In comments to the U.S. Centers for Medicare and Medicaid Services (CMS) today, HCA focused on four principal areas of the proposed hospice rule for fiscal year (FY) 2022. These include:

• CMS’s hospice utilization data analysis and spending outside of the hospice benefit and other issues.
• Revision and rebasing of the labor shares of the hospice payment rates.
• Adoption of the 2018 Office of Management and Budget (OMB) hospice wage index statistical area delineations and the elimination of the 5 percent cap on wage index decreases.
• Proposed clarifying regulation text changes for the Hospice Election Statement Addendum.

HCA Vice President for Finance and Management Patrick Conole has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposed 2021 payment rule for home health. The comments can be downloaded here.

The proposed rule includes updates on a mix of longstanding payment-related programs and structures, but, due to the COVID-19 pandemic, left the existing 2020 Patient-Driven Groupings Model (PDGM) intact.

CMS is expected to finalize the rule, following the comment period, in late October, with the rule going into effect on January 1, 2021.

In comments to the U.S. Centers for Medicare and Medicaid Services (CMS), HCA focused on three principal areas of the proposed hospice rule for fiscal year (FY) 2021: hospice wage index updates and revisions based on new Core-Based Statistical Area (CBSA) designations published by the Office of Management and Budget (OMB) in 2018; CMS’s proposed elimination of the Service Intensity Add-on (SIA) budget neutrality factor; and upcoming changes to the hospice election statement, along with a new addendum requirement.

HCA Vice President for Finance and Management Patrick Conole submitted comments to the U.S. Centers for Medicare and Medicaid Service (CMS) on CMS’s interim rule regarding home care and hospice “regulatory revisions” that have been issued in response to the public health emergency.

In our comments, HCA recognized CMS’s efforts thus far on regulatory relief and waivers, including CMS’s responsive interpretation of the “homebound” status definition in light of COVID-19, new allowances for non-physician practitioners to order home health services, and the modest expansion of remote telecommunications services to help shield against exposure risk and to help augment care.

On this latter area, however, HCA made several recommendations. We noted the recently extended or expanded flexibilities, permissions and payments for telehealth by other practitioners that should be likewise provided broadly to home health and hospice providers whose patients and staff also face infection exposure risks.

HCA Vice President for Finance and Management Patrick Conole yesterday sent comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposed 2020 payment rule for home health.

The proposed rule includes updates on a mix of longstanding payment-related programs and structures, alongside the major structural overhaul known as the Patient-Driven Groupings Model (PDGM).

CMS is expected to finalize the rule, following the comment period, in November, with the rule going into effect on January 1, 2020.

Continue reading “HCA Comments on Home Health Rule, PDGM” →

Rule would limit, deny immigration for those on public assistance, with implications for home care patients and the individuals who support them

HCA today commented on a new federal proposal that would limit or deny permanent legal status to immigrants if they rely on a wide range of government services, such as Medicaid, food assistance, and housing assistance. Our comments seek exemptions of individuals employed or seeking employment as home care or personal care aides. Continue reading “HCA Seeks Home Care Exemption in Federal “Public Charge” Rule Change” →

HCA this week voiced support for a proposal to add non-skilled in-home supports as a supplemental benefit under Medicare Advantage (MA).

Our comments — to the U.S. Centers for Medicare and Medicaid Services (CMS) — also include recommendations for implementation of this potentially transformative change. HCA’s comments can be downloaded here.

CMS recently announced the proposal in a notice to MA plans on 2019 payment changes, saying that it intends to expand the scope of the “primarily health related supplemental benefit standard.” Such an expansion would cover services or items that “diagnose, prevent, or treat an illness or injury, compensate for physical impairments, act to ameliorate the functional/psychological impact of injuries or health conditions, or reduce avoidable emergency and health care utilization.”

HCA has sent comments to the U.S. Centers for Medicare and Medicaid Services (CMS) urging it to halt a new proposal that would fundamentally overhaul the Medicare home health reimbursement system to the tune of $1 billion in cuts, beginning January 2019, as part of the proposed 2018 Home Health Prospective Payment System Rule. (Our comments are available here.)

