Almost half (48%) report instances where patients and/or family members refuse entry of staff in the home due to concerns about the virus at a time when home health agencies are working vigorously to screen caregivers and patients alike for the safety of both.
The state Department of Health (DOH) has updated its previous Medicaid Update on COVID-19 telehealth/telephonic billing and services allowances to more explicitly include home care and each discipline within home care following multiple appeals from HCA.
The new Medicaid Update, dated March 23, is here and may undergo future updates that providers should watch for.
Please specifically refer to the “Telephonic Reimbursement Overview” table, which is intended to show payment pathways for telehealth using the “usual billing structure.” The revised version of the chart now specifically mentions home care services and rate codes under Billing Lanes 5 and 6 for “assessment and patient management” and “other services.”
HCA has communicated continuously with the Department over the last several days for more explicit practice, service and billing code recognition of home care in this guidance. We appreciate DOH’s responsiveness to our request. Members with questions or further needs on telehealth are encouraged to contact the HCA Policy staff.
Yesterday, Governor Cuomo issued another in a near-daily set of Executive Orders. Executive Order No. 202.10 “permit(s) registered nurses to order the collection of throat or nasopharyngeal swab specimens from individuals suspected of being infected by COVID-19, for purposes of testing.”In addition, the Executive Order allows a hospice residence to designate any number of beds within such facility as dually certified inpatient beds.
Another section of the order provides relief from record-keeping requirements. It mentions “relief to the extent necessary for health care providers to perform tasks as may be necessary to respond to the COVID-19 outbreak, including, but not limited to, requirements to maintain medical records that accurately reflect the evaluation and treatment of patients, or requirements to assign diagnostic codes or to create or maintain other records for billing purposes,” granting “absolute immunity from liability for any failure to comply with any recordkeeping requirement” if done so in good faith except in certain circumstances.
UPDATE: HCA has confirmed the applicability of this provision with state Department of Health officials who state that the reference does cover home care providers; however, the licensed home care professional is only protected from liability if they are not maintaining accurate patient records due to their COVID-19 response (e.g., having a patient surge due to a COVID-19 outbreak). Licensed home care professionals could not use this waiver provision generally to avoid keeping accurate patient medical records, regardless of the COVID-19 connection.
Please continue to watch our COVID-19 resources page for the latest summary of waivers or suspended regulations.
A special edition of the state’s Medicaid Update issued last night (see here) includes a guidance broadly expanding the use of telehealth, telephonic services and other communications methods by Medicaid providers during the COVID-19 state of emergency.
Effective for dates of service after March 1, and for the duration of the state of emergency, “New York State Medicaid will reimburse telephonic assessment, monitoring, and evaluation and management services provided to members in cases where face-to-face visits may not be recommended and it is appropriate for the member to be evaluated and managed by telephone.” HCA has confirmed with DOH officials that the guidance applies to Article 36 home care providers.
Discussions have escalated in the last 24 hours on long-sought state COVID-19 guidance and assistance for home care and hospice. Throughout the weekend, HCA has again discussed with state officials a list of pressing requests for regulatory relief waivers, priority access to supplies, procedural guidance, and financial support to help providers amid the pandemic.
A just-released Dear Administrator Letter for Certified Home Health Agencies and Licensed Home Care Services Agencies (see here) provides some information on screening of patients and staff, as well as on the responsibilities of personnel in observing patients at home. It followed another guidance, sent earlier today (see here), with regulatory guidance for 1915(c) waiver programs (addressed to providers serving children and youth under the Children’s Waiver).
Yet many other critical areas of support, procedural guidance and regulatory waiver are needed across all home and community-based programs and providers.To help better define this request, HCA asks that all home care and hospice providers immediately complete a brief survey here. The aggregate results will be shared with the Department. Please complete the survey as soon as possible and no later than Tuesday, March 17, at noon. The earlier we begin collecting responses, the sooner we can convey specific needs to the Department of Health.
Late last week, Congress passed an $8.3 billion aid package that includes some waivers allowing for telehealth, but these are mostly applicable to other settings (not home health and hospice), and HCA is seeking waiver authority more broadly for use of telehealth in place of in-person and supervisory home visits where appropriate. This is necessary to reduce exposure but also to cope with staffing shortages, as is the rationale for all of our many regulatory waiver requests so far requested at both the state and federal levels.
A CMS fact sheet on the national emergency declaration does reference the availability of relief on the timeframe for OASIS transmission yet without detail on what those relaxed timeframes are. (HCA is tracking down further information.)President Trump, in declaring a national emergency on Friday, announced yet another $50 billion in anticipated aid to assist states and localities to address the crisis.
The U.S. House of Representatives has passed a relief package and the President has expressed support. The Senate is expected to act in the coming week.The House package reportedly includes $6.7 billion in federal Medicaid assistance percentage dollars for New York, a large portion of which would go to the state, as well as allocations to New York City and counties.Meanwhile, there are continuing reports that the State Legislature is working to finish the state budget this coming week, well ahead of schedule, especially after word that two members of the State Assembly are among the over 700 confirmed COVID-19 cases in New York State.
It is unknown what this may mean for health care and Medicaid, as the state’s Medicaid Redesign Team (MRT) has been considering a package of $2.5 billion in cost reductions. It remains to be seen whether the MRT process is suspended in favor of a more expedited or stripped-down budget for Medicaid, including whether (and to what extent) a federal aid package may be a determining factor in the budget outlook.
HCA will continue to keep the membership apprised of all relevant updates. Most importantly, please complete our survey so we can report your needs directly to the Department.Please also look for the latest info on our home care emergency preparedness site including our COVID-19 resources page here.
The Medicaid Redesign Team (MRT) met today in New York City for a second time to review a consolidated list of proposals from among over 2,200 submissions by the public.
The dozens of proposed recommendations discussed today were wide ranging, such as: changes to the global cap methodology; program integrity provisions; health information technology reforms; new approaches to care management, social determinants of health, transportation, and workforce supports; revenue raisers (such as insurance and health care taxes); and program-specific structural, enrollment, procedural or payment recommendations for various sectors, including additional proposals advanced by a long term care advisory committee.
