Advocate and Engage on PDGM

There are many ways that home health agencies will need to prepare their agencies for the radical changes coming from PDGM in January 2020. The Alliance is here to help.

Last month, the Centers for Medicare & Medicaid Services (CMS) issued its proposed rule for 2019 home health payment rates and policy changes, which includes significant provisions that will impact your organization, staff, and the patients you serve.

Between now and when the Patient Driven Grouping Model (PDGM) goes into effect on January 1, 2020, there are multiple ways that home health agencies will need to prepare their agencies for the radical change. (See Coding and Billing webinars coming in September, at the bottom of this page) At the same time, home care must take action to mitigate the impact of what PDGM will look like and how it will impact organizational viability.

Home care’s collective advocacy efforts have undeniably made a difference in the past, including putting a stop (at least in Massachusetts) to the Pre-Claim Review Demonstration and scrapping the Home Health Groupings Model thanks to more than 1,200 comments submitted to CMS last year. The more that CMS and lawmakers hear from home health professionals, the better our chances are at reducing the severe cuts that accompany PDGM in its proposed form.

As currently proposed, the 2020 rule will:

  • Reduce the Medicare base rate by 8.01% next year, which amounts to a $1.298 billion reduction in home health payments in 2020 alone. CMS proposes the reduction to account for anticipated changes in provider behavior that are unrelated to changes in patients served or services delivered that increase payments. This newly proposed “behavioral adjustment” reduction is up from the 6.42% reduction that CMS initially proposed, and the reduction would start before any actual behavioral changes occur.
  • Phasing out RAPS over 2020 with total elimination of RAPs in 2021. Next year, CMS proposed reducing RAPs from 60/50% to 20% for existing home health agencies (HHAs), while new agencies would get no RAP. CMS claims that RAPs create fraud risks.
  • Starting in 2021, a Notice of Admission (NOA) must be submitted Notice of Admission must be submitted within five days of the start of care. For every day late, CMS plans to reduce base-rate reimbursements for the unit of care.

The Solution: Pass S.433/H.R.2573

This month, Congress is in recess and back in the states, which presents a pivotal opportunity for home health industry professionals to engage with lawmakers about a key legislative priority – the Home Health Payment Innovation Act (S.433/H.R.2573).

This legislation prohibits CMS’s ability to adjust payment based on “behavioral assumptions” as opposed to observed evidence of behavioral changes, thus rescinding the proposed 8.01% adjustment.
Additionally, this important legislation would:

  1. Achieve full budget neutrality over the period of 2020-2029.
  2. Require behavioral adjustments based on real, actual changes in provider behavior in response to the new payment model.
  3. Permit a phase-in of rate adjustments (up or down) when an annual adjustment would be greater than 2 percent. However, the phase-in would operate to ensure full budget neutrality by 2029.

Email your Members of Congress

It’s not too late to get members of Congress informed and engaged on this important legislation. You can send an email directly from HCA’s member advocacy center.

At this point, Congressman Jim McGovern is the only member of the MA delegation signed on as a cosponsor. We must do better.

Fact Sheet: Senate 433 & HR 2573

Advocate in Person

Join home health industry advocates next month in Washington, D.C. for The Council of State Home Care Associations’ Third Annual Public Policy Summit and Advocacy Day!  On September 9, participate in a full-day summit featuring speakers including Hillary Loeffler, Director of the CMS’ Division of Home Health & Hospice.  On September 10, we be on Capitol Hill meeting with members of Congress to convey the critical need to pass S.433/H.R.2357.

Program details can be found here and registration information can be found at The Council’s website.

Submit Comments to CMS by September 9

Click here to submit comments to CMS in response to the 2020 proposed rule by 5:00 PM ET on Monday, September 9, 2019.

HCA and other industry organizations will provide more thorough comments on other problematic areas of the proposed rule. As previously stated, there is strength in numbers, so the more business-focused comments from providers – both large and small – are critical to giving CMS a full and clear picture of how devastating PDGM will be should it be implemented as proposed. Watch Update for draft comments.

Return to www.thinkhomecare.org.

Patient Legal Advocates

Information for clients/patients needing legal assistance around lost benefits or insurance.

The movement of many insured into “managed” environments has resulted in some questions to the HCA of MA regarding clients’ rights should home care services be terminated or suspended. Every Managed Care Organization (MCO) or Accountable Care Organization (ACO) – be they serving Medicare or Medicaid clients – has an obligation to have some form of patient (although not necessarily agency) internal appeal process. Agencies who are working with these organization should be versed in what these processes are.

For clients for whom the changes are threatening their well being, or seemingly discriminatory, or based on a pattern of inappropriate clinical decision making, there are legal services entities in this state who may be able to help. This list includes their names and contact information. Please note: these legal services entities will generally only take up a case if a client or, in some cases, a family member of a client calls. Keep this information on hand and share with any client who may need assistance.

Return to www.thinkhomecare.org.

Annual Report – Message from our President

Annual Report: Message from the President of HCA of MA

Last month HCA of MA published our Annual Report to members.  Below is the opening message from our President.

