Category: Advocacy

CMS Proposes Medicare Home Health Payment Changes for 2012

The Centers for Medicare and Medicaid Services (CMS) have issued a proposed rule regarding payment changes as well as revisions to the physician face-to-face and therapy assessment rules.

Below is a summary of the most noteworthy aspects of the proposed rule provided by the National Association for Home Care & Hospice (NAHC):

1.       Proposed 2012 payment base episode rates are reduced to $2112.37 from the current $2192.07. This is a reduction of approximately 3.56%.

2.       The rate changes are due to a proposed 2.5% market basket index inflation update, a 1 point reduction in the MBI under the health care reform law, and a 5.06% case mix creep adjustment.

3.       The increase in the case mix creep adjustment is due to the evaluation of 2009 coding weight changes. CMS found that ¾ of the coding increases was a result of increases in therapy visits above the 14 and 20 visit thresholds.

4.       The 3.56% rate reduction will impact individual providers unevenly. CMS proposes to make significant changes in coding weights by eliminating hypertension as a factor in the calculation, reducing the weights on therapy episodes, and increasing weights on non-therapy episodes. Providers with high volumes of therapy cases could see greater net rate reductions. A provider-specific analysis using the provider’s particular case mix is the only reliable way to assess impact.

5.       CMS proposes to change the face-to-face rule and allow one physician to do the encounter and report the information to another physician who completes the certification and plan of treatment documentation. This should help in circumstances where a patient is under the care of a hospitalist who transfers the patient to a community physician.

6.       CMS proposes to clarify the therapy assessment standard where more than one discipline is involved.

The proposed rule on rates is in line with what had been expected. Nevertheless, that does not turn a lemon into lemonade. The change on the face-to-face rule is appreciated, but will only make a slight improvement as the documentation requirements remain a problem.

CMS also posted the proposed rule on the Medicaid face-to-face encounter requirements. The proposal aligns the Medicaid time frames with the Medicare time frames while providing some flexibility to states to determine other aspects such as the content and form of documentation. The proposal also reaffirms CMS’s position that a homebound requirement in Medicaid home health is not permitted and that services can be provided outside the home. Finally, the proposal offers clarifications on the coverage of medical supplies and equipment.

Another summary is available in a press release issued by CMS with a few more specifics on payment. The Home Care Alliance is working on a specific analysis regarding the payment changes based on the northeast’s wage index and will have that available soon.

See links to the specific proposed rules in the Federal Register below:

 

Return to www.thinkhomecare.org.

Health Care Cost Trends Hearings and Panels This Week

The state’s Division of Health Care Finance & Policy (DHCFP) is holding a series of presentations, speeches and panel discussions this week in regards to health care cost trends reports and cost containment efforts currently underway.

The full agenda for the week features a range of health care experts and stakeholders, including government officials, and there will also be limited room for public comment. This is another opportunity for those interested to hear the state’s work in highlighting cost disparities as well as an attempted move for the state towards global payments and health care cost control.

The hearings are being held from Monday, June 27, 2011 through Thursday, June 30, 2011 at Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129.

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Monday, June 27, 2011 through Thursday, June 30, 2011

Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129

MA Congressional Delegation Weighs in on Physician Face-to-Face Requirement

The Massachusetts Congressional Delegation has stepped up again, this time sending a letter to CMS Administrator Dr. Donald Berwick with concern over the physician face-to-face requirement.

Every member of the delegation – Senators Kerry and Brown, as well as US Reps Markey, Frank, Neal, Olver, McGovern, Tierney, Capuano, Lynch,  Tsongas and Keating – signed onto the letter noting that the Massachusetts health care community has made considerable efforts to comply with the rule, but the paperwork burden and duplicative nature of the requirement are proving problematic and that CMS should consider changes.

The letter itself is available here and the Home Care Alliance greatly appreciates the work and support from the Congressional Delegation.

Return to www.thinkhomecare.org.

 

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.

State Seeks Comments on Accountable Care Organizations Through New RFI

The state’s Executive Office of Health and Human Services has released a Request for Information regarding the formation of Accountable Care Organizations (ACO’s) and are seeking comments from “all interested partComm-PASS logoies.”

The RFI includes an introductory letter from Health and Human Services Secretary Dr. JudyAnn Bigby and a thorough explanation of the state’s intentions for the transition to a new payment system. A response template is included in “Attachment A” of the document and comments should be submitted electronically through the Commonwealth Procurement Access and Solicitation System (Comm-PASS). Instructions are available in the RFI and the Home Care Alliance encourages home care agencies to submit comments as they see fit.

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Panel Review Dates Announced for Care Transitions Program

The Centers for Medicare and Medicaid Services announced panel review deadlines for applications to be submitted for the Affordable Care Act’s Section 3026 Community-Based Care Transitions Program.

