New PDGM Educational Material Now Available!

In a partnership with the National Association for Home Care, we are pleased to extend to you a special NAHC discount on several PDGM educational offerings. As a member of HCA of MA, you will receive the NAHC member rate* when you purchase any or all of the following:  1) the PDGM: Strategies for Success in 2020 and Beyond video;  2) the individual webinars;  3) seven-part Webinar Series;  or 4) the package,  which includes both the PDGM Video and the PDGM Webinar Series – at an unbeatable price!

Registration includes giving your entire team access to these materials. Each individual can access them separately or you can use them for a group education.  It’s  up to you!

Click on the links below to get started!

For one low price, you and your entire team will have access to these materials, access them separately or as a group, it’s up to you!

Click on the links below to get started!

PDGM Video

We’ve developed an intensive, in-depth, online training that will prepare you and your entire Medicare home health agency to transition smoothly and successfully to PDGM in 2020 and beyond. If you weren’t able to attend one of the 12 National Summits across the country, don’t worry. PDGM: Strategies for Success in 2020 and Beyond features the same top PDGM experts who educated thousands at our National Summits, and you can learn their insights without leaving your home or office. Even better, for one low price all of your staff can receive the training they need. Purchase the video

Webinar Series

These webinars will be recorded for access anytime and anywhere.  For descriptions and objectives, click here

PROMO CODE FOR INDIVIDUAL WEBINARS: PDGM-Ind-MA01

Date & Time Title Presenter
May 2, 2019
2:00-3:00 PM ET
PDGM Practical Overview Sue Payne REGISTER
May 9, 2019
2:00-3:00 PM ET
PDGM Operations Impact: Referral Source & Intake Maria Warren REGISTER
May 21, 2019
2:00-3:00 PM ET
PDGM Operations Impact: 30 Day Periods, LUPAs, Supplies Diane Link REGISTER
June 6, 2019
2:00-3:00 PM ET
PDGM: Coding / Documentation Review / Revenue Cycle Melinda Gaboury REGISTER
July 11, 2019
2:00-3:00 PM ET
PDGM: Interdisciplinary Considerations Karen Vance REGISTER
August 15, 2019
2:00-3:00 PM ET
PDGM: Electronic Medical Record Readiness Matt Garcia REGISTER
August 16, 2019
2:00-3:00 PM ET
Clinical Management of PDGM Risks Karen Vance REGISTER

Registration

PRODUCT State Association Member Price w/ Code Register
Single PDGM Webinar (1 of 7) $99 use links above
PDGM Webinar Series (all 7) $199 PURCHASE
PDGM Video (5.5 hrs) $199 PURCHASE
PDGM Video (5.5 hrs) and PDGM Webinar Series
$349 PURCHASE

PROMO CODES ARE AS FOLLOWS:

Individual Webinar Code – PDGM-Ind-MA01

PDGM Webinar Series (all 7 webinars) Code – PDGM-MA01

PDGM Video Code  –  PDGM-MA01

Combo – PDGM Video and Webinar Series (all 7 webinars) Code – PDGM-Combo-MA01

Return to www.thinkhomecare.org.

PDGM Fix Introduced, Advocacy Needed

Last week, a bipartisan group of senators, led by Sen Susan Collins (R-ME)  introduced what will be a most important legislative priority for HCA of MA this year.  Senate bill (S.433) will curtail the so-called $1 billion “behavioral adjustment” cut under the Patient Driven Groupings Model (PDGM) to which all of home health is transitioning in 2020.  Among, many other changes, PDGM will move home health from a 60 to a 30 day payment unit. This is the most significant change to home health payment since the Prospective Payment System was introduced in 2000.

The Congressional action that called for a home health payment overhaul required that the new payment model be budget neutral against current spending levels. However,  the legislation also allowed that CMS to consider “behavioral  adjustments” defined as industry actions that would be taken to increase payment under the new model, unrelated to patient case mix changes. CMS has used this authority very broadly to institute a payment adjustment in the first year of PDGM based on “assumptions” of behavioral changes, and that adjustment calls for a 6.42% base rate reduction, or a possible $1b reduction in payments.

S 433 would prohibit CMS from making any pre-rate change reductions based on assumptions and instead to phase in any adjustments (either up or down) based on observed evidence (i.e., data supported) changes in provider behavior. The objective would be to achieve budget neutrality by 2029. This later piece addresses concerns the Congressional Budget Office (CBO) expressed regarding whether a similar bill introduced last session was truly budget neutral. S.433 also would allow Medicare advantage plans and Center for Medicare and Medicaid Innovations (CMMI) to waive the “confined to home”  provision when in the best interest of a Medicare beneficiary.

Regardless of the “behavioral adjustments,” the PDGM model is expected to have a tremendously varied impact state by state and agency by agency.  A significant amount of this impact is related to a Congressional  requirement that the payment model no longer use the volume of therapy as a payment level determinant.  (Something MEDPAC has been calling on CMS to do for years.)   The state of Florida, where therapy visits average 10.45 per episode of care is set to “lose” the most – projected at $141 million.  California on the other hand, where the average therapy utilization per episode was 5.76,  will be the largest gainer.  MA (need numbers from Tim)  Note: S 433 does not seek to make changes to the structure of the payment model that produces these changes.