Many of these areas would touch the home care, hospice and Managed Long Term Care (MLTC) provider and plan infrastructure in a variety of ways. Continue reading “MRT Reviews Detailed Slate of Proposals for Consideration”
HCA has extended the deadline to March 12 for our 2020 awards nominations. Don’t miss this opportunity to recognize an exceptional colleague or staff member at your organization.
Our award categories invite nominations for all staff roles, from front-line caregivers to prominent leaders in the field, from physician champions of community-based care to the most ardent advocates and program innovators. Awards are presented at HCA’s Annual Conference on May 6-8 in Saratoga Springs.
To learn more and make your nomination, use our online questionnaire here.
If you have any questions or want to e-mail information directly to HCA, please contact Jenny Kerbein at email@example.com or (518) 810-0659.
Your nomination helps shine a light on home care’s most talented, honorable and commendable individuals. Their stories help bring visibility to what home care is, how it works, how it helps, and what makes it great. Please help tell this story in all of its many unique, individual ways, and join us in celebrating home care’s leading lights.
“No one should be surprised when we have positive cases” of novel coronavirus in New York State, remarked Governor Cuomo yesterday about the illness that has spread rapidly from its initial origins in China.
COVID-19 has now reached 37 countries, including 60 confirmed cases in the U.S. (at the time of this writing), with one case (announced yesterday) involving a person who “did not have relevant travel history or exposure to another known patient with COVID-19,” according to the U.S. Centers for Disease Control and Prevention (CDC).
While 83 people have been reportedly quarantined on a voluntary basis in Nassau County, there are no as-of-yet confirmed cases of the virus in New York State to date, according to reports. Yet national public health officials have warned of possible “community spread” in the future, the importance of preparation for such an event, and the prospect of future containment measures by public health or preparedness officials. Continue reading “Coronavirus Planning for Home Care, Hospice”
In a press conference today, Governor Cuomo announced that the federal government has denied New York’s request to continue the multi-billion-dollar Delivery System Reform Incentive Payment (DSRIP) program.
This means the state will be unable to use $625 million in unspent funds for the current $7.4 billion DSRIP waiver, as sought in a request to extend the program through March 2021. Also denied is a second phase of DSRIP, which would have provided $8 billion in federal reinvestment funds also sought by the Cuomo Administration through 2024.
A Senate and Assembly joint legislative committee convened today in Albany for a hearing examining the Governor’s state Medicaid budget proposals.
HCA President and CEO Al Cardillo submitted testimony, available here. It explains the vital role of home and community care, Medicaid budget trends involving home and community care (including new obligations and responsibilities on plans and providers), as well as HCA’s recommendations for offsetting Medicaid costs in place of cuts to assure the viability of vital programs and services. Continue reading “HCA Presents Testimony as Senate, Assembly Panel Examines Medicaid Budget”
The Governor today proposed a sequel to the Medicaid Redesign Team (MRT) process of 2011 as an approach to restructuring Medicaid and ensuring its long-term sustainability.
HCA understands the magnitude and seriousness of New York’s budget circumstances. This is why we have already presented the Governor’s office and Legislature with ready proposals to support Medicaid cost efficiencies and relief.
These cost offsets and reforms merit a voice at the MRT table. They leverage the capabilities of New York’s home and community-based care system to save millions of dollars through improved coordination of Medicare-Medicaid covered benefits, avoidance of higher-cost service utilization, enhancements in chronic disease management, efficient care transitions and direct cost-control and efficiency reforms. Continue reading “A Statement from HCA President and CEO Al Cardillo Regarding Governor Cuomo’s Proposed Budget”
Home Health Care News reports on the state’s 1% across-the board cuts to Medicaid. These come at a time when home care providers have not had a Medicaid cost-of-living rate adjustment in 10 years, and as providers operate on wafer-thin margins or losses in the majority of cases.
“In that light, this 1% reduction is extremely alarming,” HCA says in the article; and the cuts’ “timing, just before the release of a new budget proposal in only a few weeks, is a harbinger of just how serious the state’s fiscal outlook is — and what else is yet to come amid a projected $6 billion deficit.”
On behalf of HCA and the membership, New York State Health Commissioner Dr. Howard Zucker, M.D., J.D. has provided a meaningful and poignant year-end video message to home care and hospice providers.
“As we turn the calendar from 2019 to 2020, I extend warm thanks and appreciation to the many individuals delivering vital care at home to over half a million New Yorkers,” says Dr. Zucker.
He adds: “I also commend the Home Care Association of New York State for supporting this work through its mission: to ‘promote and enhance the quality and accessibility of health care and support at home.’”
HCA has posted the video to Facebook and YouTube. HCA members, colleagues and all organizations with Facebook accounts are strongly urged to share the video as widely as possible. In doing so, please join HCA in returning the thanks to Dr. Zucker for such powerful sentiments about the important work we do in community-based care.
Livanta, the new Medicare Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO), reports to HCA that many health care providers, including home health and hospice providers, have not signed a required Memorandum of Agreement (MOA) mandated of Medicare providers under Section 1866(a)(1)(E) of the Social Security Act.
Providers in New York were required to sign the MOA by June 8, 2019. Livanta has set a deadline of December 31, 2019 after which “instances of non-compliance will be reported to CMS,” Livanta states.
HCA has written about this requirement in our weekly newsletter, most recently on October 28, 2019, noting that 92 percent of home health agencies and 95 percent of hospices have not submitted the required form.
In the latest update, Livanta explains that unless you received an e-mail confirmation from the BFCC-QIO on October 1, 2019, your organization’s MOA has not been received. It is urgent that all Medicare providers complete this requirement of the Conditions of Participation (CoPs).
