Tag: Medicare

Issue:

The Home Care Alliance is asking all Medicare-certified agencies to submit comments on the Proposed Rule issued by CMS on July 16, 2010, which addresses a variety of subjects that raise numerous concerns for home health services. These matters include:

• 2010 HH PPS payments rates with a 3.89% case mix creep adjustment
• New standards for therapy coverage, patient assessment, and documentation
• Requirements for physician face-to-face encounters for care plan certification
• Modifications of the 36-month rule on ownership changes
• Modification of claims coding and data collections
• Consumer Assessment of Healthcare Providers and Systems (CAHPS) implementation

Case Mix Background:

CMS has implemented three case mix weight change adjustments to date—2.75% rate reductions in each of 2008, 2009, and 2010. It planned on an additional reduction of 2.71% in 2011. In its recent Proposed Rule, CMS proposes to increase the 2011 adjustment to 3.79% and to add a further 3.79% adjustment in 2012.

With these adjustments NAHC estimates that nearly 45% of home health agencies would receive Medicare payments that are below the cost of care. These rate cuts are in addition to the projected $39.7 billion in cuts coming from the 2010 federal health care reform legislation.

Action:

Please make sure you send your comments on these matters to three places:

1) CMS

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.”

2)      The Home Care Alliance of Massachusetts

3)      Your Congressperson

Also, please contact your congressperson and urge their support of the Home Health Planning Improvement Act and the Home Health Access Protection Act.

Aside from the obvious destination of sending comments to CMS, it is important for the Home Care Alliance to compile testimony for federal advocacy. Information is vital in making the argument against case mix adjustments, face-to-face encounters for care plan approval, and etcetera.

In addition, your agency sending comments to your Congressperson and asking that they in turn assist in this process is another very important step. HCA will follow up with your elected official once we have received your comments, but it is important for them to hear from businesses in their district that deliver care to their constituents.

Comments to CMS are due by September 14, and agencies are encouraged to have staff, patients and their families submit comments on these matters as well. The Home Care Alliance will have testimony available for agencies to view at least two weeks prior to the deadline.

Please contact James Fuccione at the Home Care Alliance if you have any questions.

Return to www.thinkhomecare.org.

The Home Care Alliance joined agencies and organizations from across the country in submitting comments on the Interim Final Rule requiring physicians enroll in PECOS (Provider Enrollment, Chain and Ownership System).

The Alliance submitted comments because the regulation change, although directly related to physicians, would prohibit home health agencies from submitting claims to Medicare for reimbursement if the physician was not enrolled in the online PECOS system.

Due to inquiry from federal elected officials, letters and comments, the Centers for Medicare and Medicaid Services (CMS) issued a notice clarifying that they will, “for the time being, not implement changes that would automatically reject claims based on orders, certifications, and referrals made by providers that have not yet had their applications approved by July 6, 2010.”

The notice continued that “While the regulation will be effective July 6, 2010, CMS will not implement automatic rejections of claims submitted by providers that have attempted to enroll in PECOS.  However, until the automatic rejections are operational, providers should not see any change in the processing of submitted claims, they will continue to be reviewed and paid as they have historically been reviewed and paid.”

The Home Care Alliance’s comments call for a delay in the implantation of the regulation to October 1, 2010 and also to hold home health agencies and other Medicare part B providers harmless for claims submitted prior to that date for services ordered by physicians not listed in PECOS.

To take action, fill out this form and send an email to your federal elected officials.

Return to www.thinkhomecare.org.

For those looking to comment on the PECOS (Provider Enrollment, Chain and Ownership System) issue, visit this link on regulations.gov and click on “submit comment.”

HCA strongly suggests that members also send a message to Congress (scroll all the way down to the last message on the list) and call the office of Senator John Kerry and US Representative to follow up on the Alliance’s letter and alerting their offices to the timeliness and urgency of the matter.

If you’re unsure who represents you in the US House of Representatives, click here.

Return to www.thinkhomecare.org.