PQHH’s 2017 Policy Priorities

As we move into 2017 and welcome a new Administration and Congress, the Partnership has outlined policy priorities for 2017. While it is hopeful that the new Administration will provide regulatory relief from multiple, duplicative programs detailed below, the Partnership will continue to press on with Congress to make critical changes.

Pre-Claim Review
Last year, the Centers for Medicare & Medicaid Services (CMS) introduced the Pre-Claim Review for home health demonstration project. Under the demonstration, home health agencies would need to receive approval from a CMS contractor before being reimbursed for providing home health services – even if those services were prescribed by a patient’s physician. While the original purpose of this demonstration was to address fraud, a combination of technical failures and contractor mismanagement has led to significant and unnecessary delays in home care delivery while doing little to tackle fraudulent claims.

Thankfully, CMS suspended pre-claim review in several states where it was slated to begin this year. However, the demonstration remains active in Illinois, the first state in which the program was implemented, and is scheduled to take effect in Florida early this year. In 2017, the Partnership will be renewing its efforts to pass the Pre-Claim Undermines Seniors’ Health (PUSH) Act, bipartisan legislation to delay pre-claim review for one year so CMS can determine how to strengthen the program and prevent care disruptions.

The Partnership also welcomes the opportunity to work with CMS simultaneously to address our concerns with pre-claim review and delay implementation of the program in other states.

Face to Face Requirement
Under current Medicare rules, patients who need home healthcare must have a documented face-to-face encounter with a physician to certify their eligibility for services. This is to ensure that patients are receiving care in the appropriate setting and providers are not billing Medicare for unnecessary services. However, overly complicated and burdensome requirements have resulted in unintended consequences like care delays and improper denials of services.

Data show tens of thousands of claims have been denied for care that is medically necessary and appropriate. While many of these claims are overturned on appeal, the initial denials make it difficult for home healthcare agencies to provide continued, uninterrupted care.

This year, we will work with our partners in Congress to develop legislation to streamline the existing face-to-face documentation rules to reduce the paperwork burden on physicians and home health agencies so that there are fewer improper care denials.

Rural Safeguard
According to recent data, the cost of providing Medicare home health services is 36% higher per parent episode in rural areas than it is elsewhere. This is primarily due to increased transportation and staffing costs, which make it difficult for home health agencies to balance their operating costs with reduced Medicare reimbursement rates. Medicare home health patients in rural areas are also older, on average, than the general Medicare population and are more likely to be dually eligible for Medicare. Therefore, ensuring continued access to home health services is critically important for rural beneficiaries.

Since the year 2000, Medicare had recognized this disparity and has provided a rural safeguard to ensure older Americans living in rural areas have access to home healthcare. Currently, the safeguard is set at a 3% add-on to the baseline reimbursement rate. However, this provision is set to expire at the end of 2017 if Congress doesn’t act to extend the safeguard.

We will make extending this valuable rural safeguard a top priority in 2017 so that America’s rural communities can rest assured that they will always have access to skilled care at home.

Remembering the Importance of Home for Our Seniors Around the Holidays

As families around the country gather to celebrate the holidays this year, giving gifts and spending quality time with loved ones, it’s important to reflect on the importance of home and the comfort and security it provides.

For many American seniors, nothing is more important than being able to remain at home while recovering from illness or injury.  And thanks to home healthcare, more than 3.5 million seniors now have that option. Home is comfortable. Home is where the family is. And home is where seniors want to be – especially around the holidays!

475860502At the Partnership, we work hard every day to ensure that seniors have the choice to receive care in their preferred setting. We understand that recovery is stressful enough as it is and shouldn’t be made worse by having to receive care in an unfamiliar environment.

So this holiday season, take some time to thank the dedicated doctors, nurses, and home health aides who work around the clock to make sure seniors can enjoy their golden years in the comfortable, secure, and peaceful atmosphere home provides. And remember, that for some, being able to enjoy the holidays at home, surrounded by friends and family, is the greatest gift of all.

Have a safe, happy and healthy holidays from your friends at the Partnership!

Congress Must Enact the PUSH Act to Protect Seniors Home Healthcare

As Congress wraps up for the year, the Partnership is again calling on Congress to enact the Pre-Claim Undermines Seniors’ Health (PUSH) Act of 2016, which would delay the implementation of the home health pre-claim review demonstration until Medicare and home health agencies are prepared to manage the process without disrupting care delivery.

Since the program was first rolled out in Illinois this summer, providers across the state have run into numerous delays and technical problems – including improper care denials and issues using the Medicare Administrative Coordinators (MAC) electronic submission system. This led to longer wait times and unnecessary delays in patient services.

The PUSH Act, orginially introduced by Reps. Tom Price, MD (R-GA) and Jim McGovern (D-MA), would delay pre-claim review for one year to allow Congress, CMS,  and home health stakeholders to figure out how to strengthen the program through proper education and training. You can find out more about the bill here.