  • July 19, 2011 – Applications must be received no later than June 20, 2011 to be considered for this review.
  • August 24, 2011 – Applications must be received no later than July 15, 2011 to be considered for this review.
  • September 19, 2011 – Applications must be received no later than August 18, 2011 to be considered for this review.

The Home Care Alliance has received questions regarding the assembly of a budget for the application and a helpful guide  is available upon request for those interested.

Guidance is also still available on the Q&A section of the CMS Care Transition Program’s web page.

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Advocacy Alert: Send an Email to Budget Conferees to Support Telehealth

A new advocacy message is available to click and send to legislators who are part of the FY 2012 Budget Conference Committee, which is charged with compromising the House and Senate versions of the state budget before it’s sent to the Governor.

The Home Care Alliance, thanks to State Senator Richard Moore, saw a Senate budget amendment pass that would bring MassHealth reimbursement for telehealth services provided by a home health agency.

You can help support this issue by visiting the HCA’s Legislative Action Center and clicking on the telehealth message. Simply fill out your contact information and click “send messages” to email each member of the conference committee.

Here is the language of the telehealth budget amendment (# 593) that passed in the Senate:

Messrs. Moore, Montigny and Tarr moved that the bill be amended, in Section 2, in item 4000-0500, by adding the following words:- “; provided further, that for purposes of long-term health care cost savings and enhanced patient care, the commonwealth shall recognize telehealth remote patient monitoring provided by home health agencies as a service to clients otherwise reimbursable through Medicaid”.

You can also call the conference committee members and ask that they support Senate budget amendment # 593 relative to telehealth. Contact info for the conferees is below:

  • Sen. Stephen Brewer – 617-722-1540
  • Sen. Steven Baddour – 617-722-1604
  • Sen. Michael Knapik – 617-722-1415
  • Rep. Brian Dempsey – 617-722-2990
  • Rep. Viriato Manuel deMacedo – 617-722-2100
  • Rep. Stephen Kulik – 617-722-2380

If you have any questions or would like to learn more, please contact the Alliance.

Return to www.thinkhomecare.org.

State Senate Budget Includes Telehealth

The state senate this week passed a $30.5 billion state budget for FY 2012 that included a major priority of the Home Care Alliance.

An amendment instructing MassHealth to reimburse for telehealth remote patient monitoring provided by a home health agency was adopted by the Senate.  That provision must now survive a conference committee made up of House and Senate members who will work out differences between the House and Senate budget proposals and send the finished version to the Governor for his approval.

The amendment passage is a victory for home health care and reflects a greater understanding from the state legislature on issues important to the industry. Moreover, the adoption of the telehealth amendment, while only a first step in the process, is also recognition of the cost savings that home health agencies and the use of technology can provide.

Most of the 599 budget amendments proposed in the Senate did not make it through, including restoration of MassHealth rates of payment for home health past 60 days, a pediatric home care amendment, and another that would have established a special care transitions rate for home care agencies.

Two amendments regarding adult day health were also adopted.  One would establish licensure standards for adult day health providers and the other would require MassHealth to notify the legislature of any changes to rates or clinical eligibility criteria for adult day health services.

Other amendments of note include:

  • An amendment was adopted that would require MassHealth to annually notify each beneficiary over 65 about their options regarding enrollment in voluntary programs, including Program of All Inclusive Care for the Elderly (PACE) plans, MassHealth Senior Care Options, Frail Elder Home and Community Based Waiver Program and “any other voluntary elected benefit to which such beneficiary is entitled to supplement or replace such beneficiary’s MassHealth benefits.”
  • An amendment was rejected that would allow nursing homes to place a hold on beds for residents who are transferred to the hospital for emergency care.
  • An amendment was adopted to provide an additional $1 million for elder protective services (total amount: $16,250,554).
  • An amendment was adopted to provide an undisclosed amount of funding to elder pre-admission options counseling.
  • An amendment was adopted providing an additional $4 million for Day Habilitation Services
  • The Salary Reserve for human service workers was not approved, but the Senate did approve a substitute amendment enable human service provider agencies to purchase health insurance through the Commonwealth Health Insurance Connector for their employees earning less than $40,000/year.

For any questions or further information on the state budget, contact James Fuccione at the Alliance.

Return to www.thinkhomecare.org.

Advocacy Messages Now Available for Senate Budget

The Home Care Alliance has several important amendments filed in the FY 2012 Senate budget and messages to support these initiatives are available here.

Here are the issues HCA is advocating for:

Amendment #483 – Home Health Care Rates, filed by Senator Michael Moore.

  • The MassHealth home health payment rate was cut by 20 percent to patients receiving skilled nursing care past 60 days of care in December of 2008. This created a new payment category that goes from $86.99 to $69.59 for patients that require longer periods of care and who are at a greater risk of inpatient facility admissions or readmissions.
  • Since all of MassHealth’s home health services receive a 50 percent federal match, the actual state expenditures reflect only half of a $7.1 million budget increase.

Amendment #478 – MassHealth Home Care, filed by Senator Steven Tolman.

