Secretary Bigby Addresses Alliance Annual Meeting

Massachusetts Secretary Judy Ann Bigby reviewed the Patrick Administration’s plans for reform of the health care delivery system in Massachusetts.  In her remarks, Secretary Bigby was clear that just as was the case with universal access, Massachusetts may well move before most other states or the federal government on issues such as global payment and integrated care organizations.  Secretary Bigby was clear that the building blocks for the ICOs – as she called then – would be primary care advanced medical home practices.  “I see a strong role for home based care in areas such as complex care management,” she said.  “Working out your role directly with doctors will be key.”

The state currently has out a Request for Information on the formation of ICOs/ACOs  – comments are due by July 13th.   At the meeting Secretary Bigby indicated an interest in ideas as to how the state policy makers  could support a role for high quality,  cost effective home care in redesigned systems. Among the ideas put forth at the meeting:  test episodic – rather than fee for service –  payment  for MassHealth home health care and do some modeling of what a home -based chronic care bundled payment would like.

Do you have ideas for Secretary Bigby – related to home care under health care reform?  Send them along for inclusion in either the Alliance’s ACO comments or in Annual Meeting follow-up with the Secretary.

Please Circulate Physician Survey on Face to Face Requirement

The National Association for Home Care and Hospice is seeking help from home health agencies in getting physicians to complete a very important short survey that will help inform federal government policymakers about important issues related to CMS’ face-to-face encounter requirement. NAHC is meeting with CMS leadership in the coming weeks to discuss the impact of the face-to-face requirement, and in order to effectively stress the home care industry’s position on this issue, they need substantive data from physicians. P

The 10-question survey is only for physicians and will take less than 5 minutes of a physician’s time to complete. The deadline to submit the survey is Friday, June 24 at the close of business!  To ensure the accuracy and confidentiality of this survey, NAHC has partnered with an independent research company which will collect all responses and keep them completely anonymous. It is very important for the credibility of this survey that physicians be informed that the benefit to them for participating in this survey is to make sure their opinion is heard, whatever that opinion may be.

Click here to download the survey information for physicians.

Click here to down load a page explaining the survey in more detail.

The Case Against a Medicare Home Health Copayment

At our recent meeting with representatives from our state’s  Congressional delegation, Rey Spadoni, President/CEO of the VNA of Boston made some important remarks on the perils presented to home care patients should the MEDPAC proposal – presented to Congress in March –  for a per episode copayment to be enacted on home health services.  Calling copayments “short-sighted” and “ineffective,  Rey has this to say about the reaction from his staff in the field:

When our nurses, who care for patients in the poorest neighborhoods of Boston, hear about this suggestion… they roll their eyes and tell us that most… most… of their patients will not pay them. They will prioritize paying for their prescriptions, their rent and food before they will pay for home care services. For most of our patients, age 80 and above, they are already spending 30% of their limited incomes on uncovered medical care.

The battle to stop a home care copayment  has been successfully fought by this industry before. But this year, it feels a little different. MEDPAC’s copayment call has been embraced by the Congressional Budget Office; and with talk of major Medicare reform on at least the Tea Party’s agenda, copayments in the name of more “personal responsibility” for health care purchasing may have a new and receptive audience.

Although the President resisted the recommendation in his budget proposal, it is clear that this possible wave of change will need “all hands on deck” to stop.

Return to www.thinkhomecare.org.

Privatize Medicare – On the Agenda in Congress

The House Republicans are putting forward a plan, drafted by Representative Paul Ryan, chairman of the House Budget Committee, to cut federal spending by $4 trillion over the next decade.

Central to that plan is a proposal to end traditional Medicare.  It would turn Medicare for those currently under 55 into a “premium support”  plan where beneficiaries would choose a private insurer and the government would provide vouchers to pay the premiums, about $15,000 a year, with bigger higher support for those who are poorer or sicker.

Writing on the New York Times “Room for Debate” blog, Princeton professor  Paul Starr says: “Privatizing Medicare would enable the federal government to wash its hands of all the vexations of health-care cost containment and leave the elderly to deal with those vexations on their own.”