We also stress that all previously signed agreements were invalid as of June 7, 2019, so a new MOA must be completed if you have not done so already for this present period. Information about Livanta’s MOA process is available in this flyer or see the following web pages:
If you have any questions, please contact the Livanta Communications team here.
“Home health agencies provide interdisciplinary health care to individuals at home,” writes HCA President Al Cardillo in a viewpoint piece for the Legislative Gazette. “You may be familiar with some forms of this care. Thousands of exceptional people with specialized training make it happen, working together to overcome countless medical, social and environmental hurdles in too-often untold ways.”
The state Department of Health (DOH) has posted information on the actions that providers should take to prepare for the upcoming winter weather season. See here.
DOH recommends that all facilities and agencies review their Emergency Response and Evacuation Plans to ensure procedures are up to date and understood by staff and that contact information for all key staff and response partners is current. Providers should be ready to activate these plans when needed. Continue reading “Winter Storm Season Alert Posted”
Earlier today, Governor Cuomo declared a State of Emergency for Cayuga, Chautauqua, Cortland, Dutchess, Erie, Essex, Hamilton, Herkimer, Montgomery, Oneida, Saratoga and Warren Counties due to heavy rains and high winds that have caused flooding and power outages throughout most of the state. Continue reading “State of Emergency Declared in 12 Counties”
With sad and tragic news this week of a young boy passing from sepsis in Cohoes, NY, the Capital Region’s ABC affiliate, News 10 WTEN, spoke to HCA and medical experts on Tuesday about sepsis, including a bill that passed the State Legislature in June to support the work of home care providers in screening for this deadly condition.
“Our goal, particularly with the home health system, is to work not only to monitor, but teach the individual and the family what to look for and how to prevent” sepsis, said HCA President Al Cardillo in the interview. Watch the clip here and learn more about the legislation here. The bill (S.1817/A.3839) awaits action by the Governor.
“If you think compliance is expensive, try non-compliance,” former U.S. Deputy Attorney General Paul McNulty once wisely observed.
The toll is not just financial: as in government fines or penalties, civil liabilities, legal or recovery costs, or loss of licensure/operational privileges, which are bad enough. Noncompliance costs can also be counted in the form of grave reputational risks to your organization, straining or ruining relationships with referral sources or contractors at a time when state policies are imposing even greater restrictions and obligations on network contracts.
Most at stake is your hard-won trust with patients in the community.
HCA’s flagship Corporate Compliance Symposium provides your compliance officers and executive teams with the tools, resources, information and guidelines to overcome these risks. This includes procedural best-practices for self-auditing, so that your own internal investigations can detect pitfalls instead of government or law enforcement doing so on your behalf, and at great expense to your organization.
Each session covers prominent compliance issues by eight highly esteemed legal and compliance minds, all available to you at one time and one place. Don’t miss out.
Everything you need to know about sepsis detection protocols that are saving lives and reducing costs through home care — plus next steps for broader application (www.stopsepsisathomeny.org)
September is “Sepsis Awareness Month,” and the Home Care Association of New York State’s national-first sepsis screening program for home care nurses and providers is making major strides in addressing this medical emergency — sepsis — a condition that claims a life every two minutes (according to Sepsis Alliance) and is more likely to occur in the home and community than in a hospital.
“Data suggests that 80% to 90% of sepsis cases actually originate in the home or community,” says HCA President and CEO Al Cardillo. “This fact alone is one of many reasons why home care’s involvement in sepsis screening is so vital, and why protocols, like HCA’s program, are incredibly important when it comes to improving outcomes and saving lives in a home care population that is especially vulnerable. All sectors of the health care system have a responsibility to intervene — and, wherever possible, prevent — the tragic loss of life, morbidity and life-altering effects of this condition. The home care system is especially equipped to do so.” Continue reading “September is Sepsis Month: Thousands Now Screened by Home Care RNs for Life-Threatening Sepsis Using Innovative Tool”
Today, HCA and six other prominent health care associations wrote to the state’s Deputy Secretary for Health and Human Services Paul Francis with core recommendations and key amendments that the state should consider in its multi-billion-dollar 1115 Medicaid waiver renewal process. (See the letter here.)
Section 1115 of the Social Security Act gives the U.S. Secretary of Health and Human Services the authority to approve state-level experiments, pilots, or demonstration projects in Medicaid and the Children’s Health Insurance Program (CHIP) programs.
In response to an RFI soliciting public comments on regulatory relief, HCA on Monday provided the U.S. Centers for Medicare and Medicaid Services (CMS) with a set of recommendations to ease home care and hospice regulations.
Our recommendations include such areas as the retrieval of records, use of actual patients (versus pseudo-patients) in aide competency evaluations, coordination of documentation requirements with physicians, and a range of other proposals that, we believe, will align with CMS’s aim to make the health care system more effective, simple and accessible.
Sometime next week, without advance notice, the state Department of Health (DOH) will hold an Interoperable Communications (IOC) drill for the entire state.
However, the drill will take place on a rolling basis in staggered stages. As mentioned previously, the IOC drill will be targeted to home care, hospice and other providers across the entire state; though voluntary, it can be used to fulfill federal and/or state requirements for agencies to hold emergency preparedness exercises.
HCA holds a vast repository of over 100 reports – and thousands of home care, hospice and MLTC data cells – available exclusively to HCA members through our web-based HCA DATA platform.
These reports provide a major advantage for HCA members in their business and operations planning. They support and inform your financial benchmarking, local market analysis, strategic plan development, contract negotiations, consulting work, and many more functions across various departments.
Through HCA Data, you’ll find everything from big picture trends on statewide home care financial performance to operational data on every individual CHHA, MLTC, LHCSA and Hospice in the state. This data includes operating revenues and expenses across payors, cost factors for salaries and wages, payor mix, visit totals by discipline, caseload capacity by county, unit costs, medical expense ratios, live discharge data (for hospice), and many more items.
Give your CFOs, financial managers, chief strategy officers, operations managers and business planners the keys to this powerful resources today. Learn more and obtain an account here today!
