HCA and Northeastern University Partner on Nurse Symposium in June

March 21, 2019

These days, it seems like every week a new report is published sounding the alarm of a rapidly aging population across the United States and a shortage of workers prepared to care for this barreling silver tsunami. So much of the media coverage and research is focused on the paraprofessional workforce.

See for example, these reports/publications:

However, the Home Care Alliance member surveys indicate that the problem is broader than just a shortage of home health aides. The availability of a trained nursing workforce to meet a growing home-based health care delivery system is also emerging as an issue. Compounding challenges are impacting our ability as an industry to attract nursing students into home and community-based settings after nursing school.  That is why, on June 7th the Home Care Alliance of Massachusetts and Northeastern’s School of Nursing are hosting a symposium on the very topic of building a home care nursing workforce at Northeastern University from 9AM – 3PM.

The event, titled: Nursing Call to Action: Building a Nursing Workforce to Deliver Complex Care at Home, will bring together more than 25 nursing schools and 25 home health providers for a day-long session. The program will kick-start a dialogue brainstorming new approaches for preparing and exposing Massachusetts nursing students for an increasingly intensive health delivery system in the home.

This event will look past the issue of reimbursement rates or ever-changing reforms at CMS, and instead will focus on four key areas:

  1. Identifying knowledge and skills gaps for LPN/RN new-grads and what changes can be made to address the gaps and develop competencies in executing highly complex services
  2. Elevating the visibility to nursing schools of the growing demand for home-based services and the need to expose students to possible careers in home care nursing
  3. Identifying strategies on recruitment as new-grads and experienced nurses prepare for possible careers in home care nursing
  4. Identifying barriers and strategies to get home health agencies more involved in clinical placements for nursing students

If you would like more information on this event, please reach out to Jake Krilovich. Please note: There is limited space for this event!


PDGM Fix Introduced, Advocacy Needed

February 21, 2019

Last week, a bipartisan group of senators, led by Sen Susan Collins (R-ME)  introduced what will be a most important legislative priority for HCA of MA this year.  Senate bill (S.433) will curtail the so-called $1 billion “behavioral adjustment” cut under the Patient Driven Groupings Model (PDGM) to which all of home health is transitioning in 2020.  Among, many other changes, PDGM will move home health from a 60 to a 30 day payment unit. This is the most significant change to home health payment since the Prospective Payment System was introduced in 2000.

The Congressional action that called for a home health payment overhaul required that the new payment model be budget neutral against current spending levels. However,  the legislation also allowed that CMS to consider “behavioral  adjustments” defined as industry actions that would be taken to increase payment under the new model, unrelated to patient case mix changes. CMS has used this authority very broadly to institute a payment adjustment in the first year of PDGM based on “assumptions” of behavioral changes, and that adjustment calls for a 6.42% base rate reduction, or a possible $1b reduction in payments.

S 433 would prohibit CMS from making any pre-rate change reductions based on assumptions and instead to phase in any adjustments (either up or down) based on observed evidence (i.e., data supported) changes in provider behavior. The objective would be to achieve budget neutrality by 2029. This later piece addresses concerns the Congressional Budget Office (CBO) expressed regarding whether a similar bill introduced last session was truly budget neutral. S.433 also would allow Medicare advantage plans and Center for Medicare and Medicaid Innovations (CMMI) to waive the “confined to home”  provision when in the best interest of a Medicare beneficiary.

Regardless of the “behavioral adjustments,” the PDGM model is expected to have a tremendously varied impact state by state and agency by agency.  A significant amount of this impact is related to a Congressional  requirement that the payment model no longer use the volume of therapy as a payment level determinant.  (Something MEDPAC has been calling on CMS to do for years.)   The state of Florida, where therapy visits average 10.45 per episode of care is set to “lose” the most – projected at $141 million.  California on the other hand, where the average therapy utilization per episode was 5.76,  will be the largest gainer.  MA (need numbers from Tim)  Note: S 433 does not seek to make changes to the structure of the payment model that produces these changes.