Fortunately, pre-claim review has already been temporarily suspended in several other states where it was slated to roll out. The PUSH Act would delay the pre-claim review for the rest of the country, and stop the program underway in Illinois.

The bill also calls on the Centers for Medicare & Medicaid Services to analyze the impact of the program and present a series of alternative measures for combating home health claims fraud – the original purpose of pre-claim review.

There is still time for you to help protect vulnerable seniors who depend on home health seniors – contact your member of Congress today and asking him or her to support this bill!  Click below to get started:

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Don’t Forget About Seniors’ Issues on Election Day

Today is Election Day! Nearly 146 million Americans are currently registered to vote and millions across the country will cast their ballots not only for the U.S. President, but also for state, local, and county offices.

America’s senior citizens play a powerful role in the electoral process. Approximately 46 million Americans aged 65 + are currently eligible to vote and make up a large and diverse section of the electorate. Regardless of whom you cast your vote for, remember the 12 million seniors who receive home healthcare and the one million jobs the sector supports.

All members of the home-based care community should be able to fully participate in our nation’s democratic process via information distribution, voter registration, and absentee ballots. And thanks to Bring The Vote Home, a nationwide initiative that is surveying seniors on a wide range of issues while empowering them to engage fully in America’s electoral process, many seniors have already voted in this election!

Click here to find more information about your polling place and how to vote.

Illinois Congressional Delegation Asks CMS to Delay Pre-Claim Review

Earlier this month, CMS Administrator Andy Slavitt received a letter signed by every member of the Illinois Congressional delegation urging him to suspend the Pre-Claim Review Demonstration (PCRD) program in the state. Since the program began on August 3, providers have reported numerous improper care denials and technical issues with the state’s Medicare Administrative Contractor (MAC). Several of the program’s provisions, such as the requirement that physicians wishing to prescribe home-based treatment submit a detailed plan of care to the MAC before any care can be delivered, have been especially difficult to comply with.

“We urge CMS to immediately grant the state of Illinois the same PCRD delay that your agency has provided to Florida, Massachusetts, Michigan, and Texas, until education and guidance for home health providers, the state MAC, and patients are improved,” the letter reads. “If the lessons from Illinois prove that PCRD is not adequately developed for implementation in those states, then our constituents and provider organizations deserve the same consideration.”

Fortunately, CMS has already announced that it will suspend Pre-Claim Review in Florida and several other states after Illinois providers reported extreme difficulty complying with the new requirements. This comes as new reports show that between 60 and 80 percent of PCRD submissions have been rejected by the state’s MAC.

But there’s an even better fix. Recently, Representatives Tom Price (R-GA) and Jim McGovern (D-MA) introduced bipartisan legislation that would delay PCRD for at least a year.  The Pre-Claim Undermines Seniors’ Health (PUSH) Act (H.R. 6226) suspends PCRD’s implementation in all states where it was set to begin – including Illinois – and requires the Department of Health and Human Services to submit a detailed analysis of the program along with a list of alternative measures to identify improper Medicare payments. The Partnership supports this legislation and remain committed to working with patients, providers, and the federal government to find a more effective solution to fighting Medicare fraud without jeopardizing quality home healthcare.

Congress: Support the PUSH Act to Protect Seniors’ Home Health

Since the Centers for Medicare & Medicaid Services (CMS) rolled out pre-claim review for home healthcare in Illinois, providers across the state have encountered numerous delays and technical problems. Across the home health community, we’re already receiving reports of improper care denials from the Medicare Administrative Coordinators (MACs) that review Medicare home health claims. Several other providers have also reported issues using the MAC’s electronic submission system – resulting in long wait times and unnecessarily delaying patient services.

Fortunately, there is a fix. Last week, Representatives Tom Price (R-GA) and Jim McGovern (D-MA) introduced bipartisan legislation to suspend and delay further extension of pre-claim review to other states so CMS can make adjustments to the program. The Pre-Claim Undermines Senior’s Health (PUSH) Act would implement an immediate, one-year delay to pre-claim review and require the Department of Health and Human Services to produce a report detailing the program’s impact on patients, providers, and the Medicare system.

Specifically, the PUSH Act:

  • Delays the application of the demonstration in each State so it does not apply to episodes of care beginning earlier than one year after the earliest date that the demonstration was scheduled to begin in each State;
  • Calls on the Secretary to suspend the demonstration in a State for at least one year if the pre-claim review demonstration is underway at time of enactment. This would extend the program’s delay to Illinois, which is currently the only state in which this program was implemented.; and
  • Calls for a report to Congress no later than six months after the date of enactment to, among other things, analyze the impact of Medicare pre-claim review in any State in which it was implemented, describe the resources provided to physicians and home health agencies to conduct the demonstration, and outline alternative measures to identify improper payments with possible corrective actions

You can help protect vulnerable seniors who depend on home health seniors by emailing your Congressperson today and asking him or her to support this bill! Click below to get started:

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National Seniors Poll Signals Opposition to Pre-Claim Review Policy

Recent data sponsored by Bring The Vote Home (BTVH) found that the large majority of U.S. seniors oppose Medicare policy that requires a government contractor to approve claims for physician-prescribed home healthcare services — those often recommended by doctors for elderly patients following hospitalization.

While the data is concerning, as it proves that the majority of seniors oppose the recently implemented “pre-claim review” demonstration by the Centers for Medicare & Medicaid Services (CMS), we are not at all surprised that the senior population opposes government intervention when it comes to a patient’s health.

Healthcare decisions should be made by a physician and a patient — the federal government’s intervention only complicates, interferes and upsets the process.

The poll found that more than four-out-of-five seniors, 83 percent to be exact, of U.S. seniors think physicians should have the final word when prescribing home health. Because after all, a doctor knows significantly more about an individual patient’s situation than a government contractor.

Other key take-aways:

  • Seniors think requiring a government contractor to approve claims for home health will result in care delays.
  • Seniors think requiring a government contractor to approve care will increase costs – to both the patient and Medicare.
  • Seniors most trust doctors and nurses to handle issues related to their healthcare.

The Partnership continues to monitor the impacts of the “pre-claim review” requirement as it is implemented this month in Illinois.  In the meantime, we urge CMS to consider this data and the clearly expressed patient opinion that government interference in healthcare is wrong.

CMS: Rethink Pre-Claim Review for Home Health Services

By Colin Roskey, Executive Vice President of Partnership for Quality Home HealthcareRoskey-colin

The Center for Medicare & Medicare Services recently proposed a pre-claim review demonstration for Medicare home health services, upon which approximately 3.5 million Medicare beneficiaries depend.

The Partnership is echoing concerns expressed by more than 120 bipartisan lawmakers to a previously proposed, and very similar, pre-authorization policy.  We are highly concerned the demonstration will result in unnecessary and unwarranted disruptions in seamless patient care, negatively affecting the weakest and sickest patient populations that depend on skilled home health care services to remain with their families and in their communities, not institutions.

Right now, the demonstration is set to start no earlier than August 1 in the state of Illinois, and shortly after, CMS will apply it to every claim made by every home health agency in Florida, Texas, Michigan and Massachusetts.

Why is this concerning?

  1. Medicare Administrative Contractors (MACs) are not fully prepared to manage the substantial increase in workload that will result from the pre-claim review demonstration. MAC staff will have to review 100 percent of all claims from all home health agencies in each state – a material new task requiring highly trained clinicians that can “turn around” each claim within 10 days.
  1. Home health agency (HHA) and physician workload and administrative costs will increase measurably.
  1. CMS has not armed physicians with the education and support needed to ensure they understand, and implement correctly, new pre-claim review policies and procedures.
  1. Pre-claim review policies will not appropriately prevent fraud and abuse.
  1. Home health stakeholders were given no opportunity to comment to CMS on the policies set forth in this demonstration project.

We continue to work with CMS and lawmakers in Congress to seek a solution that ensures that this demonstration is implemented in such a way that does not impede patient access to care, and that minimizes new burdens on home health agencies

We share CMS’s goal of eliminating fraud and abuse in the Medicare home health benefit, which we believe is a worthwhile and achievable goal.  We just don’t agree that pre-claim review policies will have the desired result nor will they target  bad actors who are currently abusing the system.  More targeted reforms are needed to protect patients as well as the quality and honest providers who deliver care to American seniors in their homes every day.


Home Health Leaders Applaud Introduction of Independence at Home Act

The Partnership commends U.S. Senators Edward J. Markey (D-Mass.), John Cornyn (R-Texas), Michael Bennet (D-Colo.) and Rob Portman (R-Ohio) for introducing the Independence at Home Act, which will convert the Independence at Home (IAH) demonstration into a permanent national Medicare program.

The legislation has been lauded across the home health community for bringing primary medical services to Medicare beneficiaries with chronic and debilitating conditions in the comfort of their own homes. The Partnership previously praised the Independence at Home program for saving an estimated $25 million in its first year, or an estimated $3,070 per beneficiary, underscoring the value of home health services for aging Americans.

The program enables doctors and caregivers to provide primary care services to those in need of care at home, thereby reducing the number of unnecessary emergency room visits and avoidable hospitalizations and readmissions, and their associated costs.

The bill provides beneficiaries access to quality home care, giving them better control of their health and putting families at ease, while lowering healthcare costs.  The Partnership thanks these lawmakers for recognizing the value of home-based care and urges the Congress to work with home health providers to develop additional programs to protect patient access to care in the home.

New Analysis Shows Role Home Health Plays in Reducing Readmissions

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