New York City home care agencies put their emergency preparedness plans into action earlier this month during two July power outages that left tens of thousands of New Yorkers in the dark on two consecutive weekends: on July 14 and July 21.
Nurses, home health aides and other home care personnel play a vital role for patients during emergencies like these — just as they provide critical supports to vulnerable populations at home each day. This includes New Yorkers who are among the 2.5 million individuals nationally relying on home medical equipment, like in-home respiratory ventilators, that require reliable power to function.
Home care providers have plans in place to assist these and other patients living at home who are vulnerable to heat-related illness or environmental conditions during a disaster, especially a situation like the recent power outages coinciding with a wave of near-record high temperatures that gripped the metropolitan region.
“Your action to protect New York’s Medicare home health system (S.433/H.R. 2573) just reached a dramatically new level of urgency,” says an advocacy campaign message posted today on HCA’s Legislative Action Center.
Please send this message to Congress now, and share this action item widely with your staff and colleagues so that they act as well. It takes less than a minute of your time. Continue reading “Write Congress NOW: S.433/H.R. 2573 Imperative as Home Care Faces 8% Cuts”
The state Legislature remains in session at the time of this writing to consider a range of final bills, with an expected adjournment sometime tomorrow, according to reports.
Two HCA bills cleared both houses this week with votes in the Assembly yesterday following earlier passage in the Senate. They include HCA’s aide in-service tracking bill and our sepsis legislation.
HCA also participated in a press conference and media outreach yesterday, along with representatives from 20 other community-based provider associations and Assembly Health Committee Chairman Richard Gottfried, on a third bill related to health care transformation funds. Continue reading “HCA’s Sepsis, In-Service Bills Pass Both Houses”
HCA is receiving one of five Sepsis Heroes awards from Sepsis Alliance in recognition of our Stop Sepsis at Home initiative.
The award honors “Sepsis Heroes who have made a significant contribution to sepsis awareness and education among both the general public and health care professionals.” Awards are presented at an annual gala in New York City on September 12 during Sepsis Awareness Month. Learn more about the event here.
HCA’s Stop Sepsis at Home initiative has been adopted in 55 of New York’s counties where nurses are using the screening tool to potentially identify life-threatening cases of sepsis and help triage follow-up protocols.
HCA thanks Sepsis Alliance for this recognition, and we hope it elevates the importance of this initiative for the 80% of home care cases that originate in the home and community-based setting.
National home care, hospice expert brings unmatched experience and skills to HCA
HCA President Al Cardillo and the HCA Board proudly and enthusiastically announce the appointment of state and national home care expert Rebecca Fuller Gray as HCA’s new Executive Vice President for Clinical and Program Affairs. Ms. Gray starts her position on May 1.
HCA has learned that the “Employee Scheduling” rule, which was proposed by the state Department of Labor (DOL), will not be promulgated at this time, due to comments raised by HCA and other organizations who argued that the approach was impracticable to certain industries or sectors, like home care and hospice.
The rule, first proposed on November 22, 2017 and then revised on December 12, 2018, would have required employers to pay additional hours for “unscheduled shifts,” “cancelled shifts,” “on-call” and “call for schedule.” HCA had argued that the proposal was incompatible with how care at home is delivered, where hours are started, increased, decreased or eliminated due to reasons unique to home care and hospice and their patients, and beyond the control of the employer.
At today’s health and Medicaid budget hearing, HCA President Al Cardillo delivered testimony revealing the financing, workforce and overall support needs of the home care, hospice and Managed Long Term Care sector using data from our just-issued financial and trends report.
On January 8, HCA, the Hospice and Palliative Care Association of New York State and the New York State Association of Health Care Providers held a forum for state legislators and their staff offering background on home and community care services – in particular, home care, hospice/palliative care and MLTC – that may aid in:
- Assisting constituents, families and communities with their health care needs.
The Home Care Association of New York State, the Hospice and Palliative Care Association of New York State, and the New York State Association of Health Care Providers are jointly holding a January 8 Home and Community Care Services Open Forum for State Legislators and their staff at the Legislative Office Building in Albany. Details are in the flyer here. Continue reading “Home Care 101 for Legislators, Staff on January 8”
For Veterans Day, the Home Care Association of New York State (HCA) joins its home care, hospice and managed long term care provider members throughout New York State in recognizing exceptional individuals who have made the ultimate sacrifice through military service.
Our observance of veterans also coincides with National Home Care and Hospice Month in November.
HCA honors the wishes of patients, including our nation’s veterans, to live independently, with dignity, and with the medical,
social or assistive services to help them fulfill those wishes in the community setting.
If you are a veteran – or if your veteran constituents need care – HCA is proud to be a resource for services at (518) 426‐8764.
HCA, IPRO, HANYS, the Rory Staunton Foundation for Sepsis Prevention, Sepsis Alliance and partner organizations invite you to register for a first-of-its-kind All-Sector Sepsis Summit on October 3 in Albany.
Click the event page here for online registration and to download the brochure for the full agenda, which includes top state health officials, physician experts, representatives of the various health sectors, public policy and education partners, and quality and clinical experts.
This year’s state legislative session is expected to wind down very quickly in terms of the timeline and level of legislative activity, especially given statewide elections in the fall which will likely drive an early beginning to the summer campaign season.
As reported in several recent editions of The Situation Report newsletter, HCA has written a slate of proactive bills to support the home care, hospice and MLTC membership. HCA’s measures are designed to position the home and community based system favorably given the current political environment in which the Legislature and Governor are expected to concentrate on only a select range of issues for action.
Today, we need your grassroots help in writing to the legislative sponsors, bolstering their support for our initiatives while helping to raise the visibility of issues that affect home care, hospice and MLTC organizations.
What We Need You to Do Now
HCA has created a new landing page on our Legislative Action Center with seven messages of support for HCA’s bills that all members must send to the legislative sponsors as soon as possible.
Please act on all seven of these messages, each of which takes less than a minute of your time to send by entering your contact information and pressing a button on each action item. Your action will significantly augment our chances of success.
