Urgent: Your Advocacy Needed on F2F Fix Now

We cant fix it without your help!!!

The Home Care Alliance of Massachusetts is working nationally on new strategy for a F2F fix in the House Appropriations Committee.

The Alliance, along with the Forum of State Home Care Associations (FSA) of the National Association for Home Care and Hospice (NAHC), is pushing on a unified front for a simple legislative fix that would provide relief from the onerous Medicare face-to-face (F2F) rule.

The  legislation would specifically allow for physician certification of the face-to-face requirement on the ‘485,’ or plan-of-care document, in place of a separate, redundant narrative requirement currently being enforced by the U.S. Centers for Medicare and Medicaid Services (CMS).

What we need from you!

Massachusetts has no Congressional representative on the House Appropriations Committee, which is where we are trying to get the language introduced.   

All HCA members should urge their Congressional representatives to reach out to House Appropriations Committee Ranking Member Nita Lowey (D-NY) seeking assurances that the face-to-face fix is included in the House Appropriations bill.

The best way to reach your Congressional Representative is to call the main switchboard at (202) 224-3121.

In addition to calling your House representative, every Alliance member should send an e-mail.  This process will only take a minute of your time. Click HERE to send a message to Congress with a push of the button.

Script for Phone Call or email

Please Help Home Care:  Insert F2F Fix in Appropriations Bill

The home care industry needs your help to fix the face-to-face encounter rule. This federal rule requires a physician to certify that he or she has seen a home care patient face-to-face for authorization of home care services. The problem is not so much the requirement itself, but CMS’  interpretation of the requirement, and its expectations for physicians to document it. A simple line of legislative language would clarify Congress’ intent for the regulation to be met with the least disruption in patient care services.

Please work with your Congressional Colleagues on the Appropriations Committee to advance this vital legislation. If you need, I would be happy to forward the draft legislation, along with further background information, to your office.

Links for More Information

Home Care Face-to-Face Mandate: A Major Problem, a Simple Fix. Use this resource to show Congressional offices how the existing 485/plan-of-care already certifies the patient’s need for home care and could include a simple edit for meeting the face-to-face mandate.

The HCA-FSA-NAHC draft legislation to fix F2F. This draft legislation simply states: “Physician documentation of the face to face encounter shall consist solely of a simple and concise confirmation that such encounter occurred and that is provided by notation on the same plan of care document the physician signs to order the home health services required by the patient.”

Thank you for your help.

Return to www.thinkhomecare.org.

 

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 www.mass.gov/masshealth/onecare/learning

Download the Conference Agenda(https://onecarelearning.ehs.state.ma.us/pdf/One-Care-Conference-Flyer-Agenda.pdf

Return to www.thinkhomecare.org.

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”

ODF for Home Health and Hospice, March 5th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday,, March 5, 2014 at 2:00 PM

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 71246014

Proposed Agenda

1. Opening Remarks

2. Announcements & Updates

  • Hospice and Part D
  • Hospice Claims Reporting
  • Hospice & CAHS
  • Hospice Quality Update
  • FY2015 and FY2016 reporting cycles
  • Hospice CAHPS survey
  • HH CAHPS
  • Home Health Quality Update

For details visit the ODF Website

Return to www.thinkhomecare.org.

Medicare Advantage Cuts Proposed

A national trade association of health insurers, America’s Health Insurance Plans, is strongly protesting a new round of proposed cuts to 2015 Medicare Advantage payment rates. Preliminary estimate of the combined effect of the Medicare Advantage growth percentage and the fee-for-service growth percentage is estimated to be -1.9 percent,” CMS said Friday in releasing their proposed rule.

“The new proposed Medicare Advantage cuts would cause seniors in the program to lose benefits and choices on which they depend.  Last year’s six percent cut to Medicare Advantage rates resulted in higher premiums, reduced benefits, fewer coverage options, and loss of provider choices for seniors.  Another round of payment cuts would be devastating to the more than 15 million seniors and people with disabilities that have chosen to enroll in Medicare Advantage for the better benefits and higher quality coverage these plans provide.
The politics of Medicare Advantage are expected to be an issue in some upcoming elections, according to Washington observers.

 

CMS Reopens Bundled Payment Initative for Post-Acute Care

The Bundled Payments for Care Improvement initiative, developed by the Center for Medicare and Medicaid Innovation, has been reopened for additional models focusing on post-acute.

Through the initiative, organizations partner together and enter into payment arrangements that include financial and performance accountability for episodes of care. There four models of bundled payment being tested, but models 2 and 3 are areas where home health agencies can play a central role.

  • Model 2 is titled Retrospective Acute Care Hospital Stay plus Post-Acute Care, where the episode of care includes the inpatient stay in the acute care hospital and all related services during the episode.
  • Model 3 is Retrospective Post-Acute Care Only, where the episode of care is triggered by an acute care hospital stay and begins at initiation of post-acute care services with a participating home health agency, skilled nursing facility, inpatient rehabilitation facility, long-term care hospital.

