Alliance Comments to CMS on CY2022 Home Health Rule

To ensure that home health agencies in Massachusetts can provide high-quality care to older adults, the Home Care Alliance of Massachusetts has submitted comments to the federal government regarding the proposed rule for next year’s Medicare home health rates. Our comments to the Centers for Medicare and Medicaid Services (CMS) address several sections of the proposed rule, including:

  • CMS’s flawed reasoning behind the -4.36% “behavioral adjustment” to the rates;
  • Concerns about a budget neutrality adjustment based on 2020 data skewed by COVID;
  • A market basket adjustment that does not account for ongoing costs related to COVID;
  • Protections for counties with large wage index reductions;
  • Modifications to the Value Based Purchasing model before it is implemented nationwide;
  • Greater flexibility around the five-day deadline to submit the new Notice of Admission;
  • Greater flexibility to allow therapist to conduct initial assessments; and
  • Expanded allowances for virtual aide supervisions.

HCA Breaks Down MassHealth 1115 Waiver Proposal

Months of stakeholder meetings and public engagement by MassHealth has resulted in a long-awaited draft proposal that aims to completely restructure the state’s Medicaid program.

Known as the Section 1115 Waiver, the 90-plus page document outlines a possible multi-year agreement  with the federal Centers for Medicare and Medicaid Services (CMS). The focus of the proposal is a move towards accountable care organizations (ACOs) and alternative payments while better addressing the needs of MassHealth members and putting in place a financially sustainable system of health care and support services.

Before the agreement can be made with CMS, however, there is a public comment period that runs until July 17th. The Home Care Alliance created a breakdown of the proposal so that members and advocates can better understand the key provisions.

MassHealth also provided a more basic fact sheet available on their 1115 Waiver Proposal webpage that also includes the full document and slide decks from previous public meetings.

The proposal attempts to seize an opportunity for new funding streams to support the creation of three types of ACOs that are required to partner with existing providers of behavioral health (BH) and long-term services and supports (LTSS). The state aims to rearrange provider and managed care relationships to set forth a better coordinated and integrated set of networks.

The first “pilot ACOs” are expected by MassHealth to come online later in 2016, while the full roll-out of the three ACO models, enhanced funding, and BH/LTSS integration will take place in October 2017.

The Alliance was appointed to several of the MassHealth stakeholder groups and plans to submit comments on the proposal on behalf of home care.

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HCA Applauds Tele-monitoring Support from MassHealth

After years of advocacy with the legislature and working collaboratively with MassHealth, the Home Care Alliance proudly testified at a public hearing on proposed remote patient monitoring (RPM) payment rates and regulations this week.

Alliance Legislative and Public Affairs Director James Fuccione commented that reimbursement for RPM will strengthen the ability of home health agencies to carry out their mission of keeping people healthy at home and commended MassHealth for including a broad definition that will allow agencies to be creative in their use of the service. Dana Sheer, NP of Partners Healthcare at Home, also submitted comments in support of RPM and offered recommendations on clarifying language.

The Alliance asked for clarification on a number of points, including whether an “installation/removal” fee of $50 would be paid by MassHealth for both or on each end of the set-up and removal of RPM equipment. HCA suggested that the fee be raised to $75 and paid on both ends. Additionally, the Alliance asked for guidance on how to proceed when multiple patients in the same setting could benefit from RPM services. Comments from the Alliance suggested that RPM could go a long way in assisting patients with behavioral health and substance abuse issues as well.

In his testimony, Mr. Fuccione raised the ongoing concern regarding MassHealth rates for nursing, therapy, and home health aide visits, and urged MassHealth to expedite a review and update of those rates.  He noted that the Alliance has had several recent meetings with MassHealth staff focusing on that very subject. However, the hearing was centered on the tele-monitoring proposal and the Home Care Alliance is thrilled to have spearheaded the push for reimbursement.

Massachusetts is one of only a few state Medicaid programs with financial support for RPM, which will be effective this November. MassHealth explained at the hearing that they expect a savings just within the home health program of $1.4 million.

The Alliance’s comments are available here and more updates on any changes MassHealth may make based on our comments will also be sent to member agencies.

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Advocacy Alert: Email State Reps to Gain Support for Home Care in the House Budget!

The Home Care Alliance has been busy working with state representatives to file amendments to the recently released House version of the state’s FY16 budget. Now that those proposals are submitted, it is time to gain crucial support by asking other reps to cosponsor these amendments.