It is important to reflect on CMS’ proposal in 2017, Home Health Groupings Model (HHGM) and how we arrived to where we are today. At the time, HHGM represented similar changes to the payment model, without soliciting industry feedback and some estimates predicting a 15% reduction in payments. As a result, the industry unified itself behind one message: that CMS withdraw its proposal and engage stakeholders to come up with an alternative. Upwards of 13,000 emails were sent to Congress from the industry, 49 members of the U.S. Senate and almost 160 members of the U.S. House of Representatives signed onto letters to CMS echoing the request to withdraw HHGM. This was a remarkable show of mobilization by the industry and we’ll need it again to make modifications to PDGM.

At present there is no bill in the House, but it is expected that one will be forthcoming.  Strong early sign on support is critical to keeping this bill moving and HCA of MA will be urging members to contact the MA delegation to support S.433 and the companion house legislation to be introduced. Stay tuned for these advocacy alerts in our weekly newsletter and advocacy messages in the coming weeks.

HCA will also be hosting a number of member events to prepare for the payment transition.  While the full day PDGM programs in March in Northampton are sold out, there will be a high concentration of sessions on PDGM at the New England Home Care Conference and Trade Show in on June 5 -7 inn Falmouth. Watch here for more details.

In the meantime, send a message here to Senators Warren and Markey about the need for their support on this issue. 

Let’s do this home care – we cannot sustain $1 billion in cuts based on assumptions, not facts!


Talking Home Care: NAHC’s Calvin McDaniel on the 2018 Midterm Elections

November 19, 2018

Kelleher and McDaniel

On this week’s edition of Talking Home Care, we are joined by Calvin McDaniel, Director of Government Affairs for the National Association for Home Care & Hospice (NAHC). Calvin oversees NAHC’s legislative priorities on Capitol Hill, and collaborates with the Alliance and other state associations on shared, industry-wide priorities.

Our discussion recaps the 2018 Midterm Elections and what to expect in the 116th Congress, which will be seated in January 2019. Enjoy!


You may listen to the podcast by clicking the play button below, downloading it directly, or subscribing through iTunes or Google Play. (Length: 29 minutes; Size: 23.2 MB). If you enjoy it, please give us a five-star review so others can find it.

Host: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

GuestCalvin McDaniel, Director of Government Affairs for the National Association for Home Care & Hospice (NAHC).

2018 Midterm Elections Recap (Updated Monday, 11/19):

  • Democrats regained control of the US House of Representatives, gaining 37 seats so far and holding a majority of 233 seats to Republicans’ 198 seats.
  • Republicans held control of the US Senate picking up two seat as and expanding their Senate Majority to 52 seats to Democrats’ 47 seats. The Mississippi senate seat is heading toward a run-off election on November 27th.
  • On the state level: Democrats flipped nearly 400 state legislative seats nationwide, flipped seven Republican-held governor seats, and took full control of the legislature and Governors’ mansion in seven states.
  • Lastly, three states: Idaho, Nebraska and Utah voted to expand Medicaid. And a fourth state, Maine, elected a democratic governor, who will likely do the same.
  • Overall, nearly 116 million voters cast ballots, representing over 40% of eligible voters and represents the largest midterm voter turnout in 104 years.
  • It is expected that Representative Richard Neal (D-MA) will become the Chairman of House Ways & Means, and Representative Jim McGovern (D-MA) will become the new Chairman of the Rules Committee. This greatly increases the Massachusetts’ Congressional Delegation influence on Capitol Hill.

The most important takeaway from our conversation with Calvin is that HCA members should prepare for an incredibly active two years of advocacy. Take hold of your responsibility to engage your elected officials on behalf of your organization and join us in the fight on the many issues facing our industry. Be it an email to a legislator, inviting them to your offices for a tour or on a home visit, or taking time to join us in D.C. for one of the many fly-in events, it takes an army of voices to accomplish a common goal. To get involved, email Jake Krilovich.

Return to www.thinkhomecare.org.


Talking Home Care: Amanda Oberlies on “No on MA Ballot Question 1”

October 31, 2018

The Alliance’s Pat Kelleher &
ONL’s Amanda Oberlies

Should health care facilities have their nurse-to-patient ratios defined by law? That’s the question put to Massachusetts voters this coming Tuesday. Amanda Oberlies of the Organization of Nurse Leaders joins us to discuss why her organization (and the Alliance) oppose Massachusetts Ballot Question #1. Their conversation covers:

  • Who’s behind the ballot question and why?
  • What is the intersection of staffing-ratios and quality?
  • How does California’s experience with a similar law correlate to the MA proposal?


