HCA Responds to Questionable Northwestern U Study on Private Pay Home Care

The Home Care Alliance has responded to a Northwestern University report, titled “Hiring and Screening Practices of Agencies Supplying Paid Caregivers to Older Adults” that confuses different models of private pay home care and asserts that most aides are not properly screened or trained.  The report, from researchers at the NU Feinberg School of Medicine, appeared in the most recent issue of the Journal of the American Geriatrics Society.

The study authors telephoned agencies in Illinois, California, Florida, Colorado, Arizona, Wisconsin, and Indiana, pretending to be looking for home care for a family member.   The information provided by the agencies over the telephone was analyzed and some broad and negative conclusions were drawn about the lack of industry standard practices for background checks, training requirements, and supervision. The report was discussed this week in the New York Time’s “New, Old Age” blog in a post called “Who’s Watching Mom?”

Please see the Home Care Alliance’s response to this report and feel free to use this in the event that your agency receive media inquiries.

Return to www.thinkhomecare.org.

Request for Responses for Consumer Consultants

MassHealth released an RFR to recruit “consumer consultants” that will assist with the review of applications from potential Integrated Care Organizations managing care for dual eligible individuals.

The demonstration project to better integrate and coordinate care for dual eligibles is still set to begin in January 2013 and the state remains on an aggressive pace to get the initiative underway. The RFR for Integrated Care Organizations (ICO’s) is due at the end of the month, and this separate RFR for “consumer consultants” is due July 20th.

These “consumers” must receive medical services, behavioral health services and/or long term services and supports (LTSS) from the state and will form a paid advisory subcommittee that shares its experiences and expertise with MassHealth and the state’s Executive Office of Health and Human Services.

The RFR is available on the state procurement website Comm-PASS as Document Number 13CBEHSCONSUMERCONSULTANTRFR and at this site on the Integrating Medicare and Medicaid for Dual Eligibles website under Related Information.

For those home care agencies that have patients with positive experiences of the care and services that have been delivered to them and that may be interested, please encourage them to apply.

Return to www.thinkhomecare.org.

CMS Home Health/Hospice Open Door Forum Tomorrow

The next CMS Home Health, Hospice, & DME Open Door Forum is scheduled for tomorrow, Wednesday, July 10, 2012 at 2:00pm ET.

To participate in this conference call, please dial (800) 837-1935 and use the conference ID 52259092. Participants are not required to RSVP and are asked to dial in at least 15 minutes prior to the call start time.

Two New ACOS Approved in Massachusetts

Health and Human Services (HHS) Secretary Kathleen Sebelius announced today the approval of 89 new Accountable Care Organizations (ACOs). The  89 new ACOs have entered into agreements effective July 1 with CMS, taking responsibility for the quality of care they provide to people with Medicare in return for the opportunity to share in savings realized through high-quality, well-coordinated care. Among the 89, there are two in Massachusetts:

  • Circle Health Alliance, LLC, located in Lowell, Massachusetts, is comprised of partnerships between hospitals and ACO professionals, with 353 physicians. It will serve Medicare beneficiaries in Massachusetts and New Hampshire.
  • Harbor Medical Associates, PC, located in South Weymouth, Massachusetts, is comprised of ACO group practices, with 116 physicians. It will serve Medicare beneficiaries in Massachusetts.

The 89 ACOs announced today bring the total number of organizations participating in Medicare shared savings initiatives to 154.  Of these, there are already five entities in Greater Boston designated as Pioneer ACOs  by CMS’ Center for Medicare and Medicaid Innovation (Innovation Center) announced last December.  There are an additional two physician  practice demonstrations, one south of Boston, the other on Cape Cod.

For 2012,  CMS has established for all ACOs 33 quality measures relating to care coordination and patient safety, appropriate use of preventive health services, improved care for at-risk populations, and patient and caregiver experience of care.