This payment system, (called the Home Health Groupings Model, or “HHGM”) is the most drastic reimbursement change affecting the home care sector in decades. Because it is not budget-neutral (which should be a fundamental requirement when modifying any payment system), CMS needs to rescind this policy change and put into place a stakeholder-involved process to make rational and methodical policy changes that will not have dire consequences on America’s home care agencies. Continue reading “HCA Comments on 2018 HHPPS, with Focus on HHGM Payment Cuts” →

HCA submitted extensive comments this week on the U.S. Centers for Medicare and Medicaid Services proposed rule for the 2017 Home Health Prospective Payment System (HHPPS). You can download the comments here.

The comments address such areas as the continued methodology flaws in CMS’s rebasing of Medicare home health rates, including the incorporation of a “case-mix-creep” adjustment that appears to adjust the rebasing cuts to a level beyond that authorized by Congress. We also seek CMS action to address the lack of a comprehensive impact analysis for rebasing and the failure of rebasing to incorporate all usual and necessary indirect and direct costs in CMS’s analysis. Continue reading “HCA Submits Comments on HHPPS Rule for Medicare Home Health” →

While the U.S. Centers for Medicare and Medicaid Services (CMS) has revised the Medicare Prior Authorization of Home Health Services Demonstration to now become a Pre-Claim Review Demonstration, HCA believes the revised Demonstration would still create unnecessary obstacles to care, increase system wide costs, and jeopardize the quality of care that patients receive. Download our July 20, 2016 comments to CMS on the proposal.

HCA has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposal to modify the Medicare Conditions of Participation (CoPs) related to discharge planning requirements for hospitals, critical access hospitals and home health agencies. The proposal was first issued in October.

While HCA supports efforts to revise the CoPs in this area, we commented on several technical and substantive areas of concern, including: CMS’s cost estimates (which fall short of the real impact); implications and possible conflicts with managed care practices; flaws in the publicly reported quality data that hospitals would use for assisting patients in selecting a post-acute provider; the content requirements of discharge summaries; and other issues.

You can download the comments here.

HCA has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on a proposed rule that would provide the most significant update to Medicaid managed care rules in more than a decade. The rule covers the delivery of managed long term services and supports (LTSS); quality improvement; program and fiscal integrity; state delivery system reforms; rates to plans; beneficiary experience; and other areas.

HCA’s comments address: the misalignment between federal and state regulations for home care; the need for actuarial soundness of rates by states to managed care plans and rates by plans to home care providers; disenrollment due to home care provider changes; transitions of care; state monitoring requirements; grievances and appeals and aid continuing; provider screening and enrollment; uniform billing; and plan contacts.

HCA writes a letter to the Cuomo Administration with comments on a new state budget proposal which seeks to move all health care payments from fee-for-service models to value-based models.

The U.S. Centers for Medicare and Medicaid Services (CMS) has proposed the first new changes to the Medicare home health Conditions of Participation (CoPs) in years. The CoPs haven’t been changed since 1989, and this new set of changes includes sweeping new requirements related to patients rights, quality reporting and other areas affecting the operation of most home care agencies.

HCA comments on the proposed 2015 home health prospective payment system rule which establishes the Medicare home health payment and regulatory policy for 2015. The proposed rule extends the cuts previously enacted under the federal “rebasing” regimen and makes some changes to the Medicare home health physician face-to-face rule documentation requirements.

HCA requests an extended comment period that would provide more time for the industry to vet CMS’s proposed rule revising the Medicare and Medicaid Conditions of Participation (CoP) for home health agencies. The current December 8, 2014 comment deadline does not offer adequate time to obtain crucial feedback from the home health agency members in the field, who have been operating under the existing home health CoPs since 1989.

HCA and LeadingAge New York write to the state’s Medicaid Director regarding Safety Net concerns in the Delivery Reform Incentive Payment (DSRIP) program, as well as some recommendations regarding the attribution methodology whereby patients are assigned to DSRIP networks.

HCA writes to the Governor in support of A.6530-B (Cusick)/S.4719-B (Lanza), which passed both houses of the Legislature. The legislation will help ensure vital access to care for home health and hospice patients during emergencies, as well as support the overall operation of the health system in responding to disasters.