To the Members:

“The world is changed by your example, not by your opinion.”

This year HCA of MA is celebrating 50 years as a membership driven trade association advocating with and on behalf of home care agencies, and home care patients.

It is very humbling to be Board Chair during such a milestone year. As many Board chairs before me have done, I have learned from the example set by those that have come before me, that includes both my immediate predecessors, such as Holly Chaffee and Wayne Regan, and those that came before them.  They all instinctively knew that you can’t ask of others what you are unwilling to do yourself and that waiting around for somebody else to do it is a sure way to assure that nobody does it.

As I look back at the year as laid out in this report, I see so much that we can be proud of as a member dedicated organization.  As President for a second term, I will work hard to make sure that continues. As our diverse members – each in their own way – struggles with the human resource, funding, marketing/image and regulatory issues, I want us not to lose site of some very big picture indisputable facts, including:

  • The demographics of our aging population will continue to demand new and more creative approaches to chronic care, serious illness and population health management and home care is the industry to provide these,
  • Home Care is where the professional and paraprofessional health care jobs will be increasingly moving to, and
  • All indications are that patients and families want and are satisfied with the services our member agencies provide.

When we lead by example and build on these certainties, we cannot help but be successful.

Thank you for your confidence.

Maureen Bannan
President

Report on the Massachusetts Serious Illness Coalition

The MA Serious Illness Coalition pushes to bring awareness and focus on end-of-life issues.

“It is my goal that every nursing school in MA embrace that a nursing student must see a dying patient with the same fervor that they embrace that every nurse must see a baby being born.”
— Susan Lysaght Hurley, PhD, RN
Director of Research, Care Dimensions, Inc

Last week, the Massachusetts Serious Illness Coalition hosted its annual meeting welcoming more than 100 attendees to the JFK Library in Boston. The message from the Coalition’s leadership – as articulated by Blue Cross Blue Shield MA President and CEO – is that “the momentum is building.” From the Coalition’s beginnings less than five years ago, Dreyfus has focused on a long-term strategy to achieve the Coalition’s six goals. These include the ideas that everyone in Massachusetts 18 years or older has a designated health care decision-maker and that all Massachusetts clinicians have appropriate training to communicate comfortably with patients around advanced care planning and serious illness. Dreyfus has likened the work to that done in years past on smoking and on car seats, where steady force and public messaging achieved near-universal changes in public thinking.

The progress on clinician education – from a provider association perspective – is perhaps the most engaging and encouraging news. Dr Atul Gwande, as eloquent as ever, declared that the work to date has shown that: “People have priorities in life beyond just surviving, but you must ask them. Suffering happens when care doesn’t match our priorities.”

In addition to a public education campaign about engaging in advanced care planning conversations, Dr. Gwande announced that the Coalition is in talks with all four Massachusetts medical schools about a cooperative effort to require training of med students in serious illness communication as a graduation requirement.

But it was Dr, Hurley’s remarks that struck home for the home health and hospice agencies in the Coalition. In addition to the above comment, Dr. Hurley spoke of being a young nurse “totally unprepared as to how to talk to the dying.” Along with her subcommittee co-chair Anne Marie Barron of Simmons College, she is working on recommendations on core competencies for nursing education related to serious illness care. These are to be presented in the near future to the Massachusetts Association of Colleges of Nursing. What a great achievement that would be!

For those following the Coalition’s work, these may also be of interest:

  1. End Games, an Academy Award-nominated short documentary on hospice and palliative care executive produced by Shoshana Ungerleider, MD. It premiered at Sundance Film Festival in 2018 and was acquired by Netflix.

2. The Coalition’s public message research and draft public facing marketing approaches.

Commendable progress!

Return to www.thinkhomecare.org.

Get “Woke” on Sepsis

Several new resources are available to members to help them combat one of the most dangerous health conditions in the Commonwealth: Sepsis.

Massachusetts Sepsis ConsortiumSepsis: A public health challenge of enormous proportions, a top driver of health care costs, and a condition that kills more people each year than cancer. But when recognized and treated swiftly, sepsis can be stopped before it causes significant health damage.

The statistics are sobering: Approximately 42,000 Massachusetts residents are diagnosed with sepsis every year and an estimated 5,000-7,000 of them die from the condition. Sepsis is consistently among the top causes for 30-day hospital re-admissions in all regions of Massachusetts and is the third-leading cause of hospital inpatient deaths in the state. And yet, Massachusetts is only a middling performer on sepsis indicators, ranked 25th in mortality in 2017 and at the national average in providing timely care for patients with sepsis.

Providers and policy makers have come together as the Massachusetts Sepsis Coalition – under the umbrella of the Betsey Lehman Center for Patient Safety – to bring more resources to bear in terms of understanding, identifying, and treating sepsis. The Coalition’s initial task force assessed the current state of sepsis response in hospital emergency departments and just recently released their extensive report, with recommendations.

Because 80% of sepsis cases are thought to originate outside the hospital, the home care community is beginning to examine our own understanding of, and training around, sepsis identification. A year or so ago, the Home Care Association of New York State developed their “Stop Sepsis at Home” campaign and tool kit. The Home Care Alliance of MA presented this to our members on several occasions, including at last year’s annual Spring Conference and Trade show.

On May 14th, 2019, the Alliance will host – along with Healthcentric Advisors – a free Train the Trainer session on Sepsis Awareness in the home setting. All members are encouraged to send someone. Agencies who cannot attend can find sepsis resources below.

Return to www.thinkhomecare.org.

Home Health, EHRs and Data Interoperability

In 2011, the Centers for Medicare and Medicaid Services launched the “Meaningful Use (MU) initiative to incentivize certain sectors in the US health care system to move toward electronic health records (EHR) that would be used in a meaningful manner that allows for the electronic exchange of information to improve continuity and quality of care. Significant financial incentives were provided to “eligible providers” – essentially defined as hospitals and physician practices. More than $20 billion was spent and more that 600,000 eligible providers were enrolled. Home health, behavioral health and skilled nursing facilities were not eligible.

Now, it seems there is some limited acknowledgement that it may be time to rethink that. In a proposed rule relative to interoperability just published in the Federal Register, CMS is including – as a Request for Information – an ask for any feedback as to how to improve data interoperability for providers that have as yet received any incentives for using electronic health records.

“Transitions across care settings have been characterized as common, complicated, costly, and potentially hazardous for individuals with complex health needs. Yet despite the need for functionality to support better care coordination, discharge planning, and timely transfer of essential health information, interoperability by certain health care providers such as long term and PAC, behavioral health, and home and community-based services continues to lag behind acute care providers,” the proposed rule says.

CMS acknowledges that a contributing factor to the lag in Interoperability among post-acute care providers was that they were not eligible for incentives under the program formally known as meaningful use. CMS asks for input on specific ways it could financially help these sectors adopt and use technology.

CMS also asks for feedback on measurement concepts and quality improvement steps that could feasibly be applied to post-acute care, behavioral health and home and community based-services providers. Given that mandate in the IMPACT ACT that certain patient assessment data should be standardized and CMS is interested in feedback as to what parts of that data set — or the whole IMPACT Act data set — would be appropriate to include.

Adding some fuel to what may be an obvious fire (no incentive = limited movement) is a just published study in the Journal of the American Medical Directors Association that examined gaps in communication between hospital and home health care staff, concluding that some could have serious medical consequences.

The authors surveyed nurses and staff at 56 home health agencies throughout Colorado. Participants were sent a 48-question survey covering communication between hospitals and agencies, patient safety, pending tests, medication schedules, clinician contact and other areas. Although almost all (96 percent) respondents indicated that Internet-based access to a patient’s hospital record would be at least somewhat useful, fewer than half reported having access to EHRs for referring hospitals or clinics. No surprise: getting medication doses right due to conflicting information was identified as a major problem.

Their conclusion: Future interventions to improve communication between the hospital and HHC should aim to improve preparation of patients and caregivers to ensure they know what to expect from HHC and to provide access to EHR information for HHC agencies.

Comments to CMS will be due in April. Date not yet announced.

Return to www.thinkhomecare.org.

How CMS Stole Home Care Christmas!

Every person in Home Care liked caring a lot.
But the Grinches south of Baltimore, they surely did not!
The Grinches hated home care, delivered in any which way.
Now, please don’t ask why. No one knows what to say.

It could be CMS didn’t have a mom or a dad.
It could be their jobs were incredibly sad.
But, the most likely reason was this just this my dear,
Their hearts were hijacked by nasty old fear.

They feared the support, the need and the caring.
“It has to stop now,” they said, nostrils flaring!
“I hate all their teamwork! I despise all they do!
I’ll pick them all off, one-by-one, two-by-two!”

With a laugh and snort, they sneered, “I know just what to do!”
And put pen to paper to plot their evil, awful coup.
They threw it all at us, with the usual glee,
COPs, OASIS changes, and even VBP!
“I’ve ruined them now and forever, I swear,
Let’s see how you cope, how you can possibly still care!”

But across the Land of Home Care, they got down to work.
HCA had their back, a membership perk!
Every worker in home care, the small and the tall,
Still kept making visits, swearing once and for all:
“The families, they need us, and we will be there!
No Grinches in DC can stop us with fear.”

And what happened then? Well… in home they say,
Those Grinches’ hearts grew three sizes that day!
The true meaning of home care shined right on through.
They ripped up their papers, stopped pre-claim review.
“Maybe home care,” they said, “isn’t about regs, or rules.
Maybe home care is bigger, a national jewel!”

“Thank you, home care,” they said, now with a smile.
“For once, in your shoes, maybe I’ll walk a mile.
I’ll make a home visit, I’ll assist with a med.
I’ll listen to stories from clients in bed.”

“I’ve a new understanding why you do what you do.
Let’s make a new year that’s bright with a start that’s brand new!”

Return to www.thinkhomecare.org.