CMS Releases Proposed PPS rates for 2013

CMS on Friday released an advance copy of the proposed regulation for changes to the home health PPS rates for calendar year 2013.

Brief highlights:

• The proposal increases the national base episodic rate by 0.16%, from $2,138.52 to $2,141.95.  (calculated using a 2.5 percent inflation update, a 1 point reduction mandated by the health care reform law, and a 1.32 percent case mix creep adjustment.)

• The portion of the rate adjusted by the wage index is increased from .77082 to .78535

• The county wage index is available here (click on the “download” at the bottom of the page).:

Here are changes for MA counties:

Current                2013

Barnstable                        1.2838                   1.2872
Boston                              1.2283                   1.2394
Middlesex                         1.1210                   1.1285
Essex                               1.0698                   1.0575
erkshire                            1.0616                   1.0745
Bristol                               1.0639                   1.0718
Springfield                        1.0247                   1.0390
Worcester                         1.1076                   1.1230
Dukes/Nantucket              1.3962                   1.3570

The proposed rule also:

  • allows certain non-physician practitioners in inpatient settings to conduct the required Face-to-face encounter;
  • increases flexibility in complying with the therapy reassessment requirements;
  • establishes hospice quality reporting requirements to begin in 2014, including various proposed measures to report;
  • creates an Informal Dispute Resolution process that agencies can use to dispute survey deficiencies;
  • establishes a range of “Intermediate Sanctions” for non-compliance with the Medicare Conditions of Participation, including civil money penalties, suspension of payment for new admissions, and temporary management.

The Alliance will conduct a thorough analysis of the proposed rule and prepare comments.  Watch for additional details in the next few weeks.

Comments are due by Sept. 4.

Medicare Home Health Proposed Rule Issued: Clarifications and Improvements on Therapy Assessment Rules

The  Medicare Home Health Proposed Rule was release last week. Among proposed payment changes, Face to Face clarifications, and new sanctions for non-compliance with federal requirements, the Therapy Assessment Rule is also slated for changes and improvements. But are all of these proposed changes really improvements to this Therapy Rule?

Clearly an improvement to the rule—CMS proposes to revise the regulations to state that if a qualified therapist missed a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, not the visit after the therapist completed late reassessment.— Currently, when a qualified therapist misses one of the required reassessment visits, once the therapist has completed the required reassessment, coverage resumes after this reassessment visit.

In addition, CMS proposes to revise the regulations to state that” in cases where multiple therapy disciplines are involved, if the required reassessment visit was missed for any one of the therapy disciplines for which therapy services were being provided, therapy coverage would cease only for that particular therapy discipline”. Therefore, as long as the required therapy reassessments were completed timely for the remaining therapy disciplines, therapy services would continue to be covered for those therapy disciplines. Again this change appears to work in favor of the provider. — Currently the regulation states,  even if qualified therapists from the other therapy disciplines have completed all their required reassessment visits, therapy visits for these disciplines would not be covered until the qualified therapist who missed the reassessment visit has completed the previously missed reassessment visit.

This last change has potential to cause headaches for scheduling the multi-therapy visits. —CMS is proposing a change to allow “flexibility” and guidance to the provider.  This change would be applicable in cases where beneficiaries are receiving more than one type of therapy; the qualified therapists could complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th visit for the required 19th visit reassessment. — Currently the regulation states that therapist’s visit need only be “close to” the 13th and 19th visits. This proposed revision does not appear flexible but rather has great potential for scheduling patients’ visits for three disciplines to be extremely inflexible. Hopefully stakeholders will comment on this proposed change.

www.thinkhomecare.org.

Skilled Teaching for Dementia Patients

NHIC, Corp. has just released a medical policy article that addresses a specific category of skilled nursing care currently available to Medicare home health beneficiaries who have dementia with behavioral disturbances; A51856 Home Health Skilled Nursing Care: Teaching and Training for Dementia Patients with Behavioral Disturbances.  The category of skilled nursing is called “teaching and training activities”, defined in the CMS Manual System. The Medicare beneficiaries with dementia and behavioral disturbances could receive a patient-centered care plan directed at teaching the family or caregiver how to manage the behavioral disturbances.

