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

August 30, 2018

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but far from the more than 1,300 comments submitted last year in response to the HHGM proposal which was ultimately withdrawn.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.

Talking Home Care: Ryan McEniff on Running a Private Care Agency

August 6, 2018
Ryan McEniff of Minute Women

Ryan McEniff

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
  • Ryan’s own podcast, The Caregiver’s Toolbox (expect Pat on an upcoming episode).


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.

Host: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

GuestRyan 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.


Talking Home Care LogoDon’t want to miss the next episode of Talking Home Care? Subscribe through iTunes, Google Play, or accessing its feed directly.

Return to www.thinkhomecare.org.


Talking Home Care: Eric Scharber on Workforce Challenges: “Whoever Has the Talent Is Going to Win”

May 22, 2018
Eric Scharber of Exact Recruiting

Eric Scharber

For the sixth episode of the Talking Home Care podcast, Pat Kelleher talks recruiting and retention with Eric Scharber, a principal of Exact Recruiting. Topics include:

  • The advantages to employers of focusing on retention as much as recruiting
  • How small changes in retention can make a real difference to an agency’s bottom line
  • Why offering staff development is sometimes more important than pay increases
  • The challenges (and opportunities) of hiring Millennials
  • How to get graduating nurses and therapists to consider careers in home care and hospice
  • The specific challenges of retaining non-medical caregivers such as CNAs and home health aides

You may listen to the podcast by clicking the play button above, downloading it directly, or subscribing through iTunes or Google Play. (Length: 28’30”; Size: 15 MB).

Host: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

GuestEric Scharber is a principal at Exact Recruiting, a Simione Talent Solution, where he leads talent acquisition and employee retention for the home care and hospice industry. He oversees executive search and non-executive recruiting services, as well as recruitment process outsourcing, compensation analysis, and employee satisfaction survey services.

Talking Home Care LogoDon’t want to miss the next episode of Talking Home Care? Subscribe through iTunes, Google Play, or enter the following in your podcast app: https://thinkhomecare.wordpress.com/category/talking-home-care-podcast/feed/

Return to www.thinkhomecare.org.


Just Published: 2018 Resource Directories!

March 14, 2018

This is the one, indispensable book that anyone making referrals must have. It’s the bible for home care in Massachusetts. — Gina Martin, RN, CCM

Thousands of copies of the the Alliance’s home care referral directory have already been shipped to every case manager, hospital, COA, state legislator, and GCMs in Massachusetts.

Need an copy? They’re available for purchase on our website, with free shipping (as always).

Alternatively, you can also use the Digital Edition of the directory, as well as our online Find an Agency search.

 

Return to www.thinkhomecare.org.


HCA Partners with Other State Associations to Offer Valuable Webinars

March 1, 2018

HCA prides itself in providing the most current, important, and in demand educational topics for our members. To do this, we sometimes partner with sister state associations who are willing to offer their programs at member rates. Below you will find some upcoming webinars that are being made available to all HCA of MA members!

Operational Lessons Learned from a Disaster Plan That Didn’t Work
March 7: 1:00-2:30PM

This case study will help your agency better prepare for the unthinkable. Hear the experience of an agency that worked with local and regional groups to develop a comprehensive disaster plan only to discover IT DIDN’T WORK!! Emergency preparedness will be a top priority in upcoming surveys. Failure to comply can result in serious financial penalties, or even loss of your agency’s license. Take the steps necessary to create a plan that works.

Learn More and Register

The Aide’s Role in Confidentiality and HIPAA
March 8: 3:00-4:00PM
This workshop will focus on assisting your In-Home Aides in understanding HIPAA and confidentiality guidelines. This workshop will offer practical tips to ensure that the para-professional adheres to the required privacy standards. Also included: the impact of social media such as Facebook, My Space, YouTube and cell phones, text messages, etc.

Learn More and Register

Re-Imagining the Plan of Care: A Pyramid Model
March 22: 1:00-2:30PM
There are many ways to build a plan of care – but how do you know that the one you are using is effective, comprehensive and will support strong clinical care in the home?

The “Pyramid of Care” uses the comprehensive OASIS assessment you already have as the foundation. Explore the process of identifying critical areas that become the goals of the plan of care, and transform these into skilled interventions. This process will be easy for your clinicians to grasp and implement, will enable them to clearly support skill in each visit, and achieve measurable improvement in the outcome goals attached to each plan.

Learn More and Register

Understand PT & OT Functional Tests: Selecting & Interpreting the Best Assessment Tools
April 5: 1:00-2:30PM
There are so many assessment tool options available to home care, but so little time to research them all! Home care physical therapist and educator Ernest Roy has taken the deep dive to provide webinar participants with an evidenced-based review of tests suitable for field use by Physical and Occupational Therapists. Roy will focus on data norms for specific populations, as well as highlight minimal clinically important differences as well as specificity and sensitivity. Utilize the data you collect from intake to discharge, and improve your functional testing efficacy.