The competing opinion is offered by James Capretta, a former associate director of the US Office of Management and Budget who sees vouchers as a positive step toward giving beneficiaries  “more control” over what they get:  “The key is that the government’s contribution is set independently of the choice made by any one beneficiary. If Medicare participants choose a somewhat more expensive option, they will pay higher premiums. If they choose less expensive options, perhaps through a more efficient delivery system, they will pay less.”

Is the public or the Congress ready for such a radical step? Would it hold down costs?  Or move Medicare from ” one size fits all” to a system of “haves” and “have nots,”  in which some can only afford a less generous plan?

This is a discussion we all – as providers and citizens – have a stake in.

Lobbying Congress and/or Lobbying CMS?

Next week, Home Care Alliance members will be in Washington DC to make sure that our elected federal officials understand the role of home care in the health care delivery system and the strain on services being imposed by new federal rules, such as the face to face requirement.  We will also be seeking their help in carrying our message to those unelected federal officials who run the Medicare program for the Congress and the American people: the Centers for Medicare and Medicaid. With both enormous responsibility and authority, this federal agency can hugely influence who gets and who provides health care.

In advance of our meetings, the Home Care Alliance sent a letter to United States Secretary of Health and Human Services Kathleen Sibelius asking that she use her recently granted authority to at least temporary impose a “cooling off” period for new home health agencies in our states.   Included in the letter was the following:

  • ” CMS has sufficient data to indicate that rapid increases in the number of home health
    agencies has led to increases in utilization and spending beyond that which would be
    indicated by payment changes, growth in enrollees, or policy actions. The National
    Association for Home Care and Hospice collected data indicating that from 2001-2006,
    Medicare spending grew 2.5 times more in states where the number of home health
    agencies (HHA’s) increased as compared to states where the number of providers
    remained the same or decreased.
  • The proposed rules suggest that determining factors for moratoria include a trend of
    growth that is disproportionate relative to the number of beneficiaries or a rapid uptick
    in enrollment applications. The recent situation in Massachusetts satisfies both of those
    requirements. After virtually no growth between 2001 and 2006, our state has seen an
    increase of 27 certified agencies in the past four years – an increase of more than 20
    percent. This has occurred despite the fact that no area of the state is un-served or
    underserved.
  • This recent growth is driven by that fact that Massachusetts is one of only a few states
    that has neither state licensure nor certificate of need rules for new home health care.
    This ability to “take all comers” was further exacerbated by a CMS decision a few years
    ago to allow state Survey agencies to transfer their responsibilities for new Medicare
    home health certification to private accreditation agencies. Our experience is that these
    private surveys are less rigorous and that it has become much too easy for new agencies
    to become established without a full understanding of the complexity of Medicare
    compliance. In fact, we believe that several agencies received Medicare deemed status
    in the past five years have either been decertified or in danger of being decertified once
    the state makes an initial survey. All of this adds costs and no value to our system.”

Our agenda also includes – thanks to one of our most responsive elected officials Congressman Jim McGovern – a meeting to try to bring some reasonableness to the federal/state “TPL” fight over paying for home care.

Please continue to share your thoughts on both our current industry challenges and what you see as needed fixes.  When we are in DC, we are speaking for you.

 

 

Metrowest Home Care & Hospice Honored for Their Work

Congratulations go out to MetroWest Medical Center which, in collaboration with MetroWest HomeCare & Hospice, has been awarded the 2010 Betsy Lehman Patient Safety Recognition Award. The award honors leadership and innovation in patient safety and the development of systems-based solutions through the implementation of best practices. The theme for this year’s award focused on the importance of transitions in care across the healthcare continuum.  Jane PikeBenton, Executive Director at MetroWest HomeCare & Hospice, presented their innovative approach at the most recent statewide STAAR Learning Session and sent this along to the Home Care Alliance:

“ At Metro-West, we implemented a multi-faceted approach to the transitioning of patients that was designed and implemented via a strong cross-continuum collaboration between the home health agency and the hospital. The model includes:

  • the implementation of a ‘teach back tool’ for patients with heart failure both within the hospital and through their transition to home with home care services
  • the development of a standardized Heart Failure Protocol with front loading of home care visits, the use of a standardized teaching tool based upon evidenced-based research, an increase focus on medications, and the integration of phone calls by the home care case managers on non visit days
  • post hospital telephonic support via the use of a calling center in conjunction with the MetroWest HomeCare Nurse Specialist intervening for these patients when gaps in care are identified
  • the implementation of a Transition Care Coach who is also a MetroWest HomeCare Nurse who meets with the patients bedside prior to discharge from the hospital
  • the implementation of a Palliative Care Team with members from both MetroWest Hospice and MetroWest Medical Center

These initiatives demonstrate the importance of cross-continuum collaboration to our patients and to our health care system. Our entire team is committed to implementing new and innovative ways to provide care for our highest risk patients, and to demonstrate the value that home health care offers to hospitals and other health care partners.”

Among those sending congratulations to MetroWest HomeCare & Hospice and MetroWest Medical Center on their innovative approach to patient care across the continuum was HHS Secretary Judy Ann Bigby, MD.  Her comments as to MetroWest as a “shining example” were posted on the Commonwealth Conversations Public Health Blog.

Thank you to Jane and her team for demonstrating leadership in this crucial area of care transitions and readmission reduction.

Study Looks at Home Care to Nursing Home in Mass

The Gerontology Institute at the University of Massachusetts/Boston this month released a study on Massachusetts’ Home Care Programs and Reasons for Discharge into Nursing Homes. The study, which was partially funded by Mass Home Care, looked at a program snap shot for March 2010, at which time there were 32,417 clients enrolled in the Home Care Basic program, 5,221 clients in Choices, and 4,563 clients in ECOP.

The study concluded that 13% of Home Care Basic clients, 17% of Choices clients, and 20.6% of ECOP clients were terminated from the home care programs and placed into a nursing home.  Further examination of a subset of clients and interviews with case managers indicated – as home care agencies well know – more and in many cases a more skilled level of community based services is needed to keep clients from nursing homes.   Not surprisingly the interviewed care managers call for more 24/7 care options, but the study also calls for  more help for patients with medication administration, falls risk assessment and home safety assessment and improved coordination with medical providers, especially in the area of pain management.

While there has always been a push in the state home care program against “over-medicalization” of the benefits purchased, it seems clear from this report that there may need to be movement towards supplementing homemaker and home health aide with more professional support for certain clients.

ASAP providers: Does your experience match up with this report?   Do you have comments that you would like to see reflected in feedback from the Alliance to EOEA?

Return to www.thinkhomecare.org.

Governor Releases Health Reform Legislation

Today , Governor Patrick released proposed legislation “Improving the Quality of Health Care and Controlling Costs by Reforming Health Systems and Payments.” The bill calls for  “Encouraging the formation of integrated care organizations, commonly referred to as accountable care organizations, comprised of connected or integrated groups of health care providers that achieve improved health outcomes and lower the costs of care.

The bill does not explicitly define provides and services that must be encompassed in an ACO instead defining an ACO as “an entity comprised of provider groups which operates as a single integrated organization that accepts at least shared responsibility for the cost and primary responsibility for the quality of care delivered to a specific population of patients cared for by the groups’ clinicians; which operates consistent with principles of a patient centered medical home and satisfies the other requirements of this chapter; which has a formal legal structure to receive and distribute savings;  The bill does anticipate that “certain providers that are not primary care providers may be ACO network providers in more than one ACO, as set forth in regulation by the division.”    The “division” which has authority to draft authorizing regulations is the Division of Health Care Finance & Policy.

The bill calls for greater transparency in payment arrangements and requires that by March 31, 2012, the “Division will “document, categorize and publish all current payment arrangements in the commonwealth between payers and providers.”   Medicaid participation in the ACO model is envisioned by 2014.