Refer to Article A51856 for sample case scenarios and details on documentation, coding guidelines, and potential interventions

Return to www.thinkhomecare.org.

Home Care Alliance, National Organizations Make Statements on Supreme Court Decision

In light of the Supreme Court’s decision to uphold the Affordable Care Act, the Home Care Alliance of Massachusetts and other organizations representing health care providers and consumers had this to say:

“Today’s decision of the US Supreme Court has established the Affordable Care Act as the law. With their ruling, the Supreme Court has removed enormous uncertainty – particularly in states other than Massachusetts and for those involved in ACA funded demonstrations – as to whether to move forward. They now can, and we think they must.  While some parts of the law will impact Massachusetts far less directly than other states, there is evidence that our state has already benefited by some provisions. Most notably, 62,000 seniors and people with disabilities in Massachusetts have seen significant savings on their prescription drugs because the law was upheld.

All providers, including home health care, were subject to Medicare rate reductions in the ACA in order to expand coverage and pay for reform demonstrations.  These cuts have not been easy to absorb. With this ruling, we must now get to work to deliver on the promise in our state not just of universal access to insurance, but to a better coordinated, and ultimately more cost effective delivery system.”

-Patricia Kelleher, HCA Executive Director

Statement from the National Association for Home Care & Hospice (NAHC):

“NAHC has long supported reforms that increase access to health care for all in the United States and supports health delivery reforms and the expansion of Medicaid eligibility. The ACA rightly shifts the focus of care from inpatient services and institutional care to the community setting, which home health agencies and hospices have effectively served for decades.

NAHC believes that the Affordable Care Act can and should be improved. Accordingly, NAHC will continue to work with both Democrats and Republicans to improve the legislation. NAHC will ask that its implementation date be delayed for two years so that states have the time to prepare for implementation, including the creation of exchanges. This delay will also save approximately $200 billion, which can be applied to deficit reduction, extending the SGR “doc fix” and avoiding the need for any further cuts to Medicare. NAHC will continue to argue that home health care has been cut disproportionately and will oppose the imposition of copayments or additional cuts. NAHC believes that a good case can be made for expanding the scope of Medicare home health services to reduce hospitalization costs and improve services for the 5 percent of Americans who are responsible for 50 percent of total U.S. health care costs.”

-Val Halamandaris, NAHC President

Here are other statements from the following organizations:

And statements from political leaders:

Return to www.thinkhomecare.org.

CMS’ Hospice Quality Reporting Data Training Webinars Available

Video files and Q&A from the CMS Hospice Quality Reporting Data Collection Training webinars conducted in April are now available. There are two zip files located under Related Links on the Hospice Quality Reporting Spotlight Section webpage. One zip file contains four versions of the structural measure training videos and the other zip file contains four versions of the NQF #0209 measure training videos. There are four versions of each section of the training so hospices may choose to view either captioned or uncaptioned versions using either MP4 or Windows Media Video. The Q&A are located in the Downloads section on the same page.

ACA Mandate Ruled Constitutional

In Plain English: The Affordable Care Act, including its individual mandate that virtually all Americans buy health insurance, is constitutional. There were not five votes to uphold it on the ground that Congress could use its power to regulate commerce between the states to require everyone to buy health insurance. However, five Justices agreed that the penalty that someone must pay if he refuses to buy insurance is a kind of tax that Congress can impose using its taxing power. That is all that matters. Because the mandate survives, the Court did not need to decide what other parts of the statute were constitutional, except for a provision that required states to comply with new eligibility requirements for Medicaid or risk losing their funding. On that question, the Court held that the provision is constitutional as long as states would only lose new funds if they didn’t comply with the new requirements, rather than all of their funding.

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