You may listen to the podcast by clicking the play button below, downloading it directly, or subscribing through iTunes or Google Play. (Length: 30 minutes; Size: 24 MB). If you enjoy it, please give us a five-star review so others can find it.

Host: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

Guest: Amanda Stefancyk Oberlies, PhD, MBA, RN, CENP, is the Chief Executive Officer of the Organization of Nurse Leaders (ONL).

Resources:


Talking Home Care LogoDon’t want to miss the next episode of Talking Home Care? Subscribe through iTunes, Google Play, or accessing its feed directly.

Return to www.thinkhomecare.org.


HCA Submits Comment on Medicare Changes; Submit Your Comments Now!

August 30, 2018

On July 1st, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule which includes several changes to the home health benefit for 2019 and beyond. The public comment period closes this Friday August 31, 2018, at 11:59 p.m. As of this blog posting, 760 comments have been submitted to CMS which is encouraging, but far from the more than 1,300 comments submitted last year in response to the HHGM proposal which was ultimately withdrawn.

You can view the HCA’s written comments here and can download the word document here.

You may submit your own comments to CMS here.

Here are some of the key changes proposed, and an overview of HCA’s response:

Home Health Wage Index Changes

  • The 2019 proposed payment rates increase by 2.1% which represents a $400 million increase.
  • HCA of MA has long expressed concerns to CMS over inequities in how the wage index is calculated for home health agencies compared to hospitals. HCA urges CMS to adjust the 2019 home health agency wage index to reflect a policy to limit the wage index disparity between provider types within a given CBSA.

Proposed Patient Driven Groupings Model (PDGM) for CY 2020

  • Implementation: As the proposed PDGM would mark a major change in the way home health agencies will be reimbursed, the HCA urges CMS to delay implementation by one year to ensure that there is no disruption in access to services for beneficiaries and evaluate the accuracy of the model and its effect.

  • LUPA Thresholds: CMS proposes to set the LUPA visit threshold at the 10th percentile for each payment group. HCA believes this is complex and will complicate the care planning process for home health agencies. HCA urges CMS to retain the current LUPA thresholds and revisit them in future years.

  • Behavioral Assumptions: CMS proposed three ‘behavioral assumptions’ in the PDGM totaling -6.42%. However, these assumptions are not based in data or evidence. HCA believes that two of the three assumptions already exist in the current PPS methodology including; that agencies are already incentivized to both report the highest playing diagnosis codes and to develop and deliver plans of care that exceed the LUPA threshold. This could result in an over estimated impact of behavioral assumptions and the HCA urges CMS to eliminate the Clinical Group Coding and LUPA threshold assumptions.

  • Split percentage payment approach: HCA believes that changing from a 60 to 30 day billing period will be very disruptive to agencies’ operations and increase back-office costs. Therefore, HCA urges CMS to continue the split payment approach at the current 60/40 and 50/50 splits for early and late periods, respectively, to give agencies cash flow breathing room.

  • Certification and Re-certification of Patient Eligibility: HCA has long advocated for regulatory language to align with sub-regulatory guidance as it relates to documentation of the patient’s eligibility. HCA is encouraged by CMS’ proposal to eliminate the requirement that the physician provide an estimate of how much longer skilled services are required and we request that CMS consider revisions to the physician’s burden of the F2F encounter as a condition of payment. 
  • Remote Patient Monitoring: HCA strongly supports the proposal to recognize remote patient monitoring costs as an administrative cost on the HHA cost report. HCA does recommend however that CMS remove the regulation that does not allow remote patient monitoring to be used as a substitute for in-person home health services. 
  • Home Health Value Based Purchasing Model: HCA has long supported the HHVBP model aiming to improve quality by giving HHAs incentives to provide better quality care. However, HCA urges CMS to modify the HHVBP to recognize stabilization in the scoring because in many cases, stabilization (instead of improvement) is an appropriate goal for some patients.