It is important to reflect on CMS’ proposal in 2017, Home Health Groupings Model (HHGM) and how we arrived to where we are today. At the time, HHGM represented similar changes to the payment model, without soliciting industry feedback and some estimates predicting a 15% reduction in payments. As a result, the industry unified itself behind one message: that CMS withdraw its proposal and engage stakeholders to come up with an alternative. Upwards of 13,000 emails were sent to Congress from the industry, 49 members of the U.S. Senate and almost 160 members of the U.S. House of Representatives signed onto letters to CMS echoing the request to withdraw HHGM. This was a remarkable show of mobilization by the industry and we’ll need it again to make modifications to PDGM.

At present there is no bill in the House, but it is expected that one will be forthcoming.  Strong early sign on support is critical to keeping this bill moving and HCA of MA will be urging members to contact the MA delegation to support S.433 and the companion house legislation to be introduced. Stay tuned for these advocacy alerts in our weekly newsletter and advocacy messages in the coming weeks.

HCA will also be hosting a number of member events to prepare for the payment transition.  While the full day PDGM programs in March in Northampton are sold out, there will be a high concentration of sessions on PDGM at the New England Home Care Conference and Trade Show in on June 5 -7 inn Falmouth. Watch here for more details.

In the meantime, send a message here to Senators Warren and Markey about the need for their support on this issue. 

Let’s do this home care – we cannot sustain $1 billion in cuts based on assumptions, not facts!

HCA Submits Comment on Medicare Changes; Submit Your Comments Now!

On July 1st, 2018, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule which includes several changes to the home health benefit for 2019 and beyond. The public comment period closes this Friday August 31, 2018, at 11:59 p.m. As of this blog posting, 760 comments have been submitted to CMS which is encouraging, but far from the more than 1,300 comments submitted last year in response to the HHGM proposal which was ultimately withdrawn.

You can view the HCA’s written comments here and can download the word document here.

You may submit your own comments to CMS here.

Here are some of the key changes proposed, and an overview of HCA’s response:

Home Health Wage Index Changes

  • The 2019 proposed payment rates increase by 2.1% which represents a $400 million increase.
  • HCA of MA has long expressed concerns to CMS over inequities in how the wage index is calculated for home health agencies compared to hospitals. HCA urges CMS to adjust the 2019 home health agency wage index to reflect a policy to limit the wage index disparity between provider types within a given CBSA.

Proposed Patient Driven Groupings Model (PDGM) for CY 2020

  • Implementation: As the proposed PDGM would mark a major change in the way home health agencies will be reimbursed, the HCA urges CMS to delay implementation by one year to ensure that there is no disruption in access to services for beneficiaries and evaluate the accuracy of the model and its effect.

  • LUPA Thresholds: CMS proposes to set the LUPA visit threshold at the 10th percentile for each payment group. HCA believes this is complex and will complicate the care planning process for home health agencies. HCA urges CMS to retain the current LUPA thresholds and revisit them in future years.

  • Behavioral Assumptions: CMS proposed three ‘behavioral assumptions’ in the PDGM totaling -6.42%. However, these assumptions are not based in data or evidence. HCA believes that two of the three assumptions already exist in the current PPS methodology including; that agencies are already incentivized to both report the highest playing diagnosis codes and to develop and deliver plans of care that exceed the LUPA threshold. This could result in an over estimated impact of behavioral assumptions and the HCA urges CMS to eliminate the Clinical Group Coding and LUPA threshold assumptions.

  • Split percentage payment approach: HCA believes that changing from a 60 to 30 day billing period will be very disruptive to agencies’ operations and increase back-office costs. Therefore, HCA urges CMS to continue the split payment approach at the current 60/40 and 50/50 splits for early and late periods, respectively, to give agencies cash flow breathing room.

  • Certification and Re-certification of Patient Eligibility: HCA has long advocated for regulatory language to align with sub-regulatory guidance as it relates to documentation of the patient’s eligibility. HCA is encouraged by CMS’ proposal to eliminate the requirement that the physician provide an estimate of how much longer skilled services are required and we request that CMS consider revisions to the physician’s burden of the F2F encounter as a condition of payment. 
  • Remote Patient Monitoring: HCA strongly supports the proposal to recognize remote patient monitoring costs as an administrative cost on the HHA cost report. HCA does recommend however that CMS remove the regulation that does not allow remote patient monitoring to be used as a substitute for in-person home health services. 
  • Home Health Value Based Purchasing Model: HCA has long supported the HHVBP model aiming to improve quality by giving HHAs incentives to provide better quality care. However, HCA urges CMS to modify the HHVBP to recognize stabilization in the scoring because in many cases, stabilization (instead of improvement) is an appropriate goal for some patients.