Tag: Medicare

HCA Issues Statement on Home Care Copay Proposed by President

In response to President Barack Obama’s proposal to impose a co-payment on Medicare home health services, the Home Care Alliance has issued a release to the press. Any home care agencies or concerned advocates is encouraged to follow up with local media and make the public aware of this proposal.

Below is the Home Care Alliance’s statement:

President Proposes Home Health Copays to Help Reduce Federal Deficit

Industry Calls Copayments an Inappropriate Burden and a Tax on Most Vulnerable Elders

Boston, MA – With the debate over the federal budget debt ceiling heating up, the Home Care Alliance of Massachusetts has joined organizations from across the nation in vehement opposition to President Barack Obama’s proposal to impose co-payments for Medicare Home Health Services.

What began as a recommendation to Congress by the Medicare Payment Advisory Committee (MEDPAC) is now entrenched in discussions over how the country will raise revenues and reduce spending.

“It has been shown in many studies that copayments are an inefficient and regressive ‘sick tax’ that falls most heavily on the poorest and oldest Medicare beneficiaries,” said Patricia M. Kelleher, the Executive Director of the Home Care Alliance of Massachusetts. 

Congress eliminated home health copayments in 1972 as part of a Medicare modernization effort that concluded that such copayments fell disproportionately on the home health users with the highest Medicare expenses and the worst health status. Moreover, they discouraged using home health in lieu of more expensive nursing facility stays. As recently as 2003, Congress rejected a home care co-pay proposal for the same reasons.

President Obama’s proposal calls for a copayment of $100 per Medicare episode and excludes Medicare episodes immediately following a hospital stay. The measure would only apply to new beneficiaries beginning in 2017 and is estimated to save approximately $400 million over 10 years.

“Imposing of a copayment would continue an assault on the Medicare home health benefit that witnessed $39.7 billion in cuts passed by Congress last year,” said Kelleher. “Additionally, on January 1, 2011, Medicare added a new impediment to accessing services by requiring that homebound elderly and disabled patients, as well as hospice patients, will now need to have a ‘face-to-face encounter’ with a physician or nurse practitioner in order to receive home health services under Medicare.”

Most home health users are age 75 or older and in very poor health.  A Commonwealth Fund Report recently found that individuals of all incomes with fair or poor health status or age 85 and older spent almost 30 percent of their income already on uncovered medical care, primarily due to Medicare gaps, deductibles and copayments. Additional publications, including the New England Journal of Medicine, have released findings that an increase in such copayments lowers utilization and increases hospitalizations.

“Home health agencies in Massachusetts have supported aggressive efforts to slow growth of home health spending, including testifying in support of a moratorium on new agencies,” said Kelleher. “Asking patients to pay more is not the answer.”   

Return to www.thinkhomecare.org.

Advocacy Needed During August Recess to Avoid Cuts and Co-Pays

A so-called Debt Reduction Super Committee evolved out of the federal debt ceiling debate and will be charged with reducing the federal deficit over the next ten years.

Although cuts to entitlement programs and home health co-payments are on the table as options, a potential bright spot was reported this week in that US Senator John Kerry (D-MA) is among the members appointed to the Super Committee. Kerry was instrumental in getting cuts to home health reduced as part of health care reform.

Even with the work of Senator Kerry, Medicare home health payments are still taking a $39.7 billion hit over the next ten years. Additionally, CMS is proposing a 5.06% reduction in payments for calendar year 2012. Both of those points need to be raised when this committee considers even deeper cuts that could drastically impact agencies and patients.

Home health co-pays are another option that must be broadly opposed. Seniors could be forced to pay as much as $150 per 60-day episode of home health care, which would only push those who cannot afford it or unwilling to pay into costlier care.

Below are issues and materials that advocates can use to contact the Massachusetts Congressional Delegation, not just during August recess, but as the discussion of the Super Committee progresses. There are also materials and advocacy messages that can be used to urge Congressional support of other home care initiatives.

Advocates should be contacting their Congressperson, as well as Senator Kerry, to ask that they in turn urge the Super Committee to oppose home care cuts and copays.

Home Care Co-Pays & Medicare Cuts:

Support Home Health Access Protection Act:

Support Home Health Planning Improvement Act:

See a list of other issues, talking points, and messages available on the HCA Legislative Action Center. You can also compose your own message here.

Return to www.thinkhomecare.org.

 

CMS Responds to Congressional Letter on MD Face-to-Face

Congressman Jim McGovern, along with the rest of the state’s Congressional Delegation, received a response to a letter sent to the Centers for Medicare and Medicaid Services (CMS) that reflected the struggles of home health providers in Massachusetts relative to the physician face-to-face encounter requirement.

Unfortunately, the response from CMS is mostly a reiteration of the reasoning behind the rule and a commitment to monitor the implementation of the policy “to ensure that there are no unintended disruptions in access to medically necessary home health care for our beneficiaries.”

For more on the Physician Face-to-Face Encounter Requirement, see previous posts on the subject.

Return to www.thinkhomecare.org.

OIG Examines Hospice Services for Nursing Facility Residents

A new report from the Office of Inspector General has found that Medicare spending on hospice care for nursing facility residents has grown nearly 70 percent since 2005.  Many hospices had a high percentage of their beneficiaries residing in nursing facilities, and most of these hospices were for-profit. Compared to hospices nationwide, these high-percentage hospices:

  • received more Medicare payments
  • had a longer average length of stay
  • served Medic are patients whose diagnoses required less complex care
  • served more patients who already lived in nursing facilities before they elected hospice care.