So, click the link to our Legislative Action Center, where you’ll see boxes for each action item. Click “add your voice” on each action item, read the short summary, enter your contact information, and send the messages today. Please do this for all seven messages.
With our Legislative Action Center, we’ve worked to make this process quick and easy for you, so your participation is imperative. Please also use the messages as a basis for making phone calls to the legislative sponsors as well. The more ways that they hear from you, the better our chances of success.
HCA has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) urging CMS to maintain its existing requirement for states, like New York, to submit an access monitoring review plan that holds states accountable on Medicaid access to care.
Under a rule known as the “equal access provision,” states are required to set Medicaid fee-for-service (FFS) rates to ensure access to services for Medicaid beneficiaries at a comparable level to non-Medicaid FFS-insured individuals. To hold states accountable for keeping competitive rates, CMS in 2015 began requiring states to submit an access monitoring review plan (or AMRP) every three years when rate changes occur (among other factors) to fee-for-service entities like Certified Home Health Agencies (CHHAs) and other FFS providers. Continue reading “In Letter to CMS, HCA Opposes Thresholds Exempting States from Having to Submit Monitoring Plans of Medicaid Access”
The state Department of Health (DOH) has posted a notice to home care agencies, medical directors and other provider representatives on the Health Commerce System (HCS) regarding an investigation into the reliability of a laboratory service provider’s glucose and potassium test results that could affect HCA members.
The notice, available here, states the following:
On 5/22/2018 the New York State Department of Health (Department) issued an Order for Summary Action against a laboratory service provider, Modern Diagnostic Laboratory Inc. due to findings of an investigation by the Wadsworth Center’s Clinical Laboratory Evaluation Program. The investigation determined that glucose and potassium test results were not reliable and in some instances falsely reported.
Today (5/23/2018), the Department issued an Amended Order for Summary Action against MDL. The Amended Order enables MDL to resume providing services under existing contracts. The Amended Order requires that MDL meet certain requirements, including but not limited to, the immediate employment of an independent consultant who will be approved by the Department, and the cessation of any inappropriate testing and reporting practices.
For providers seeking to contract with an alternative laboratory, a list of other approved laboratories can be found at the following link: https://www.wadsworth.org/regulatory/clep/approved-labs.
No other information is available at this time regarding actions that providers should take for lab services affected by these findings. HCA remains in communication with the Department for further information, which we will share in an alert to the membership or in our newsletter as necessary.
The Caring Award recognizes a staff person of an agency who has exhibited the compassion, skills and service that sets his or her contribution apart and/or whose actions on a particular day or over a period of time exemplify caring in home care.
Vicky Gentile, Home Health Aide at New York City-based Selfhelp Community Services
“Vicky Gentile embodies the caring, dedicated spirit we wish to be associated with our name,” says Selfhelp Community Services, noting Ms. Gentile’s exceptional care to patients.Continue reading “HCA’s 2018 Award Recipients”
HCA members serving Buffalo, Rochester and surrounding counties sent a letter this week to Western New York Congressman Chris Collins bolstering his support for legislation (H.R. 1825) to allow non-physician-practitioners (NPPs) to order and refer for home health services.
Rep. Collins is sponsor of this priority bill and has indicated his support to move it forward this Congressional session. The bill has widespread bipartisan co-sponsorship, including from 11 members of the New York House Delegation. Please see the list of House cosponsors here. If Representatives serving your patients are not on this list, please contact their offices to urge their co-sponsorship of H.R. 1825 so that we can keep up momentum on this priority bill. If you need any assistance, please contact HCA’s Communications Director Roger Noyes at firstname.lastname@example.org. Continue reading “WNY HCA Members Write to Rep. Collins on NPP Authorization Bill”
Conference: 40 Years Strong, HCA’s Annual Conference
Date: May 9-11, 2018
Registration is now open for HCA’s milestone Annual Conference celebrating our 40th year as an association with the theme 40 Years Strong.
Please help make this the best celebration yet, by registering today using the form at the back of our brochure here.
For this banner conference, we’ll be joined by special guest Bill Dombi, President of the National Association for Home Care and Hospice, as well as other expert presenters offering insights on all facets of home care operations.
These sessions, networking opportunities and more will help your organization plan for the future by: tackling emerging issues, enhancing your team’s performance, confronting public health and population health challenges, and optimizing your success with some of the biggest challenges happening to home care in decades.
HCA has prepared a 2018 report on the finance and program trends within the home care, hospice and MLTC sectors. This report is based on a statistical analysis of state-required financial documents, a survey of HCA’s membership, and other data sets. It provides aggregate data on financial margins, accounts-receivable balances, direct-care staffing vacancies and turnover rates, and other important findings within New York’s home care, hospice and MLTC sector.
The national push for extension of the home health rural add-on continues, as Congress considers extension bills and other fiscal matters amid the ongoing debate over the continuing budget resolution.
In a separate but important federal matter, HCA has also learned that key leaders are considering a priority bill for authorization of home care services as part of an omnibus package. The bill is sponsored by Buffalo-area Congressman Chris Collins and has strong support from New York’s Congressional Delegation who we need to press Congressional leaders for final adoption of this measure. Continue reading “Act Now on Home Health Rural Add-on, NPP Authorization of Home Care”
For a low cost of $149/$249 (member/non-member rate), HCA is offering an unlimited number of your HR, executive and management staff to get guidance from top legal experts on the law, policies-and-procedures, and staff training to address sexual harassment in the workplace and reduce your organization’s exposure to costly legal liabilities. Join our webinar on January 30 from 10 to 11 a.m. Continue reading “Webinar Offers Premium Legal Guidance for Home Care HR/Execs on Sexual Harassment Law, Procedures”
Yesterday, HCA submitted comments to the state Department of Labor (DOL) and testimony for a state Senate Hearing on DOL’s proposed scheduling/call-in pay rule, which would have major implications for health care providers, especially home care. Our comments are here and our testimony is here.