Learn More and Register

The Aide’s Role in Assisting a Patient with Chronic Pain
April 12: 3:00-4:00PM
Our world is aging. The elder population may falsely believe that because they are aging that pain is a normal part of living and is therefore not reported or managed. Since the majority of our patients seen in the home are elderly, this webinar will provide an overview of symptoms the aide may observe and the aide’s role in providing care to those patients experiencing pain.

Learn More and Register


Talking Home Care Episode 5: Barbara Citarella on Emergency Preparedness

February 27, 2018
Barbara Citarella

Barbara Citarella

For the fifth episode of Talking Home Care, Pat Kelleher talks emergency and disaster preparedness with Barbara Citarella, president of RBC Limited Healthcare & Management Consultants. Topics include:

  • CMS’s 2016 preparedness operations requirements;
  • The unique challenges home care agencies face during emergencies (as well as their unique capabilities);
  • Lessons agencies can learn from recent natural disasters;
  • Home care’s ability to provide surge capacity for other health providers;
  • The biggest obstacles agencies face in implementing a disaster plan; and
  • Resources for agencies who wish to become better prepared.

You may listen to the podcast by clicking the play button above, downloading it directly, or subscribing through iTunes or Google Play. (Length: 32’45”; Size: 17 MB).

Links/Action:

Talking Home Care LogoHost: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

Guest: Barbara Citarella is the president and founder of RBC Limited Healthcare and Management Consultants, a national leader in the home health and hospice industry in addition to disaster planning. As the only recognized expert in the area of home care and hospice disaster planning, she specializes in emergency disaster planning, bioterrorism, health care development and operations.  She provides education to law enforcement and government agencies, health care providers, private sector, first responders, national and state associations in all aspects of disaster preparedness.

Don’t want to miss the next episode of Talking Home Care? Subscribe through iTunes, Google Play, or enter the following in your podcast app: https://thinkhomecare.wordpress.com/category/talking-home-care-podcast/feed/

Return to www.thinkhomecare.org.


MA Legislative/Regulatory Preview for 2018

January 11, 2018
On Wednesday January 3rd , the Massachusetts Legislature returned for the second year of its two-year session. After a seven-week recess, the body is looking at a traditionally busier second half than the first. The nearly 170 bills that passed in 2017 marked the lowest total in twenty years.

Lawmakers have until July 31 to complete all substantial legislative debate. In addition, all 200 members are up for election in 2018, which is expected to be a distraction from normal legislative work as a result of a polarized political landscape. Here’s what the Alliance will be focused on in 2018:

Workforce Issues:

Prior to the Holiday break, the Alliance met with its ‘Enough Pay to Stay’ partners to strategize coordinated efforts to attain wage relief for direct care workers and ASAP case managers. The coalition has pending legislation which would take steps toward this initiative, but we will pursue other legislative vehicles to fight for our workforce.

Worker Registry:

In November, Governor Baker signed into law the Home Care Worker Registry. This law will establish a worker registry that requires agencies contracting with ASAPs to submit workers’ private information to the state. The law is enacted and subject to regulations. The Alliance and its partners are in active communication regarding next steps toward protecting our members and their workers’ rights.

Licensure:

The FY 2018 State Budget included language that will establish a licensure process for home health agencies providing skilled services. It is unclear at this point when the process to promulgate regulations will begin, but the Alliance will be providing input to the Department of Public Health as these parameters are developed. In addition, Alliance-sponsored legislation that would license private care agencies is still making its way through the legislative process. Under procedural rules, the legislature has until February to report legislation out of committee. The Alliance will continue to advocate for passage of this legislation.

Continuous Skilled Nursing:

In late 2017, MassHealth announced two rate increases for the Continuous Skilled Nursing (CSN) program that totaled nearly 11 million. This was welcomed news, but there remains work to be done. The CSN provider/parent coalition will continue to advocate for the CSN Bill of Rights legislation that would mandate bi-annual reviews of the workforce to ensure safeguards against future crises.

MassHealth Rates:

The Alliance has been informed that MassHealth will conduct a long-overdue review of rates for per-visit nursing, therapies, and home health aide services.  The Alliance will be working to gather data to demonstrate that the current low rates are interfering with agencies’ ability to attract and retain enough workers to meet the demand for services.

MassHealth Reorganization:

MassHealth’s initiative to enroll the majority of members into managed care programs this coming spring will dramatically change the way MassHealth members access home health services, and disrupt many existing provider referral relationships.  The Alliance will continue to work to ensure that MassHealth members retain access to needed home health services, and that agencies are adequately reimbursed for those services.

House of Representative Health Care Bill:

Late last year the Senate passed a health care cost containment bill aimed at curbing costs while maintaining access. It has long been rumored that the House will be embarking on similar initiatives. Though the details are scarce, this legislation could be a vehicle for many of the Alliances priorities in 2018 and we will continue to advocate where necessary.

If you have any questions about the year ahead for advocacy or would like to get involved, reach out to Jake Krilovich, the Alliance’s Director of Legislative and Public Affairs.


%d bloggers like this: