plaza

The New England Home Care Conference & Trade Show is pleased to officially announce its 2014 venue and dates:

Park Plaza Lobby
Credit: Boston Park Plaza Hotel

May 28 – May 30, 2014
Boston Park Plaza Hotel
50 Park Plaza at Arlington Street
Boston, MA 02116

Considered one of Boston’s finest hotels since it opened its doors in 1927, The Park Plaza features 8 on-site restaurants, a state of the art Fitness Center, Business Center, and full Concierge Service.  It’s located in Boston’s historic Back Bay, just across the Street from the Public Gardens and Common.

To save the date to your calendar, just click here.

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Home Health Data on PatientCareLink Updated

Updated Home Health Compare data has been posted to the PatientCareLink website. Home Health Compare data allows consumers to compare the quality outcomes of Medicare-certified home health care agencies on a variety of standardized quality measures. See how the agencies in your area compare to other agencies and to national average scores.

Comments Due on Home Health 2014 Payment Rule

The Home Care Alliance is in the process of preparing comments on the June 27, 2013 Centers for Medicare and Medicaid Services (CMS) proposed rule that sets out the proposed rates for home health services in 2014. The proposed changes for 2014 include the first of a planned four year “rebasing” of home health rates.

By way of background:  The requirement that rates be rebased in 2014 and phased-in proportionately over a four year period was included in Patient Protection and Affordable Care Act of 2010 (PPACA). The language reflects a MedPAC recommendation that rebasing is needed due to significant changes in services provided during the 60 episode of care,  along with what MEDPAC believes to be “overpayments” for services,  evidenced by profit margin calculations. The average episode of care in the base year used for rate setting involved 37 visits primarily made up of nursing and aide services.  The current care utilization in an episode is less than 20 visits with few aide services and significantly more therapy visits. . From 2001 through 2011, MedPAC’s calculation of Medicare profit margin shows freestanding HHAs with an average ranging from 16-18%.  For purposes of rebasing, the CMS profit margin calculation is 14%.

The proposed rated for 2014 reflect a 2.4% Market Basket Index adjustment to reflect estimate costs increases in 2014.  CMS also proposes a total rebasing payment reduction of 14 percent, or the maximum cap of a 3.5% payment reduction for each year, over the next four years.   CMS estimates that the overall impact of the proposed rate rebasing and other rate changes is a reduction in Medicare spending of $290 million in 2014.

The Alliance’s comments will reflect concerns that:

  • the methodology utilized by CMS to calculate home health margins is  flawed in that it excluded hospital based cost report and does not include critical factors such as the impact of the recent sequestration cuts
  • the analysis in the rule is a one year impact assessment rather that the full four years of the rebasing action and is national in scope, ignoring regional and state impacts
  • is based on average national costs.  Other methodologies produce very different results.   For example, NAHC’s calculation is that using the median would produce a per episode cost $113.98 higher than the CMS proxy estimated

The Alliance welcomes member input on the local impact of these changes and also encourages members to submit their own comments with the local impact. (Send to Tim Burgers,    Comments will be accepted by CMS through 5pm on Monday August 26th.  Instructions on Electronic comments on this regulation can be found at: The regulation in its entirety is here.

NHIC- Ask the Contractor- August 15th

The Medicare Administrative Contractor, NHIC. Corp., will hold the Hospice & Home Health Ask the Contractor Teleconference (ACT) on August 15th at 10:00 a.m

Ask-the-Contractor Teleconference is an opportunity to speak directly with the contractor. NHIC staff representing a variety of functions will be available to answer questions. NHIC usually will provide some updates to the home health and hospice community but the majority of this call is dedicated to providers as a question and answer open forum.

Registration is required on NHIC’s website- Education Programs.

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Deadline is TODAY for Congressional Signatures on Face-to-Face Letter

The deadline for a Congressional letter that seeks to streamline the burdensome Medicare home health face-to-face (F2F) requirement is today. New York Congressmen Tom Reed and Paul Tonko, as well as New Jersey Congressmen Christopher Smith and Robert Andrews, are circulating the letter and we need your help in cultivating Massachusetts Congressional support.   Please act now!

Use these talking points and call your legislator’s office and ask to speak to the healthcare staffer TODAY. Phone numbers for each office are listed below and if you’re unsure which member of Congress represents you, please contact James Fuccione at the Alliance.

Massachusetts federal delegation phone numbers:

Senator Elizabeth Warren:     (202) 224-4543
Senator Edward Markey:     (202) 224-2742
Congressman Jim McGovern:     (202) 225-6101
Congresswoman Niki Tsongas:     (202) 225-3411
Congressman Joe Kennedy:     (202) 225-5931
Congressman John Tierney:     (202) 225-8020
Congressman Stephen Lynch:     (202) 225-8273
Congressman Richard Neal:     (202) 225-5601
Congressman Michael Capuano:     (202) 225-5111
Congressman Bill Keating:     (202) 225-3111

The Congressional letter is addressed to U.S. Centers for Medicare and Medicaid Services (CMS) Administrator Marilyn Tavenner. Referring to the F2F mandate, the letter describes the “complicated, confusing and overlapping documentation requirements that exceed the intent of the law passed by Congress,” and it urges CMS to allow the F2F requirement to be met through the completion and collection of the separately signed 485 form.  Such a change would significantly ease the burden of the F2F mandate.

Almost 40 state home care associations (including the Alliance) are already listed in support of the letter, but in order to have the strongest impact with CMS, we need resounding support from as many Members of Congress as cosigners to this letter.

Agency members with any questions can contact James Fuccione at the Alliance.

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Home Health and Hospice ODF- August 7th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, August 7, 2013 at 2:00 PM  (ET).

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 14952615.

 Proposed Agenda

1. Opening Remarks

2. Announcements & Updates

  • Marketplace Websites Re-Launch



  • FY 2014 Hospice Wage Index and Payment Rate Update
  • Upgrade
  • Status Update on Home Health Advance Beneficiary Notice – Caroline Baker



  • DME Cert Task Force

3. Open Q&A


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