As described in numrous communications, the rule would impose the following requirements on employers (with certain exceptions):
An employee must be paid an additional two hours of call-in pay if reporting for a shift that was not scheduled 14 days in advance.
An employee whose shift is canceled within 72 hours of the scheduled start time must be paid at least four hours of call-in pay. Continue reading “HCA Submits Comments and Senate Testimony on Proposed Scheduling Rule”
End-of-the-year Congressional activity is putting home care at risk, and we need your action now to reach your Congressional Representatives in Washington.
Amid the flurry of activity is extender legislation that reportedly includes some version of the Home Health Groupings Model (HHGM) or other cuts that may be as high as $3 billion to $6 billion nationally over ten years, according to our partners at the National Association for Home Care and Hospice (NAHC).
Responding to a united voice of advocacy from the home care community, the U.S. Centers for Medicare and Medicaid Services (CMS) has withdrawn its Home Health Groupings Model (HHGM) from the final Calendar Year 2018 Medicare Home Health Prospective Payment System (HHPPS) rule, posted late this afternoon.
Noting the volume of technical comments on “various aspects of the proposed case-mix adjustment methodology under the HHGM,” CMS says that commenters “were most concerned about the proposed change in the unit of payment from 60 days to 30 days and such change being proposed for implementation in a non-budget neutral manner.”
HCA made this a major point in our comments on the rule, noting that “HHGM must be revised to be implemented in a true budget-neutral fashion,” we wrote. “Budget neutrality is an essential hallmark of past payment reform policies and is an important protection against system-wide fiscal destabilization.” Continue reading “In Win for Home Care, HHGM Withdrawn from 2018 HHPPS Final Rule”
ALBANY — The Home Care Association of New York State (HCA) commends New York Governor Andrew Cuomo for signing a bill, S.5016-A/A.6549-A, which assures home care and hospice provider input into local emergency planning, including essential-personnel access for home care and hospice staff to reach vulnerable patients when disasters strike.
HCA also applauds the bill’s legislative sponsors, Assemblyman Michael Cusick and Senator Andrew Lanza, for their tireless efforts to develop and frame this legislation for unanimous passage in both houses of the Legislature and for support from the Governor. Both legislators saw first-hand the enormous need for coordinated response in their Staten Island districts when Superstorm Sandy devastated the region.
For further background on the bill, please read HCA’s Memorandum of support here.
“From Superstorm Sandy, Hurricane Irene, and countless major snow emergencies across New York, we’ve seen home care and hospice providers ready to serve as a vital resource to assist local emergency managers in reaching vulnerable patients who may be alone or without power at home,” said HCA President Joanne Cunningham. “These efforts could be substantially enhanced with a greater voice for home care and hospice in the emergency management planning process, including for addressing ‘essential personnel’ status, as this bill does. Home care and hospice providers applaud Assemblyman Cusick and Senator Lanza for their staunch support of this important bill, and for working vigorously with the Governor’s office to get it signed into law.”
HCA’s upcoming Quality and Technology Symposium, on November 16 & 17 in Suffern, NY, is our signature conference geared for home care clinical managers, directors of patient services, quality improvement officers and strategic planners, including the executive teams at your organization who need to think big about the many quality and technology imperatives in home care.
BK Health Care Consulting chief Barbara Katz got rave reviews for her segment at one of HCA’s value-based payment programs last year, and we are thrilled to tap her unique expertise again for two exceptional sessions on November 16 and 17:
- An interactive seminar on clinician time and task-management to help you “climb out of chaos” and gain a “roadmap to sanity” while juggling constant change and running an effective operation; plus
- A segment on what is perhaps the biggest hot-topic in quality of care: meeting the new Conditions of Participation (CoPs) for implementing a Quality Assurance/Quality Improvement (QAPI) program.
In preparation for federal advocacy efforts on September 12, HCA has prepared a series of advocacy documents to guide our visits with lawmakers and their staff.
We encourage you to read these for a review of HCA’s messaging. Please also share them with your Congressional contacts to encourage their action on critical home care federal priorities.
Foremost among our concerns is the ongoing threat to Medicaid, posed by Congressional attempts to repeal and replace the Affordable Care Act, as well as the new Home Health Groupings Model that the U.S. Centers for Medicare and Medicaid Services (CMS) has proposed for 2019, with cuts of up to $1 billion from the system.
HCA is also pressing for: continuation of the Medicare rural add-on; Congressional opposition to hospice rebasing; and relief from regulatory burdens like the Medicare face-to-face rule, pre-claim review, and the current limits on practitioners permitted to order and refer for home care services.
See the PDF downloads below for more information.
- “Home Care Advocacy Ask: Regulatory Relief for Home Care Providers”
- “2018 Proposed Rule: Reject Drastic New HHGM Payment System for Home Care”
- “Continue 3% Medicare Add-On for Rural Home Health”
- “CMS Should Collaborate with Industry to Evaluate Impact of Hospice Payment Reform Before Implementing Any Rebasing Initiatives”
- “Why Medicaid Works – and Why AHCA Cuts are Wrong”
The state Department of Health (DOH) late yesterday sent a brief alert to LHCSAs, CHHAs and Hospices (see here) on “immediate action” to be taken for Hurricanes Irma and Jose preparedness efforts.
These actions include required updates and corrections to your agency’s contacts in the Health Commerce System (HCS), as well as provider readiness to use the HCS to assist in possible DOH survey efforts.
Program includes tabletop exercise that partly fulfills imminent CoP requirement; plus, group registration discounts offered for HCA members!
September 27, 2017
HCA presents a comprehensive full-day program on September 27 in Albany, during National Preparedness Month, that will delve into all critical and timely aspects of home care and hospice emergency preparedness affecting your operation.