More information on the program and the “open period” where new proposals can be submitted is available here. In order to be considered for participation in the Bundled Payments for Care Improvement initiative, all open period submissions must be submitted by April 18, 2014.

Return to www.thinkhomecare.org.

Controversial Hospice Article Draws Response

photo credit: NY Times/Ruby Washington

Once again, the actions of the few bad actors in home health and hospice are getting media attention rather than the vast majority of agencies that are devoted to providing high quality care to keep people comfortable and at home.

In an investigative report, the Washington Post highlights findings that the number of patients discharged alive from hospice rose by 50 percent between 2002 and 2012. The article also highlights numbers from the Medicare Payment Advisory Commission (MedPAC) stating that in 2011, nearly 60 percent of Medicare’s hospice expenditure of $13.8 billion went toward patients who stay on hospice care longer than six months. The article singles out for-profit hospices in particular, but still puts all hospices in a negative context.

In fact, the article has prompted responses from the National Association for Home Care and Hospice (NAHC) as well as the National Hospice and Palliative Care Organization (NHPCO). In a letter to the editor, NAHC ends their rebuttal by writing:

We must all do our part to ensure that hospice remains a viable choice for terminally ill patients and their loved ones.  Articles of this type may unwittingly discourage use of hospice care, thereby denying terminally ill patients and their families access to vital services that support and comfort them during and in the aftermath of one of life’s most difficult journeys.  Under these circumstances, no one is well served.

The New York Times’ “New Old Age Blog” digs much deeper into the Washington Post’s findings and notes the many layers to the issue and why those numbers may have surfaced. For instance, the blogger writes:

What’s happening here? Hospices have lamented for years that dying patients wait too long to call, enrolling at the eleventh hour when they could have benefited months earlier. Now, we’re hearing more about patients doing as hospice believers (including me) have urged, calling earlier in the course of a terminal disease — and then, in a substantial minority of cases, getting bounced.

Return to www.thinkhomecare.org.

National Association Provides Update on Rebasing, SGR

The National Association for Home Care & Hospice (NAHC) held a conference call revealing a frantic final week of advocacy activity before Congress takes its holiday recess until the New Year.

The major part of that activity for home health agencies centered around the attempt to delay the impacts of Medicare “rebasing” cuts through an amendment to the Medicare Sustainable Growth Rate (SGR) fix – also known as the physician fix.

Senator Debbie Stabenow (D-MI) offered an amendment on behalf of home care that would delay the cuts for one full year and give the industry the chance to lobby CMS to change their methodology with more updated and accurate data. Unfortunately, part of the compromise of the short -term physician fix was that it was a “clean” bill, which means no outside amendments. According to NAHC, even the hospital industry had amendments that were proposed and then withdrawn because of that agreement between Democrats and Republicans.

The short-term SGR fix will last for three months and must be offset by $7 billion. The good news there is that none of the offset is coming from the home health industry. Some of the hit is being hit is being absorbed by cuts to Long Term Care Hospitals and Disproportionate Share Hospital rates, but copays and additional reductions for home care  were avoided.

The light at the end of the tunnel comes from the fact that the Senate is working on a permanent SGR fix and the Stabenow amendment will still be in play for that effort. In addition, NAHC was successful in getting language from the FITT Act into the Senate’s proposal. The FITT Act essentially establishes a national pilot program for home-based telemonitoring provided by home health agencies. It will not be straight reimbursement, but is meant to be a shared savings approach where the providers and Medicare will share in any efficiencies gained. Moreover, if the program is successful, NAHC indicated that the program could be expanded by Medicare without going back to Congress for approval since it is a pilot and not a demonstration.

In terms of hospice care, NAHC also reported that another amendment would allow physician’s assistants to serve as the attending physician for hospice patients.

All of these wheels will be in motion in the New Year, but the main idea is that Democrats and Republicans compromised on a two-year deal that keeps the federal government running and it was done without implementing co-payments for home care. The 2% sequester cuts are extended for an additional two years, but those are not “new” cuts and are simply to make the budget scoring work. By the time the extended years are reached, the sequester could potentially be a thing of the past.

The Home Care Alliance thanks agencies for sending nearly 200 messages to the Massachusetts Congressional Delegation in two days. That education and advocacy will be critical as we move forward to fight rebasing in the New Year. Of course, further information will be provided as it becomes available.

 

Return to www.thinkhomecare.org.

 

Advocacy Alert: Contact Congress Re: Amendment Delaying Rebasing Cuts

Congress is working in the final days before the holiday recess on a long-term Medicare Sustainable Growth Rate (SGR) process and an amendment to that process could delay the impending rebasing cut to home health care.