A previous OIG study published in September, 2009, concluded that Eighty-two percent of hospice claims for beneficiaries residing in nursing facilities did not meet Medicare coverage requirements.

The OIG report notes that Medicare currently pays hospices the same rate for care provided in nursing facilities as it does for care provided in the home, but nursing facilities are staffed with professional caregivers and are often paid by third party payers, such as Medicaid. These facilities are required to provide personal care services, which are similar to hospice aide services that are paid for under the hospice benefit.

The OIG concluded that some hospices may be seeking beneficiaries with particular characteristics, including those with conditions associated with longer but less complex care. Such beneficiaries are often found in nursing facilities. By serving these beneficiaries for longer periods, the hospices receive more Medicare payments, which can contribute to larger profits.

The OIG report recommends that CMS (1) monitor hospices that depend heavily on nursing facility residents and (2) modify the payment system for hospice care in nursing facilities. CMS concurred with both of our recommendations. It also agreed that the current payment structure may provide incentives for hospices to seek out beneficiaries in nursing facilities, who often receive longer but less complex care

The OIG website has a special page devoted to Medicare hospice issues.  The page includes links to the new report, a podcast interview with Jodi Nudelman, the Region II Inspector General for Evaluation and Inspections, and several other OIG studies of hospice issues.  This is the first in a series of three studies by the OIG of hospice services to nursing facility residents.  Additional studies will examine the marketing practices of hospices that focus on nursing home residents and the business relationships of such hospices with nursing facilities.

Return to www.thinkhomecare.org.

CMS Community-Based Care Transitions Program Update

The Centers for Medicare and Medicaid Services (CMS) has provided new guidance and updates on their Community-Based Care Transitions Program.https://i0.wp.com/www.gmcf.org/transitions/images/transitions_image.jpg

New panel review dates for submitting applications beyond August 18th have been posted and are as follows:

  • October 6 & 7, 2011 – Applications must be received by September 6th to be considered for this review.
  • November 15 & 16, 2011 – Applications must be received by October 14th to be considered for this review.
  • November 30 & December 1, 2011 – Applications must be received by October 28th to be considered for this review.

Secondly, more than a full page of new guidance has been added to the program’s Question & Answer section. Below are a few examples:

  • Q: How shall we anticipate to cover up front costs? I heard that CBOs would be paid a per eligible discharge rate that is determined by target population, interventions proposed, anticipated volume and expected reduction in readmissions (cost savings) Can you give a concrete example of how this payment methodology would work?

A: Because this program seeks to build off of earlier care transitions initiatives and requires applicants to have a track record in the delivery of care transition services we are not paying “start up” costs. CBOs will be paid on a monthly basis for services delivered in the previous month. This payment will be whatever the agreed upon per eligible discharge rate is multiplied by the number of eligible beneficiaries served in the previous month. Please refer to the budget worksheet available on our program webpage for additional guidance on developing the per eligible discharge rate.

A: These are the patient experience measures that CBOs will be required to collect and report during the program. We will provide the instruments to awardees at the time of award.

The Home Care Alliance has also made a webinar available on the experiences from a previous CMS care transitions demonstration program that worked through 14 QIO’s across the US. The webinar focuses on, among other things, drawing from the Home Health Quality Improvement campaign’s Best Practices Intervention Package.

More info from this newsfeed on care transitions is available here.

Return to www.thinkhomecare.org.

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.

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.

 

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.

Return to www.thinkhomecare.org.

 

New Materials and Guidance for CMS Care Transitions Program

A pair of presentations with helpful information and resources regarding the CMS Community-Based Care Transitions Program have been made available.

For home health agencies interested in applying or just getting started with the process, this CMS PowerPoint provides a good summary of the information, helpful links and resources, and answers to some of the more frequently asked questions.

Another helpful set of presentations sponsored by the Commonwealth Fund is available and includes a webinar with audio featuring:

  • Anne-Marie Audet, M.D., M.Sc., moderator, vice president, Quality Improvement and Efficiency, The Commonwealth Fund
  • Eric Coleman, M.D., M.P.H., director, Care Transitions Program, and professor of medicine at the University of Colorado Health Sciences Center
  • Garry MacKenzie, M.D., medical director of cardiology services at McKay-Dee Hospital Center in Ogden, Utah
  • Janice Fitzgerald, R.N., director of quality and medical management at Baystate Medical Center in Springfield, Mass.
Lastly, there have been a lot of questions regarding how to proceed with the “root cause analysis” in the application. A very helpful resource to assist in this matter is available courtesy of the Care Transitions Quality Improvement Organization Support Center (QIOSC).
More updates and resources will be provided by the Home Care Alliance as they become available.

New CMS Care Transitions Program Q&As, Open Door Forum

The Centers for Medicare and Medicaid Services (CMS) have released a new round of Questions & Answers in regards to the Community-Based Care Transitions Program.

See the full list of these helpful Q&A’s here, and below are a couple of the newest posts that may be of interest to home health agencies. One in particular about whether some of the responsibilities of the lead applicant can be subcontracted to other entities.

There is also an “open door forum” scheduled for May 5 and the Home Care Alliance strongly encourages all interested agencies to register and participate.

Yes that is acceptable; however, the applicant would need to demonstrate that each proposed subcontractor possessed expertise in the delivery of care transition services.

Experience with chronic care management/disease management is not synonymous with care transitions experience. The per eligible discharge rate is meant to cover a relatively short term intense intervention around admission to and discharge from an acute care hospital. This rate would not support an ongoing chronic care management program which usually requires a per member per month payment for an indefinite period.

Return to www.thinkhomecare.org.