Author: James Fuccione

Revised Publication Available for Reporting Fraudulent Home Care Referral Practices

In an effort to help home health agencies educate their partners in the provider community about lawful referral practices, the Home Care Alliance has revised and updated the first in a publication series called “Keeping It Legal.”

The document below is intended for distribution to hospitals, physicians, skilled nursing facilities and other sources that refer patients for Medicare-certified home health services. The Alliance has updated contact information for oversight entities so that providers, patients or the families of patients can accurately report fraudulent activity if they wish to do so. The document also lays out some of the basic examples of wrongful activity that should be reported.

With the help of HCA members and those they work with and work for, the Alliance hopes that this document will be passed along and posted prominently in an effort to promote home health services that are high-quality and ethical.

 

Return to www.thinkhomecare.org.

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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State Seeks Waiver from Three-Day Rule

With the input of several health care provider groups, including the Home Care Alliance, the state sent a letter on July 23rd to CMS Administrator Marilyn Tavenner officially requesting a waiver from the so-called “three-day rule.”

The rule refers to Medicare’s requirement that post-hospital extended care services in a skilled nursing facility are not allowed unless they are preceded by a hospital inpatient stay lasting three consecutive days. The Home Care Alliance joined other groups like Mass. Hospital Association, Mass. Senior Care Association, Mass. Medical Society and others in voicing support for such a waiver in multiple stakeholder meetings.

The idea is that patients can be properly directed to skilled nursing facility care and/or home health services, but eventually and ideally transitioning back into the community. All the while, patients would receive an appropriate level of care and avoid unnecessary hospitalizations.

The state’s Executive Office of Health and Human Services asks that the waiver include Medicare Fee-for-Service patients and last for three to five years.

The Home Care Alliance will continue to monitor the state’s request and provide updates.

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Proposed PPS Rule for Home Care and a Call to Action

In the July 3rd Federal Register, The Centers for Medicare and Medicaid Services (CMS) released the proposed Medicare Home Health Rule for 2014.  A key provision of this rule is the first year of a multi-year planned adjustment of home health prospective payment rates, otherwise known as “rebasing”.

The directive to rebase the home health PPS rates comes from language in the Affordable Care of 2010 that was a reaction to multiple years of MEDPAC Reports to Congress calling for dramatic steps to reform the home health payment system, which they claim have widely exceeded  program costs almost from the 2001 launch of the current PPS system.

Starting with 2014 rule and going forward through 2017, CMS plans to impose a 3.5% rebasing adjustment to the home health base rate.  This 3.5% reduction is based on CMS’ projection of an average home health profit margin of 13.63% in 2013 (calculated from 2011 data trended forward as the difference between the average national episode revenue in home health and the average national episode cost). The 2014 rule does include a 2.4% market basket update as well.

The phase-in of this rebasing cut and the inclusion of a market basket update is in conflict with what MEDPAC had recommended to Congress (no update and deeper and faster rebasing cuts) and is direct result of industry advocacy form these mitigating factors during the ACA debate.

Now, that type of industry advocacy is needed once again.  While eliminating any rebasing cut may well be impossible, it is possible that with strong Congressional support, we can challenge the CMS calculation and achieve some decrease in the 2014 cut.   Particularly subject to challenge is CMS’ calculation of industry profit margins from which the rebasing number are derived.

We also know the following about CMS’ calculations on profit margins:

  • Only freestanding and not hospital base agency cost reports are considered
  • They are at odds with what MEDPAC’s and NAHC’s numbers show
  • They may fail to adequately capture industry costs around mandates such as the Face to Face requirement, the ICD-10 implementation and investments in electronic health records .

The Alliance believes that we can make a strong case to Congress, but we need members to be engaged as advocates and as sources of information for us.

Please use the questions below as a guide to provide information on the anticipated impact of the CMS Proposed Rule by Friday, July 26th at 12pm. Alliance staff is traveling to Washington DC to meet with members of congress and the national associations, so please have information in ASAP:

  • What is the impact on your agency’s bottom line (in dollar amount and percent loss)?
  • What is the impact on staff, including reducing staff time, cutting jobs, or halting new hires?
  • Do you anticipate cutting or reducing service lines, particularly MassHealth/Medicaid?
  • What is the impact on innovative service lines, like hospital readmission, dementia, chronic disease management, falls prevention and etc?
  • How will the proposed rule affect other ways your agency does business?

Answers to the above can be emailed to James Fuccione at the Alliance

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New Web Resource on Hospital Quality Adds Home Health Data

A collaborative effort of three leading healthcare trade associations has brought a new, first-in-the-nation website for consumers to find quality data on the state’s hospitals and, more recently, federally-certified home health agencies.

The Massachusetts Hospital Association, the Home Care Alliance of Massachusetts and the Organization on Nurse Leaders of Massachusetts and Rhode Island have teamed up to build the website called PatientCareLink. The site aims to deliver transparent quality and safety information from hospitals and home care agencies to patients and other healthcare stakeholders.

The data itself is drawn directly from the Medicare Home Health Compare website and is updated regularly. An alphabetical list of agencies is presented and each agency has their contact information and website included with selected quality measures that are compared to the national average for home health agencies.