The amendments include the following proposals:

  • An increase in MassHealth rates for visiting nurses (filed by Rep. Sean Garballey)
  • Creating a commission to study state oversight options for private-pay home care agencies (filed by Rep. Mark Cusack)
  • An increase in MassHealth rates for home health aide services (filed by Rep. Chris Walsh)
  • A study of MassHealth’s Third Part Liability Billing process (filed by Rep. Paul Brodeur)

Agencies and advocates can send an email through HCA’s Advocacy Center just by clicking on the message, filling out the contact info form, and hitting “send.” The message will automatically shoot off to the correct Representative based on the address you enter.

Private pay home care agencies can send their own message for just the Study Commission language here, or a message can be sent for all the Alliance’s priorities here.

Any questions can be directed to James Fuccione at the Alliance.

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FY16 State Budget Plan Released by House

The House Committee on Ways & Means released their version of the state’s fiscal year 2016 budget with most accounts important to home care level funded. Out of the $38 billion in the proposed budget, $15.3 billion is spent on MassHealth, the state’s Medicaid program.

Since language proposed by the Home Care Alliance to establish a commission to study options for agency oversight was not included, the HCA will be working with state representatives to file amendments to the budget for a number of items, including establishing commissions to study and make recommendations on state oversight options for private pay agencies and certified agencies. The Alliance will also be seeking an increase of $3.1 million in payment rates for home health aides as well as a restoration of MassHealth home health nursing rates.

The Alliance will also be supporting a number of budget amendments spearheaded by other organizations to raise home care worker wages, seek relief from the impending paid sick time mandate and restore the line item funding the Nursing and Allied Health Education Workforce Development program.

Additionally, the Alliance will support efforts to increase funding for elder home care purchased services from Aging Service Access Points. The House Ways & Means budget reduced that line item from what the Governor proposed earlier this year by more than $3 million.

Stay tuned as the Alliance will be sending out advocacy alerts on how agencies and advocates can urge support of these important issues.

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Governor Releases State Budget Proposal With MassHealth Savings

In his first budget as governor, Charlie Baker’s administration made sizable shifts within Health and Human Services, which accounts for 53 percent of the overall budget proposal. These shifts were done without negatively impacting most provider rates, including home health services.

In a conference call with provider and advocacy organizations, Executive Office of Health and Human Services Secretary Marylou Sudders announced that there was a 5.6 percent growth over FY15 in the total EOHHS budget and that line items in the Elder Affairs accounts governing the Aging Service Access Point network saw a 2.1 percent increase overall. This includes the following highlights:ma budget pie chart pic

  • A nearly $5.6 million increase over FY15 spending in the Elder Enhanced Home Care Services Program.
  • Level funding for the Home Care Purchased Services line item ($106.6 million), which governs contracts with home care providers.
  • A reduction of $13.7 million in the MassHealth Senior Care Account that includes, among other things, the Senior Care Options or SCO program. On the call with Secretary Sudders, it was explained that this was an adjustment on caseloads after re-determinations.
  • A continued reduction ($68,360,305) in MassHealth Fee-for-Service payments to “meet projected need.”
  • An increase of $768,713,676 in MassHealth Managed Care spending.
  • Level funding of grants to councils on aging and to the elder nutrition program.
  • A nominal increase in spending over FY15 on Pediatric Palliative Care.

For more information on the Governor’s proposed budget, visit the administration’s FY16 budget webpage.

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State Budget Process Moves to Conference Committee

As expected, the House and Senate Chairs of their respective Committees on Ways and Means will co-chair a six-member conference committee that will work out the differences between the House and Senate budget plans.

The House-approved plan calls for $36.32 billion while the Senate plan was set at $36.4 billion. Although they are similar in terms of total amounts, there are some important differences in both funding support and policy changes.

The Home Care Alliance sent a letter outlining those differences as they pertain to home care services in a letter to each conference committee member.

Here are the main bullet points from that letter where the HCA is asking for support:

  • Senate Amendment #929: Home Telehealth
    • This language was passed in the FY14 budget and allows MassHealth the policy support necessary to continue work on establishing rates and guidelines for home telehealth services.
    • Home Telehealth involves remote vital signs monitoring equipment. This service offers immediate cost savings by reducing the frequency of home health visits paid for by MassHealth, along with reduced hospitalizations through improved medication adherence, patient self-management and timely follow-up care.
  • Senate Amendment #683: Homemaker Wage Increase
    • Approved by a unanimous roll call vote in the Senate, this amendment increases pay by approximately $.75 cents per hour for homemakers and personal care homemakers serving clients enrolled in the Executive Office of Elder Affairs Home Care Program.
  • Senate Outside Section Relative to the Home and Community-Based Services Policy Lab
    • This language and corresponding funding would support the study of the cost-effectiveness of state-funded home and community-based services.
  • House Support for Elder Services Home Care Purchased Services (9110-1630)

The Alliance encourages home care agency members and advocates to contact the conference committee this week to ask for their support using the bullet points above. Here are the names and contact info for conference committee members:

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Upcoming One Care Shared Learning Conference

MassHealth and UMass Medical School are hosting a One Care Shared Learning Conference at three different locations across the state in early June.