The program features state health and emergency preparedness officials, including regional officers, planning managers and the Director of the Office of Health Emergency Preparedness, Michael J. Primeau, for insights on challenges and opportunities in home care and hospice preparedness. This is a great opportunity to share your experiences and concerns with top health emergency preparedness officials. Continue reading “Are You Prepared: Emergency Preparedness Essentials in Home Care & Hospice Settings”
One of our signature programs, HCA’s one-day Corporate Compliance Symposium (October 19 in Albany) is packed with five carefully designed sessions bringing the expertise of legal minds, top consultants, health association leaders and public officials to address your most relevant compliance worries, concerns and needs.
From big-picture considerations to the concrete mechanics of your compliance program planning, this conference will:
- Emphasize the focus areas targeted by government auditors (i.e., OMIG and OIG) so you can assure your readiness;
- Provide takeaways and best-practice guidance based on real-world cases of HIT- and HIPAA-related breaches and enforcement actions;
- Help you overcome exposure and identify new risks introduced by your participation in new integrated models of care; and
- Examine growing segments of the home care continuum that are drawing scrutiny and new regulatory activity from state compliance agencies.
Learn more. Check out the brochure and register online at the links below.
The Senate last week issued a draft health care bill with even deeper Medicaid cuts than the already adopted House plan.
HCA, meanwhile, has continued its work in collaboration with a New York coalition of health care organizations urging members of New York’s Congressional Delegation to resist the Senate measure, along with any consensus bill that would follow in like form. Continue reading “As Senate Bill Goes Public, HCA Heads to Washington Opposing Even Deeper Medicaid Cuts”
As Home Health Care News reports, “Lawmakers, too, were pushing for a delay to give agencies more time to comply with the significant changes. The Home Care Association (HCA) of New York worked with New York Congressman John Faso to urge CMS to delay the effective date as recently as March 27, when Rep. Faso sent a letter to CMS Administrator Seema Verma.”
“Home care providers understand the rationales and goals of the CoP changes, and they report vigorous and hurried efforts to get their staff trained and ready,” the letter reads. “Moving back implementation by six months will allow for all parties involved to be better prepared to operate and ultimately provide quality care to home care beneficiaries.”
Rep. Faso’s letter can be read here.
ALBANY — Today the state Assembly held a public hearing on home care workforce issues.
This hearing follows an earlier one, held last week (on February 22) in New York City. HCA sent the following statement in response to the February 22 hearing: https://hca-nys.org/policy-positions/hca-statement-state-assembly-hearing-on-home-care-workforce-issues.
Today’s HCA testimony in Albany was presented by HCA Executive Vice President Al Cardillo. The testimony can be downloaded from our website at: https://hca-nys.org/wp-content/uploads/2017/02/Testimony-of-Home-Care-Association-of-NYS_Homecare-Workforce-Hearing-2-27-2017.pdf.
“The public health system has been reconfigured to require and rely on ready access to timely, capable and person-centered home care,” Mr. Cardillo said. “Current governmental policies and reforms are rapidly and substantially deepening this reliance.” Continue reading “HCA, Member Providers Testify at NY Assembly Hearing on Home Care Workforce Issues”
Media urged to attend a second Assembly hearing on Monday in Albany (details are below)
HCA greatly appreciates the state Assembly’s focus on home care workforce issues during a hearing today in New York City and another hearing scheduled on Monday in Albany.
Home care workforce recruitment, retention and staffing shortages have long been a concern for providers, consumers, and aging and disabled New Yorkers.
Home care is a demanding occupation that requires a unique set of skills and aptitudes. A comprehensive set of solutions is therefore needed to support this vital workforce, along with adequate reimbursement from the state for labor and non-labor service costs at a time when home care providers and Managed Long Term Care plans alike are experiencing operating losses statewide.
Between 2010 and 2014, home care employment rose 43% in New York City. As of 2015, home health aides in New York City number 117,760, along with 71,390 personal care aides and 70,990 registered nurses in home care. Nevertheless, shortages and high turnover rates persist, causing enormous administrative cost and resource pressures for training and orientation in home care, not to mention disruption in the continuity of care. Continue reading “HCA Statement: State Assembly Hearing on Home Care Workforce Issues”
Today, HCA Executive Vice President Al Cardillo delivered testimony before a panel of the state Assembly and Senate on the Health and Medicaid portions of the proposed state budget. HCA’s written testimony is posted to our website here.
The hearing drew testimony from multiple sectors of health care, with stakeholders commenting on the Governor’s Executive Budget proposals and pursuing issues for the Legislature’s consideration in its own one-house budgets and/or resolutions.
Legislators also received testimony from officials at the state Department of Health, office of the State Medicaid Inspector General, Department of Financial Services and other offices representing the Executive on various components of the Health and Medicaid budget.
The Legislature addressed some important and sometimes pointed questions to state officials on issues of relevance to home care. This included: the state’s management of the Medicaid global cap and related Executive “super-powers” for rate changes; the state’s distribution of minimum wage funds to home care; the purview of the Governor’s proposed Health Care Regulation Modernization Team; and other issues. Continue reading “HCA Budget Testimony Stresses Payment, Regulatory, Workforce and Infrastructure Needs”
For immediate release: February 14, 2017
HCA Issues Home Care-Managed Care Financial Findings, State Budget Proposals
ALBANY — The Home Care Association of New York State (HCA) has issued its annual financial condition report on New York’s home care and managed care systems, along with a set of vital proposals for consideration in the 2017-18 state budget. These budget proposals cover the areas of home care and managed care Medicaid payment, regulations, workforce issues, and infrastructure investment.
The financial condition report is available here and the state advocacy agenda is here. They will be featured in HCA testimony on Thursday, February 16, before a joint legislative hearing on the health and Medicaid portions of the proposed budget. Continue reading “HCA Issues Home Care-Managed Care Financial Findings, State Budget Proposals”
HCA this week prepared and circulated two new federal advocacy pieces targeting a series of problematic home care regulations while calling for a one-year delay in implementation of the sweeping new Home Health Conditions of Participation (CoPs).