The Alliance will be reviewing this legislation with the Legislative and Policy Committee and the Board of Directors and welcomes member feedback. as to whether home health’s role should be more explicit in this legislation.

Return to www.thinkhomecare.org.

More Face To Face Clarifications Issued

The following was issued by NAHC Regulatory Affairs

CMS issued an update to the Medicare Benefit Policy Manual, Pub 100-02 Chapter 7 via a Transmittal issued this afternoon at: http://www.cms.gov/transmittals/downloads/R139BP.pdf. Summarized below are new pieces of information (including exception in case of death of patient) and clarifications found in the Transmittal.

General Issues

  • The certifying physician must document that he or she or an allowed non-physician practitioner (NPP) had a face-to-face encounter with the patient.
  • Certain NPPs may perform the face-to-face encounter and inform the certifying physician regarding the clinical findings exhibited by the patient during the encounter. However, the certifying physician must document the encounter and sign the certification.
  • The documentation must include the date when the physician or allowed NPP saw the patient, and a brief narrative composed by the certifying physician who describes how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services on the certification or an addendum to the certification.
  • It is acceptable for the certifying physician to dictate the documentation content to one of the physician’s support personnel to type.
  • It is also acceptable for the documentation to be generated from a physician’s electronic health record.
  • It is unacceptable for the physician to verbally communicate the encounter to the HHA, where the HHA would then document the encounter as part of the certification for the physician to sign.

Exceptional Circumstances in Case of Death:

  • · When a home health patient dies shortly after admission, before the face-to-face encounter occurs, if the contractor determines a good faith effort existed on the part of the HHA to facilitate/coordinate the encounter and if all other certification requirements are met, the certification is deemed to be complete.

Hospitalist Role

  • A physician who attended to the patient in an acute or post-acute setting, but does not follow the patient in the community (such as a hospitalist) may certify the need for home health care based on his/her contact with the patient, and establish and sign the plan of care. The acute/post-acute physician would then transfer/hand off the patient’s care to a designated community-based physician who assumes care for the patient.
  • Or, A physician who attended to the patient in an acute or post-acute setting may certify the need for home health care based on his/her contact with the patient, initiate the orders for home health services, and transfer the patient to a designated community-based physician to review and sign off on the plan of care.

Return to www.thinkhomecare.org.

MEDPAC Commissioners Discuss Medicare Home Health Payment Overhaul

Even as home health agencies prepare to implement the deep payment cuts and regulatory changes called for in the health reform law and 2011 payment rule, MEDPAC’s Commissioners are considering recommending major PPS payment changes in their Spring 2011 report to Congress.   At their November meeting, the Commissioners considered a presentation by home health analyst Evan Christman  on Improving Incentives and Safeguards for the Home Health Benefit .

Christman focused much of his presentation on variations in profitability and how in particular financial performance tracks to cases with therapy use.  Christman also provided detailed data on what he charatcerized as a 48% growth in home health episodes with no prior hospitalization or other post acute services.   The rate of growth for these types of cases, he informed the Commissioners, is 14 times the rate of growth for home health as a post acute care services.  Supply, he said, is expanding to take care of less severely ill patients.   The Commissioners were clearly – by their comments – taken back at this.

Christman recommended the the Commissioner endorse a “redistributive payment recommendation” that would reduce percentage of overall dollars going to cases with therapy in favor of non-therapy and dual eligible patients.  He also  recommended a 3% adjustment for dual-eligibles   Finally, he recommended consideration of a co-payment, specifically on home health cases with no prior hospitalization.   A lengthy and instructive discussion of home health trends, payments and value ensued – all of which can be found on the meeting transcript –beginning on page 211.

While ether are some things in the MEDPAC discussion that this association has  supported (dual eligible adjustments), a review of the transcript reveals we still have both an image and a substance issue when it comes to (many) MEDPAC Commissioners and our services.

Return to www.thinkhomecare.org.