The Alliance invites all to browse through the website, which will be continually promoted and improved, and see the website’s introductory video above with HCA’s Executive Director Patricia Kelleher.

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Budget Passes With Telehealth, Pediatric Palliative Care Funding

After years of advocacy and passing budget items with weak language that did not compel MassHealth to act, the Governor signed off on the $33.6 billion FY2014 state budget with a provision that recognizes home telehealth as a reimbursable service.

There is still plenty of work to be done with MassHealth, but passing the telehealth language in the budget is the furthest the Home Care Alliance has gone towards achieving reimbursement for an established service known to create efficiencies, improve care, and reduce costs.

The Alliance will be including a push for telehealth in comments on the state’s proposed home health regulation changes. Any agencies or advocates interested in commenting with HCA in an attempt to have the state include telehealth reimbursement in regulation to ensure its permanence should have a letter in to MassHealth by the July 26th deadline. Agencies can contact James Fuccione at the Alliance for details.

Also included in the the final budget is $1.5 million for the Pediatric Palliative Care Network, which serves the unmet physical, emotional, social and spiritual needs of children in Massachusetts with life-limiting illnesses. This is more than $670,000 of additional funding over previous budgets.

The Alliance would like to thank all the agencies and advocates who sent emails, made phone calls, met with legislators and otherwise supported telehealth and the pediatric palliative care funding. These items passing in the final budget represent a huge victory for home care and prove that persistent advocacy pays off.

Return to www.thinkhomecare.org.

Alzheimer’s Association Holding Training for Direct Care Staff

The Massachusetts/New Hampshire Chapter of the Alzheimer’s Association is hosting a series of educational seminars for direct care staff and the Home Care Alliance encourages those interested to participate.

The format is a train the trainer model created to prepare attendees, already familiar with Alzheimer’s and dementia care, to train direct care staff in a wide array of care settings, including home care.

Here are the details:

Caring for People with Alzheimer’s Disease: A Habilitation Training Curriculum Date of next Training:

Tuesday, August 6, 2013

Alzheimer’s Association, 480 Pleasant Street, Watertown, MA 02472

The curriculum is a train the trainer model created to prepare attendees, already familiar with Alzheimer’s and dementia care, to train direct care staff in a wide array of care settings. The 7 hour training teaches attendees the 13 hour curriculum in best Habilitation Therapy practices. Modules include a PowerPoint presentation, discussion activities, lecture, and demonstration, role-play and group work. Continue reading “Alzheimer’s Association Holding Training for Direct Care Staff”

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.

Return to www.thinkhomecare.org.

Advocacy Alert: Send a Message to Support Telehealth and Pediatric Palliative Care

The Massachusetts House and Senate have named members of a select “conference committee” that will work to negotiate differences between the House and Senate budgets for a final version to be sent to Governor Patrick.

Please visit the Home Care Alliance’s Legislative Action Center and send a message to the conference committee members to support two important budget amendments. The message will automatically be sent to conference committee members.

The first (Senate Amendment #718) would create MassHealth reimbursement for telehealth services provided by a certified home health agency.  Language was included in previous budgets with weaker language that did not compel MassHealth to act. This year we again seek the inclusion of this cost-saving service with the words “the commonwealth shall recognize telehealth remote patient monitoring provided by home health agencies as a service to clients otherwise reimbursable through Medicaid” as stated in Senate amendment #718.

The second amendment (Senate amendment # 629) would add $674,789 to the state’s pediatric palliative care program, which serves the unmet physical, emotional, social and spiritual needs of children in Massachusetts with life-limiting illnesses.

Since both of these amendments were approved in the Senate budget, but not the House, advocates have to urge that conference committee members support the inclusion of the amendments in their negotiated version. If you live in the area of one of the conference committee members and would like to advocate for these amendments directly, the committee members are listed below with link to their profile pages (including contact info) on the state legislature’s website.

It only takes a minute to send a message and advocate for these important issues!

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RFA Available for ‘Money Follows the Person’ Transition Coordination

The team managing the Money Follows the Person Demonstration released the following announcement regarding RFA’s to provide “transition coordination.” Any agencies interested are encouraged to either apply or at least become familiar with some of the community supports and services involved in the demonstration.

 

The Executive Office of Health and Human Services (EOHHS) has issued an RFA to contract with multiple qualified entities to provide MFP transition coordination to MassHealth Members enrolled in the Money Follows the Person (MFP) Demonstration. MFP transition coordination involves the performance of a broad a range of functions that will assist and enable individuals to transition from a nursing facility, long-stay hospital or intermediate care facility for people with intellectual disabilities to a community-setting with supports and services.

To view this document, please follow the directions below:

  • On the Comm-pass Home Page (http://www.Comm-pass.com), click on the “Solicitations” tab.
  • Click on the tab “Browse all Open Solicitations”.
  • Click on the second bullet “By Entity/Department”.
  • Find the Executive Office of Health and Human Services, and select by clicking on the check box.
  • On the Department page, Executive Office of Health and Human Services should be the only agency listed.  Click on the Select check box.
  • Scroll down to the procurement: 13MEEHSMFPTRANSITION (“Request for Applications for MFP Transitio …”)
  • Click the eyeglass icon on the right.
  • Click on the “Specifications” tab.

 

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