  • This amendment establishes a special MassHealth rate to reward home health agencies that are successful in helping patients discharged from acute care avoid a costly re-hospitalization for the same condition for which they were originally hospitalized.
  • The hospitalization would have to be avoided for at least 30 days in order for the payment to be administered. The Secretary of Health and Human Services shall determine the rate, which will be based on a nurse-led team model.
  • This provision would increase the efficiency of care and save costs for the state in avoiding rehospitalizations.

Amendment #481 – Pediatric Home Care Services, filed by Senator Michael Moore.

  • This amendment does not increase any rate, but merely shifts existing payment recognizing a home health agency’s administrative requirements. Also, this amendment ensures safety and quality by allowing only registered nurses to care for multiple patients in a single setting.

Amendment #593 –  Telehealth Reimbursement, filed by Senator Richard Moore.

  • In recent years, several states have all moved forward with incorporating coverage of telehealth into their state plan, waiver home care programs, or have authorized funding for demonstration projects to support telemonitoring equipment purchases.
  • The Centers for Medicare and Medicaid Services also recognize and define telehealth billing and reimbursement practices.
  • Telehealth and remote care management programs are not only proven to reduce admissions to hospitals and nursing homes, but also reduce the frequency of home health visits.
  • Such lower cost services increase communication with physicians and caregivers, which contributes to the enhancement of care. It also increases patient self-management and is widely regarding as a cost savings measure supported by a number of studies and pilot programs.

Amendment # 589 – Adult Day Health Services, filed by Senator Richard Moore.

  • A $55 million cut to Adult Day Health (ADH) services was proposed in the Governor’s budget and this amendment would freeze the current level of reimbursement to prevent that reduction from occurring. The amendment would also impose a moratorium on new ADH facilities until a study on ADH rates and services is completed by the Executive Offices of Health and Human Services and Elder Affairs.

Amendment #586 – MassHealth/Medicare Dual Eligible Demonstration Project, filed by Senator Thomas Kennedy.

  • The Patrick administration is exploring a demonstration program that would offer a new integrated care product to MassHealth members that are dually-eligible for Medicare.  The new program would apply to individuals who are eligible for both Medicare and Medicaid, and who are between 21 and 65 years old.
  • The proposal envisions the MassHealth program receiving Medicare funds from the federal government for the purpose of managing the care of dual eligible patients.  MassHealth would then pay “Integrated Care Entities” a global payment for the care of a group of enrollees.
  • The governor’s FY2012 state budget recommendation assumes $50 million in savings from the proposed initiative. MassHealth states these savings will be achieved by better coordination and management of the dually eligible population.  While the $50 million savings estimate is not based on provider rate reductions, legislative guidelines for this dually-eligible demonstration effort are needed to assure hospital, physician, and home health care payments continue at current Medicare levels.

Return to www.thinkhomecare.org.

Hearing Kicks-off Public Comment Period on Payment Reform

A packed hearing in the State House’s Gardner Auditorium on Monday kick-started the conversation on what is likely to be the biggest change in the Massachusetts health care delivery system since the state passed universal coverage in 2006.

The Governor’s payment reform legislation would move the system of paying for all health care in the state from a fee-for-service model to more of a global payment model, with accountable care organizations responsible for delivering quality care in a manner that slows the growth of spending.

Much of the testimony and discussion is centering on how prescriptive the legislation will be in terms of mandatory versus voluntary participation, and the composition and authority of various oversight boards and advisory committees. Rey Spadoni, President & CEO of the Visiting Nurse Association of Boston and James Fuccione of the Home Care Alliance presented testimony regarding the need to recognize the importance of including the full continuum of care in any ACO model and central role that home care can play in a system that becomes more patient-centered, more cost conscious and accountable.

The Alliance, in particular, has asked in its testimony that the legislation be amended to require at least one home health/post-acute provider to be included on every ACO’s governing body.  The VNAB testimony asked that the new model recognize home health’s “investments in technology, clinical centers of excellence that serve patients with chronic disease, staff training and the addition of support services designed to keep people at home and independent or achieving the highest quality of life levels possible for them.”

The Home Care Alliance strongly encourages every interested agency to submit written testimony, which can be sent to the Alliance to collect and forward on to the Joint Committee on Health Care Financing, or to show up at public hearings being held across the state at the dates below:

  • Monday, May 23 at 11:00 a.m. at UMASS Medical School, Worcester (55 Lake Avenue North, 6th Floor of the medical school, Amphitheatre 3)
  • Monday, June 6 at 11:00 a.m. at Salem State University, Salem (71B Loring Avenue, Central Campus, Marsh 210)

The Alliance needs members to offering verbal or written comments if we are to be successful in carving an explicit role for home care into the ACO model.

The Home Care Alliance previously released a position paper on ACO’s prior to the Governor’s legislation that can be used to guide comments.

Return to www.thinkhomecare.org.