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but far from the more than 1,300 comments submitted last year in response to the HHGM proposal which was ultimately withdrawn.
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.
The Home Care Alliance of MA put together a COP Task Force consisting of an expert team of home health professionals. This task force developed guidelines to assist Home Health Agencies with the understanding on the new standards in order to stay in compliance.
We are planning another great event on the shores of Cape Cod next June. Mark your calendars and keep up with all the conference news by subscribing to our blog, following us on Facebook or on Twitter.
The conference is designed for senior and mid-level administrative and clinical staff. The conference features multiple keynote sessions, workshops, and intensive programs. Topics are designed to meet the needs of all agencies, including Medicare-certified, private duty, and hospices. The trade show is the largest home health and hospice expo in the Northeast.
(Each issue of our weekly eNewsletter, Update, opens with a brief message from Pat Kelleher, reprinted below. To learn more about the news, events, legislative and regulatory updates, and career opportunities highlighted each week for our members, contact HCA Membership Coordinator Tom Meyer).
Alliance Exec. Dir. Pat Kelleher
The saying “elections have consequences” is thrown around a lot these days as a rallying cry to various constituencies to get to the polls on a specific issue, be it health care, gun ownership, or immigration. Many a TV pundit has used it in relation to – and on either side of – the coming Supreme Court confirmation battle. It’s an interesting footnote to history that the saying only entered the lexicon when uttered by our 44th President Barack Obama in a meeting very early in his presidency with Congressional Republicans who were not on board his economic plans for the country.
This is a good time to remind everyone that we have a primary election coming up in MA the Tuesday after Labor Day and a final election on Nov 6. The degree of influence our state and federal officials have over our industry, including who gets care, how it is paid for and regulated is tremendous. Anything you can do to engage with them to help them better understand what we do is important and helpful. Let your officials know who you are and that you vote!
HCA of MA will be in Washington DC in mid-September with our colleagues from other state associations to discuss federal policy issues. In the next few months, we are working with some member agencies to host membership forums on Question 1, the nurse staff ratio question. These sessions so far are scheduled for:
How did a “big, six-foot-six, burly guy” become the owner of Minute Women Home Care? For the seventh episode of the Talking Home Care podcast, Pat Kelleher talks with Ryan McEniff about what it takes to run a successful private home care agency. Topics include:
Ryan’s personal story about entering the industry;
The challenges (and opportunities) of transitioning from family to paid home care;
How home care can restore clients’ work/life balance;
Whether home care can remain affordable to middle-class families in a bustling economy;
Why finding (and keeping) the best staff is sometimes a bigger challenge than attracting clients;
Going the extra mile to protect clients with national background checks;
The single most important question all families should ask when choosing an agency for their loved ones (jump ahead to 34’35” to find out); and
You may listen to the podcast by clicking the play button above, downloading it directly, or subscribing through iTunes or Google Play. (Length: 37 minutes; Size: 18 MB). If you enjoyed it, please give us a five-star review so others can find it as well.
Guest: Ryan McEniff has been the owner of Minute Women Home Care since 2013. He became passionate about home care when his mother needed care while battling cancer. He is also a Certified Dementia Practitioner and the host of The Caregiver’s Toolbox podcast.
The 2018 Compensation Survey is an indispensable tool for c-suite staff and HR managers, proving a quick and accurate reference of industry pay standards for your employees.
The survey contains information about prevailing pay and benefits for the full range of positions in home care agencies. It lists pay and benefits figures for dozens of positions, including: executive, administrative, supervisory, care giving, and clerical positions.
The survey is available for purchase on our website for $400 for members, $500 for non-members (members who participated in the survey should have received coupon codes with an additional discount). Make sure you have the tools you need to make the best decisions for you and your staff.
The full survey is over 200 pages. To get a sense of the available information, click the sample pages above.