June 3, 2014 June 10, 2014 June 18, 2014
7:30 A.M. – 1:00 P.M.
Springfield Marriott
2 Boland Way,
Springfield, MA 01103Register for the
Springfield Conference
Before May 23, 2014
7:30 A.M. – 1:00 P.M.
Best Western Royal
Plaza – Marlborough
181 Boston Post Rd. W,
Marlborough, MA 01752Register for the
Marlborough Conference
Before May 27, 2014
7:30 A.M. – 1:00 P.M.
Four Points by
Sheraton – Norwood
1125 Boston Providence Turnpike,
Norwood, MA 02062Register for the
Norwood Conference
Before June 4, 2014

This conference will focus on “Integration of Primary Care, Behavioral Health and Community Supports in Real Life Cases: Developing and Implementing Person-Centered Care for People with Complex Health Care Needs.”

Who should attend?

This conference is primarily for primary care providers (PCPs), behavioral health clinicians, long term services and supports (LTSS) providers – including home care agencies – and other community based organizations involved in One Care.

This conference will focus on the collaboration among the members of an integrated care team, focusing on each of their roles in developing and implementing person-centered care for people with complex health care needs. There are a limited number of spots available, and One Care plan staff and their contracted providers will be given priority.

To register for one of these conferences or for more information, visit

Download the Conference Agenda(

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Summary of Conference Call WIth Senior CMS Officials on the Face-to-Face Rule

On May 20th, the Home Care Alliance of MA, along with several member agencies, physicians and a representative from the MA Medical Society had the opportunity to speak to a number of officials at CMS regarding problems with the face to face rule.  Among those on the call from CMS were: Laurence Wilson, Director, Chronic Care Policy Group;  Carol Blackford, Deputy Director, Chronic Care Policy Group and Randy Throndset, Director, Division of Home Health and Hospice.

Below is the summary of the meeting and our suggested fixes as sent to the CMS officials in a follow-up email.  Thank you to members Judy Flynn and Dr Mark Yurkofsky, Partners Health Care at Home; Robin Seidman, Metrowest Home Care & Hospice; Dr Richard Lopez and Keren Diamond, Atrius Health/VNA Care Network/VNAB,  Jeanne Ryan, VNA & Hospice of Cooley Dickinson, and Alex Calcagno, Mass Medical Society for participating and making such a strong presentation. Continue reading “Summary of Conference Call WIth Senior CMS Officials on the Face-to-Face Rule”

State Senate Proposes $36.2 billion Budget Plan with New Opportunities for Home Care

The Massachusetts Senate’s Ways & Means Committee took their turn in the state budget-crafting process with a $36.2 billion proposal that increases total state spending by almost $1.7 billion from this year.

Although some programs in the Elder Services line items took a hit, as did the MassHealth Senior Care Account, the Senate proposed other new items that pose potential opportunity.

In what is known as an “outside section,” which is a section of an appropriation bill that can create new policies, the Senate created a Home and Community-Based Services Policy Lab. According to the language, the policy lab would start with $500,000 of state funds to evaluate and analyze the outcomes and effectiveness of home and community-based services under the Secretary of Elder Affairs. This includes the state Home Care Program administered through Aging Service Access Points (ASAP’s) that contract with Home Care Alliance members.

This “policy lab,” which appears to be a program evaluation of state government-funded home and community-based services, could be the beginning of proving the effectiveness of services such as those provided by home care agencies. More information on this will be released as details are released.

Also, in another “outside section,” the Senate Ways & Means Committee created a new Community First Trust Fund, which is intended for enhanced federal financial participation (FFP) funding for the state that is tied to the Balanced Incentive Payment program (BIP), among other programs. In a previous blog post, the HCA reported on the state’s intentions around the BIP initiative that will bring more support to non-institutional long-term care services.

More budget analysis will come out in the coming days, including the Home Care Alliance’s budget amendment priorities where HCA members can help by contacting their state senators. The Alliance plans on repeating proposals to advance telehealth in home care, better MassHealth rates, and a study commission of home health care services and possible oversight recommendations.

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