Patient Groups, Providers and Lawmakers Agree: CMS Should Withdraw the Home Health Groupings Model

Our concerns about the Home Health Groupings Model (HHGM) proposed by the Centers for Medicare & Medicaid Services (CMS) are being echoed by patient advocates, provider groups and bipartisan lawmakers!

Groups ranging from the American Hospital Association to a group of 49 bipartisan members of the Senate have called the proposal “drastic” or “radical” and have pointed out that HHGM will “create major incentives to underserve Medicare beneficiaries.” Below are some examples of what these  groups are saying about HHGM:

“HHGM methodology only reflects the needs of some Medicare beneficiaries, while Medicare law applies to every Medicare beneficiary.”

 

“A change of this magnitude is also likely to put patient access at risk for Medicare beneficiaries in rural and smaller communities with few HHAs and America’s Veterans who largely depend on home health.” 

 

“We have heard from a number of stakeholders who are concerned that the proposed rule lacks sufficient information and data points to allow home health agencies to accurately estimate the impact of the proposed HHGM.”

 

Now, it is your turn to share concerns about HHGM with your local papers and Members of Congress!

It’s essential that every Member of Congress hear from the home health community on this important issue.

CMS Should Collaborate with the Home Health Community to Improve the HHGM

Recently, the Centers for Medicare & Medicare Services (CMS) released their CY 2018 proposal for the Health Prospective Payment System (HHPS) and the Home Health Groupings Model (HHGM) within it. This proposal would drastically alter the home health payment system, putting the 3.5 million Medicare beneficiaries that depend on the home health benefit at risk.

The HHGM would overhaul the current Medicare payment system in a non-budget neutral manner. Payments would now be based on patient characteristics instead of care needs, and distributed based on location of providers rather than their quality of service. This causes uneven payment distribution, as high-quality providers in certain areas could face disproportionate cuts. Furthermore, the geographic disparity would have the greatest effect on seniors living in rural, smaller areas, potentially putting their access to care at risk.

The HHGM could be implemented as early as 2019. If implemented as is, it could harm home health patients’ access to quality care and cause disproportionate home health provider payments.

We believe that CMS must work with the home health community in order to properly address and solve the issues within the HHGM. We welcome engagement with CMS, but need more data and information to be able to offer in-depth policy recommendations.

Click here to see our five reasons why CMS and the Home Health Community should work together to improve the HHGM.

Ask Congress to Extend the Home Health Rural Safeguard Today!

As a person gets older, certain things once taken for granted become increasingly difficult. Health becomes harder to manage and appointments with doctors and healthcare providers become harder to reach, especially for seniors residing in rural areas.

The Moran Company estimates the average rural patient’s travel distance to her doctor or nearest hospital is about double that of her city counterparts. Many older Americans are unable to travel such long distances, leaving them with no option but to depend on home healthcare services to ensure their wellbeing.

With that distance comes expense, and elderly patients using home health are left with significantly higher medical costs. In 2000, Congress began to combat this price differential through Medicare’s implementation of a rural safeguard. The safeguard protects older patients with poor health in rural areas who depend on home healthcare services by covering the higher costs of travel and staffing.

This safeguard has protected older Americans for 17 years, but is now set to expire on Dec. 31, 2017. On the eve of the safeguard’s expiration, we must remember how important it is to not let rural locations hinder any American’s chance at maintaining good health.

This issue is crucial to our nation’s rural seniors, and it’s critical that we communicate its value to lawmakers in Congress to ensure it is extended.

Urging your lawmaker to support the rural safeguard extension is simple. Write a letter to your lawmaker or ask for their support in your local newspaper by visiting our Action Center:

New Study Shows Why We Need to Expand the Home Health Rural Safeguard

A new study by the Moran Company uncovered the many challenges home health beneficiaries in rural areas face in accessing care.

The study found significant disparities between rural and urban home health beneficiaries:

  • In 2014, seniors living in rural areas were 15% less likely to receive home health services.
  • Medicare home health beneficiaries in rural areas are older, have a lower income, and live with more chronic conditions than the general Medicare population.
  • Medicare home health beneficiaries in rural areas are 17% more likely to be below 200 percent of the federal poverty line.
  • Rural Medicare patients live twice as far from their doctor compared to beneficiaries in urban areas.

Another factor compounding these disparities is the high cost of providing home health services to patients living in rural communities. According to a study by Ability, the cost of providing Medicare home health services is 36% higher per parent episode in rural areas than in urban areas – mainly due to the long distances providers must travel to reach patients in their homes. This presents a challenge for providers, who ultimately bare the higher cost of delivery.

Historically, the Congress has rightly understood these challenges and since 2000 has provided safeguard “add-on” payment to the reimbursement rate for Medicare home health services delivered in rural areas. This “rural safeguard” covers those extra costs so beneficiaries in rural areas have their home health needs met.

Unfortunately, the safeguard is set to expire at the end of this year, which is why home health providers are urging Congress to renew the program before time runs out. In the coming months, the Partnership will work diligently with lawmakers, patients, and stakeholders to ensure that home healthcare remains accessible to older Americans living in rural areas.

To learn more about Medicare’s rural home health population, click here.

Good News: CMS is Re-thinking the Home Health Pre-Claim Review Demonstration

On March 31, the home health community received some good news from the Centers for Medicare & Medicaid Services (CMS)!

CMS announced that it would stop the planned implementation of a Pre-Claim Review Demonstration (PCRD) in Florida, which would have applied new, mandatory regulatory requirements on all home health agencies operating across the state on April 1 and pause the PCRD program currently underway in Illinois for at least 30 days, which has made the delivery of timely home healthcare difficult since implemented in August 2016.

Here at the Partnership, we are incredibly grateful CMS responded to the concerns expressed by bipartisan lawmakers, home health providers, and advocates both in these states and across the country. We also want to applaud the thousands of advocates who collectively reached out to CMS and their lawmakers in recent months – your efforts truly made a difference!

We hope this decision will allow the home health community to work with CMS to strengthen the Medicare home health program by developing policy alternatives and through proper education and training. We welcome the opportunity to work with CMS to develop alternative, targeted reforms to reducing fraud and abuse without disrupting the care for our vulnerable Medicare patients.

Florida Lawmakers Urge Secretary Price, CMS to Reject Pre-Claim Review

This week, a bipartisan group of Florida lawmakers sent a letter to Health and Human Services Secretary Tom Price, MD urging him to reject the Medicare Home Health Pre-Claim Review Demonstration and replace it with a more effective program to tackle Medicaid fraud.

The letter, which was signed by twenty-seven members of Florida’s Congressional delegation, including Senators Bill Nelson (D) and Marco Rubio (R), called on CMS to put the breaks on PCRD ahead of its scheduled implementation date on April 1st. The program was first rolled out in Illinois last August and resulted in numerous technical issues and improper care denials across the state. Because of these issues, CMS initially delayed PCRD from taking effect in Florida and several other states for many months in order for it to be improved. However, it is clear that no serious effort was made to fix the underlying problems with PCRD during that time.

“We support efforts to combat Medicare fraud and protect taxpayer funds, but we are concerned that the PCRD’s current parameters are too broad to reduce fraud and improper payment rates,” the letter reads. “We encourage you to consider an alternative approach that would achieve these goals and ease the administrative burden and additional implementation costs for smaller home health agencies, and ensure timely patient access to services.”

The letter also raises the concern that Pre-Claim Review imposes onerous restricts on small home health providers, and was implemented without going through the formal rulemaking process.

You can read the full letter here.

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.

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.