In a rare but encouraging demonstration of unity and cooperation, an ad hoc collection of home health associations and large providers joined forces to speak to Congress and CMS with a single voice last week about the proposed Home Health Groupings Model. They agree the new Medicare reimbursement system is bound to drastically change the way home health services are reimbursed and conducted, starting in January, 2018.
Joining the National Association for Home Care and Hospice to present a unified compromise proposal to the House Ways and Means Committee are ElevatingHOME, the Partnership for Quality Home Health Care, Kindred, Healthsouth/Encompass, Amedisys, LHC Group, and Almost Family. An informative opinion piece authored by Dr. Steven Landers, president and CEO of VNA Health Group, was published in The Hill, widely read by D.C. lawmakers, on October 24.
The final rule for the CY18 HHPPS was sent to the Office of Management and Budget (OMB) on October 20, following the required 60-day public comment period. As the staff of the Office of Management and Budget are restricted from sharing information about its contents, specifics will not be known until the final rule is released, which must happen by November 1 to meet the January 1, 2018 effective date.
While release of the final rule is awaited, the House Ways and Means Committee has also proposed its own revisions to H.R. 3992, the so-called "Rural Home Health Extension and Regulatory Relief Act." Introduced by Representative Kristi Noem (R-SD), H.R. 3992 would also mandate a 30-day payment model for home health episodes.
In its public statement, NAHC describes CMS's CY2018 Proposed Rule as "a policy that must be withdrawn because it will cause massive disruption in the industry." The statement urges CMS not only to withdraw the proposal but instead to work with stakeholders to develop a fully budget-neutral policy that does not limit access to beneficiaries or diminish provider resources.
"The Home Health Groupings Model's five percent reduction in Medicare reimbursements — almost $1 billion in 2019 alone — will lead to a loss of critical services to millions of patients," the NAHC statement said. In addition, NAHC asserts that CMS does not have the statutory authority to impose these changes on the industry without Congressional action.
ElevatingHOME called the cooperative effort "an unprecedented display of industry collaboration." In that collaboration, the VNAA parent association continued, "a unified compromise proposal was offered to the House Ways and Means Committee in an effort to gain a withdrawal of the HHGM proposal from the CY2018 Home Health Prospective Payment System final rule.
Calling to mind the last time CMS designed a flawed payment system that brought harm to patients, NAHC predicts the proposed HHGM would:
In their letter to CMS administrator Seema Verma, NAHC's Bill Dombi and Keith Myers, Chairman of the Partnership for Quality Home Healthcare, asserted, "The home health industry requires additional information in order to fully assess the impact of the proposed rule, with more complete data analysis, and scrutiny as to the legal and policy authority to make the rule."
Following that theme, Dr. Landers wrote in his "The Hill" article that a change of this magnitude needs to be tested as a demonstration project in a handful of states, not rushed into a national policy. "HHGM is a totally untested and unpredictable, ivory tower, top-down, Washington science project being foist on America's most vulnerable seniors," he writes. "...there is no way to know how severely it will change home health care for older Americans. The proposal was developed by data analysts and Medicare insiders and has never been tested in the real world in any fashion. So many untested changes are being proposed at once, it is virtually impossible to predict its impact."
Associations Cannot Do It Alone
All parties conclude their individual and joint statements by urging all stakeholders to help deliver the message. "To defeat this payment rule before it brings havoc to the industry, we need home health leaders, employees and patients to make their voices heard by policymakers in Washington, D.C. Without your support and advocacy, this rule cannot be stopped," the official NAHC statement reads. To make it easy to help, NAHC has added to its Legislative Action Center a page where members can ask Congress to tell CMS to withdraw the payment rule. Your career may depend on whether you follow that link and offer your representative your views right now.
©2017 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan's Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. firstname.lastname@example.org