Category: Advocacy

HCA, NAHC Offer Guidance on Physician Face-to-Face Requirement

In an effort to assist agencies in navigating their way through a major piece of a recent CMS Final Rule, the Home Care Alliance and the National Association for Home Care & Hospice have released a list of documents aimed at improving the understanding of patients and educating doctors while encouraging their coordination and cooperation.

The requirement is that a face-to-face visit between a patient and their physician is necessary in order to be certified for home health services.  Please see the sample documents below for guidance and for your agency’s use.

A link to the entire Final Rule as published in the Federal Register is available here. The section of note is Letter “F” for the face-to-face requirement, which is available here.

If there are any questions, or if you would like further information, please contact the Home Care Alliance. Please note that clarification has been asked of CMS regarding certain aspects of the rule, including documentation.

Return to www.thinkhomecare.org.

HCA Submits Comments to CMS on Moratorum, Screening Requirements Rule

The Home Care Alliance submitted comments on a proposed rule from CMS, specifically focusing on “Temporary Moratoria on Enrollment of Medicare Providers and Suppliers, Medicaid and CHIP Providers.”

The comments point out data that supports the need for a temporary moratorium on Medicare-certified home health providers. For instance:

…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.

Highlighting the lack of licensure and Certificate of Need, along with the growth in the number of certified agencies, the Alliance saw an opportunity to protect the hard work of existing agencies that have established a tradition of quality and honesty in the business.

Click here to see more on the CMS proposed rule (CMS-2010-0239-0001: “Medicare, Medicaid and Childrens Health Insurance Programs: Additional Screening Requirements, etc, for Providers and Suppliers)

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.

HCA Announcement: CMS Final Rule Cuts Home Care

The Home Care Alliance distributed a press release spotlighting the Final Rule from the Centers for Medicare and Medicaid Services (CMS) that cuts home health payments and implements barriers between patients and the care they need.

Although some flexibility was gained through advocacy on the proposed rule, the results of the final rule are still damaging to the industry. Federal elected officials for Massachusetts were instrumental in helping to achieve some of that flexibility, but more work will need to be done as CMS plans to re-evaluate its assessment methodology in making any case mix adjustnments for 2012.

New Medicare Final Rule Cuts Home Care
Rule Scaled Back from Original Proposal, Still Damaging to Home Health Services

Home care agencies and organizations across the country knew that nearly $40 billion in cuts to Medicare home health services over the next decade were going to be included in the Affordable Care Act, but the home health industry did not expect an additional $960 million reduction in 2011 alone.

That extra cut was the result of a new final rule from the Centers for Medicare and Medicaid Services (CMS) that also will place a number of restrictions on those attempting to certify, administer, and receive home health services.

“We understand the federal government’s is trying to save Medicare by slowing growth in spending, but the degree of cuts contained in this rule are too much, too fast,” said Home Care Alliance Executive Director Patricia Kelleher. “At time when all the evidence shows that patients being admitted to home health are sicker and in need of even greater resources Medicare is reducing payments by almost five percent. This is on top of a 2.79 percent cut last year. The industry cannot continue to sustain cuts upon cuts.”

Also new to the Medicare program, CMS is now requiring a face-to-face visit between physician and patient before a home health plan can be certified. The timeframe for such a visit was extended to 90 days before the start of care or 30 days after the start of care, which is an improvement on the 30-day/14 day timeline in the original proposed rule. However, this new rule may still be a barrier to care for patients too ill to get out to a doctor or unable to get a timely appointment.

Much of the proposed rule was meant to curb what Medicare sees as excessive growth of the program in some parts of the county. But imposing an across the board cut only makes the work of caring for people at home more difficult for the providers who have always played by the programmatic rules set by CMS.

“Working with Senator Kerry, the home health industry was able to negotiate a level of payment reform for home health in the Affordable Care Act that would have been sustainable over the next few years,” added Kelleher, “but the Medicare program has far exceeded what they were instructed to do by Congress.”

Massachusetts was the only state in the nation to have the entire federal legislative delegation – all Congresspersons and both Senators – sign a letter in opposition to the level of cuts in the CMS proposed rule.

Return to www.thinkhomecare.org.

Join HCA in Celebrating National Home Care Month

November is National Home Care Month and the Home Care Alliance continues to work on spreading awareness of the great work performed by home care and home health providers everyday as well as highlighting issues of concern to the industry.

Although Family Caregiver Appreciation Day is officially postponed, HCA has a number of ways to get the word out about the important services provided by home care agencies and family caregivers that allow people in need to remain in their communities.

Here are a few ways YOU can help raise awareness on National Home Care Month.

For home care providers:

  • Tailor this press release on Home Care Month to include information about your agency and the services you provide. Then, distribute to your local newspaper and/or local senior newsletter (Please contact the Alliance if you would like assistance or have any questions).

For Everyone:

  • Print and display the different posters in your community.

–Home Care: Guaranteeing Health Care Freedom (1)

–Home Care: Guaranteeing Health Care Freedom (2)

–Ted Kennedy Poster

–Honoring the Caregiver

–Preserving Health Independence and Freedom

–No place like home

–Compassionate Health Care Delivered to your Doorstep

 

Return to www.thinkhomecare.org

New Advocacy Message on Nurse Delegation

A new message is available on the HCA’s Legislative Action Center in an effort to get the Nurse Delegation Bill (Senate Bill 860) through the House and to the Governor’s desk.

This message is aimed at the House Committee on Bills in the Third Reading, which is the last stop before the House can advance this important legislation.

See the top message titled “Please Pass Nurse Delegation for Better Home Health” and click below the title to take action!

Return to www.thinkhomecare.org.

New CMS Proposed Rule Issued on Provider Screening, etc.

The Centers for Medicare and Medicaid Services issued a new proposed rule on September 20 that lays out changes in provider screening, suspension of payments, fraud control, temporary moratorium criteria, and cross program terminations.

A summary of the rule will be made available in this week’s issue of UPDATE for Alliance members.

Those interested in submitting comments, which are due by November 16, can be made electronically by clicking here, or by mail at the address below:

  • Centers for Medicare & Medicaid Services, Department of Health and
    Human Services, Attention: CMS-6028-P, P.O. Box 8020, Baltimore, MD
    21244-8020.

Return to www.thinkhomecare.org.

HCA Comments to CMS on Proposed Rule

The Home Care Alliance has submitted comments on behalf of Medicare home health agency members to the Centers for Medicare and Medicaid Services regarding Proposed Rule CMS-1510-P (Medicare Program: Home Health Prospective Payment System Rate Update [CY 2011]; Changes in Certification Requirements for Home Health Agencies and Hospices).

The comments include suggested changes on the case mix adjustment, face-to-face physician encounter requirement, 36-month Rule/Capitalization Requirements, Claims Data Collection and Processing, HHCAHPS, and the Therapy Coverage Requirement. The comments also reflect how Massachusetts agencies have case mix weights well below the national average, but that the Northeast stands to be punished severely for following guidelines set by CMS.

Click here to see the Home Care Alliance’s comments on the Proposed Rule.

Return to www.thinkhomecare.org.

Letter Examples for CMS Proposed Rule Advocacy

Agencies in Western Massachusetts have stepped up with several letter templates for their physicians to send in to CMS and Administrator Donald Berwick regarding the Proposed Rule on case mix and Physician face-to-face visits.

Please see the letters below and feel free to edit and send as you see appropriate:

As a reminder, comments are due by September 14 to CMS and can be sent:

  1. a. By Mail: Centers for Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1510-P, P.O. Box 1850, Baltimore, MD 21244-1850
  2. b. Or electronically by clicking here, then clicking “submit comment.”

Return to www.thinkhomecare.org

Sign up for Teleconference on CMS Proposed Rule

Members of the Home Care Alliance are invited to participate in an open teleconference about the CMS proposed rule and to hear an update on the strategies that the Alliance and the National Association for Home Care & Hospice have developed to oppose the negative changes.

The call is scheduled for Tuesday, September 7, 3:00 – 4:30 p.m and  Bill Dombi, NAHC’s Vice President for Legal Affairs will participate in the call.

Pre-registration is required.  Email Stephanie Drakes at the Alliance to get the call-in information.

Return to www.thinkhomecare.org.