Advocacy Alert: Email Senators Urging Support for HCA Budget Priorities

May 18, 2018
Last week, the Massachusetts Senate Ways and Means committee released its fiscal year 2019 state budget totaling $41.4 billion dollars. Senators had a deadline of Monday to file amendments to the bill, and it will be debated next week. Three Alliance priorities have been filed as amendments. Below are brief descriptions of each, with a link to send a pre-drafted email to your state legislator. The Alliance encourages you to send an email for all three amendments.

Amendment #589: EMAC Assessment Hardship Waiver:

  • This amendment would authorize the Department of Unemployment Assistance to establish a hardship waiver for employers that provide services to EOHHS/EOEA clients, or services in the public interest, who have a financial burden as a result of their EMAC tax liability. Take Action.

Amendment #560: Enough Pay to Stay Amendment:

  • This amendment would provide $28.8 million in increased funding for the State’s home care system front-line workforce. Take Action.

Amendment #620: Continuous Skilled Nursing Funding

  • This amendment would provide a $16 million increase for the Commonwealth’s Continuous Skilled Nursing program to address the workforce shortage resulting in unfilled service hours. Take Action.

MA Legislative/Regulatory Preview for 2018

January 11, 2018
On Wednesday January 3rd , the Massachusetts Legislature returned for the second year of its two-year session. After a seven-week recess, the body is looking at a traditionally busier second half than the first. The nearly 170 bills that passed in 2017 marked the lowest total in twenty years.

Lawmakers have until July 31 to complete all substantial legislative debate. In addition, all 200 members are up for election in 2018, which is expected to be a distraction from normal legislative work as a result of a polarized political landscape. Here’s what the Alliance will be focused on in 2018:

Workforce Issues:

Prior to the Holiday break, the Alliance met with its ‘Enough Pay to Stay’ partners to strategize coordinated efforts to attain wage relief for direct care workers and ASAP case managers. The coalition has pending legislation which would take steps toward this initiative, but we will pursue other legislative vehicles to fight for our workforce.

Worker Registry:

In November, Governor Baker signed into law the Home Care Worker Registry. This law will establish a worker registry that requires agencies contracting with ASAPs to submit workers’ private information to the state. The law is enacted and subject to regulations. The Alliance and its partners are in active communication regarding next steps toward protecting our members and their workers’ rights.

Licensure:

The FY 2018 State Budget included language that will establish a licensure process for home health agencies providing skilled services. It is unclear at this point when the process to promulgate regulations will begin, but the Alliance will be providing input to the Department of Public Health as these parameters are developed. In addition, Alliance-sponsored legislation that would license private care agencies is still making its way through the legislative process. Under procedural rules, the legislature has until February to report legislation out of committee. The Alliance will continue to advocate for passage of this legislation.

Continuous Skilled Nursing:

In late 2017, MassHealth announced two rate increases for the Continuous Skilled Nursing (CSN) program that totaled nearly 11 million. This was welcomed news, but there remains work to be done. The CSN provider/parent coalition will continue to advocate for the CSN Bill of Rights legislation that would mandate bi-annual reviews of the workforce to ensure safeguards against future crises.

MassHealth Rates:

The Alliance has been informed that MassHealth will conduct a long-overdue review of rates for per-visit nursing, therapies, and home health aide services.  The Alliance will be working to gather data to demonstrate that the current low rates are interfering with agencies’ ability to attract and retain enough workers to meet the demand for services.

MassHealth Reorganization:

MassHealth’s initiative to enroll the majority of members into managed care programs this coming spring will dramatically change the way MassHealth members access home health services, and disrupt many existing provider referral relationships.  The Alliance will continue to work to ensure that MassHealth members retain access to needed home health services, and that agencies are adequately reimbursed for those services.

House of Representative Health Care Bill:

Late last year the Senate passed a health care cost containment bill aimed at curbing costs while maintaining access. It has long been rumored that the House will be embarking on similar initiatives. Though the details are scarce, this legislation could be a vehicle for many of the Alliances priorities in 2018 and we will continue to advocate where necessary.

If you have any questions about the year ahead for advocacy or would like to get involved, reach out to Jake Krilovich, the Alliance’s Director of Legislative and Public Affairs.


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