The Alliance is asking that agencies and advocates contact their Member of Congress TODAY to educate them about the amendment and what it means for Medicare home health agencies. U.S. Capitol Building

Senator Debbie Stabenow (D-MI) has offered an amendment that essentially delays the effects of rebasing so that CMS can hopefully adjust their methodology with updated and more accurate data. Educating the Massachusetts Congressional Delegation is crucial to getting support for the amendment as there is so much happening in the final two days of activity.

More information and a prepared email message is available on HCA’s Legislative Action Network and it only takes a minute to log on and add your voice to this critical push to delay a damaging 3.5% cut per year over the next four years.

We also urge members to call the offices of your Congressional representatives directly using the message below as a guide. Simply call the main switchboard at (202) 224-3121, request a transfer to the office of your Congressional representative, and ask to speak to the individual from that office that is responsible for health policy.Here is the text of the message to Congress if you choose to call:

The U.S. Centers for Medicare and Medicaid Services (CMS) has finalized a rule imposing unprecedented Medicare home health reductions under a process called “rebasing.” All told, the impact on providers will be a $200 million cut in each of the next four years.

We are asking for your support in backing an amendment from Senator Debbie Stabenow as well as any corresponding effort in the House to amend the Medicare Sustainable Growth Rate (SGR) process.

These are the largest cuts to home health in decades, and they will cause many agencies to close their doors, especially if these cuts are compounded by Medicare reductions via the continuing budget resolution. Such cuts are counter-productive at a time when health reform relies on cost-effective care at home to serve vulnerable citizens.

CMS’s rebasing cuts were finalized on November 22 and go into effect on January 1. This leaves little time to delay these disastrous cuts and compel CMS to conduct a more fair, accurate and thorough analysis of its fiscal assumptions.

The data is clear. Many Medicare-certified home care providers are already operating in the red across all sources of payment. These new cuts – scheduled to be compounded for each of the next four years – will cripple the industry and create barriers to care. Yet, despite similar trends across the country, CMS concludes that draconian rebasing reductions are needed to eliminate positive margins in home health. CMS’s math simply does not add up.

Many in Congress agree. A bipartisan letter sent to CMS raised strong concerns, stating that the rebasing methodology relies on “incomplete data and analysis that results in the under-counting of home health agencies’ costs per episode of care, and an inappropriately high rebasing adjustment.”

Home care providers nationwide thank you and your colleagues in Congress for your strong stance on rebasing and we ask for your continued active engagement supporting Senator Stabenow and others to delay rebasing and initiate a more rational approach from CMS.

Thank you.

Return to www.thinkhomecare.org

CMS Presents Jimmo v. Sebelius Manual Update

CMS is conducting a call on program manual updates related to the Jimmo v.Sebelius law suit on the CMS MLN Connects,  Thursday, December 19th at  2-3pm ET.  The program title is Program Manual Updates to Clarify SNF, IRF, HH, and OPT Coverage Pursuant to Jimmo v. Sebelius

To Register: Visit MLN Connects™ Upcoming Calls. Space may be limited, register early.

Agenda

  • Clarification of Medicare’s longstanding policy on coverage for skilled services
  • No “Improvement Standard” is to be applied in determining Medicare coverage for maintenance claims that require skilled care
  • Enhanced guidance on appropriate documentation

On January 24, 2013, the U. S. District Court for the District of Vermont approved a settlement agreement in the case of Jimmo v. Sebelius, involving skilled care for the inpatient rehabilitation facility (IRF), skilled nursing facility (SNF), home health (HH), and outpatient therapy (OPT) benefits. “Nothing in this Settlement Agreement modifies, contracts, or expands the existing eligibility requirements for receiving Medicare coverage.”

The goal of this settlement agreement is to ensure that claims are correctly adjudicated in accordance with existing Medicare policy, so that Medicare beneficiaries receive the full coverage to which they are entitled. The settlement agreement sets forth a series of specific steps for CMS to undertake, including issuing clarifications to existing program guidance and new educational material on this subject.

As part of the educational campaign, this MLN Connects™ Call will provide an overview of the clarifications to the Medicare program manuals. These clarifications reflect Medicare’s longstanding policy that when skilled services are required in order to provide reasonable and necessary care to prevent or slow further deterioration, coverage cannot be denied based on the absence of potential for improvement or restoration. In this context, coverage of skilled nursing and skilled therapy services “…does not turn on the presence or absence of a beneficiary’s potential for improvement, but rather on the beneficiary’s need for skilled care.” Portions of the revised manual provisions also include additional material on the role of appropriate documentation in facilitating accurate coverage determinations for claims involving skilled care. Target Audience
Skilled Nursing Facilities; Inpatient Rehabilitation Facilities; Home Health Agencies; and providers and suppliers of therapy services under the Outpatient Therapy Benefit