In a new document, entitled Home Care Advocacy Ask: Regulatory Relief for Home Care Providers, HCA targets five areas of regulation that demand change, consistent with our past advocacy efforts and support garnered from Members of New York’s Congressional Delegation. Continue reading “HCA Takes Aim at Federal Regs, Seeks CoP Implementation Delay”
The Medicare Payment Advisory Commission (MedPAC) recently voted unanimously to recommend an additional five-percent Medicare payment cut in the next annual rates for home health agencies. The recommendations also call on the U.S. Centers for Medicare and Medicaid Services (CMS) to implement a two-year rebasing of the home health prospective payment system (HHPPS) beginning in 2019.
MedPAC intends to incorporate these recommendations in its Report to Congress in March.
Yesterday, HCA President Joanne Cunningham sent a letter (see here) to MedPAC’s Executive Director, Dr. Mark E. Miller, raising “grave concerns” about MedPAC’s recommendations and the data assumptions underlying them. In the letter, also cc’d to New York’s Members of Congress, she presented some New York-specific home health agency financial findings that vary substantially from MedPAC’s aggregate national data assumptions. Continue reading “HCA President Responds on MedPAC Recommendations to Cut, Rebase Medicare Home Health Rates”
The state Department of Health (DOH) has sent an urgent alert to providers that the Health Emergency Data System (HERDS) is activated in preparation for Hurricane Matthew; providers (including home care and hospice) are required to submit data within three hours.
An alert is the “highest priority emergency communication” and “warrants immediate action or attention by the recipient,” according to the DOH communication.
Hurricane Matthew made landfall in Cuba at about 8 p.m. last night. It is a Category 4 storm carrying maximum sustained winds of 130 mph and moving north at 8 mph.
To plan for this event and its potential New York impact, DOH is requiring home care, hospice and other providers to complete one or more survey forms in advance of Hurricane Matthew. Providers should check the Health Commerce System (HCS) to access these required surveys and instructions.
All home care providers are urged to attend an important September 30 webinar (from 10:30 a.m. to noon) launching HCA’s home care screening tool and protocol for sepsis recognition and intervention.
We reported on the webinar in Monday’s edition of The Situation Report newsletter, but HCA just wanted to draw your attention to this important program, given recent alarms by the U.S. Centers for Disease Control and Prevention (CDC) about this top cause of health care morbidity and cost. (Please see our recent press release on the tool for more information and reasons why home care adoption of sepsis intervention is a top priority.)
The September 30 webinar is being hosted by IPRO, HCA and other key organizations. It is the first of three sessions on the adoption, integration and use of this sepsis tool in patient care. Continue reading “Free Sept. 30 Webinar to Launch Home Care Sepsis Screening Tool”
Gathering is part of the first-ever state home care association-led Public Policy Summit and Capitol Hill Advocacy Day on July 12-13
For immediate release: July 12, 2016
HCA Communications Director Roger Noyes: (518) 275-6961 (cell); (518) 810-0665 (office)
PHA Chief Operating Officer Jennifer Haggerty: (570) 510-5731 (cell); (717) 975-9448, ext. 22 (office)
WASHINGTON, D.C. – State home care associations from around the nation, including New York and Pennsylvania, are converging on Washington, D.C. this week (July 12 and 13) for the first-ever Public Policy Summit and Capitol Hill Advocacy Day.
The program is sponsored by the Council of State Home Care Associations. It includes policy discussions, presentations from federal bureaus on regulatory and payment issues, insights from D.C. political insiders, and advocacy visits with lawmakers.
The home care associations representing New York State and Pennsylvania are among the leading participants. Executives from the associations have outlined a robust federal advocacy agenda for the Council, its member associations, and individual home care agencies attending.
“July is a perfect time for state home care associations and their members to get the attention of lawmakers and federal officials on core payment and regulatory issues,” said Vicki Hoak, Chief Executive Officer of the Pennsylvania Homecare Association (PHA) and chair of the Council of State Home Care Associations, which collectively includes 37 constituent state associations representing home health care providers in their regions. “This first-ever summit brings hundreds of provider representatives to Washington, along with the leadership of their state home care associations, for a collective voice and problem-solving.” Continue reading “NY, PA Home Care Associations and State Colleagues Gather in D.C. Targeting Medicare Home Health Cuts, Onerous Mandates”
The Council of State Home Care Associations is headed to Washington on July 12 and 13 for the first-ever Home Health Policy Summit and Capitol Hill Advocacy Day. The following are a series of briefing papers (in PDF format) about core issues for home care reimbursement, regulatory relief and program needs.
- Home Health Copays and Regressive Payment Cuts Undermine Access to Services
- CMS Fails to Fix Face-to-Face Requirement with Home Care Providers Bearing Financial Losses
- NY Home Care Faces Double-Digit Losses, Reimbursement Controls and a Duty to High-Cost Patients – Yet CMS Continues to Sharpen Its Negligent Cuts
- 5 Reasons Pre-Claim Review Is Bad for Medicare Home Health Services
- Medicare’s Home Health Benefit (Fact Sheet)
HCA is offering several sponsorship opportunities for organizations that want to support — and gain exposure at — HCA’s first-ever Women’s Healthcare Leadership Summit on September 28 to 29 in Saratoga. What better or more positive way is there to promote your brand than at this important leadership program for women in healthcare? Continue reading “Invitation to Sponsor: First-ever Women’s Healthcare Leadership Summit”
HCA has prepared a special resource document that we hope all members find useful in communicating your value-proposition to DSRIP and Value-Based Payment Partners.
We wanted to make sure you saw this piece and find benefit in using it. We also invite you to put your own logo on this piece so that it is branded with your organization’s imprint. (See instructions below.)
Why did HCA create this piece? For several reasons. One, we have heard from many members that Delivery System Reform Incentive Payment (DSRIP) Performing Provider Systems (PPSs) and their committees may not understand home care’s role in the system and the infrastructure you already provide.
What’s more, in some cases, these committees and potential Value Based Payment (VBP) partners appear to be considering options for duplicating home care services from within other settings – in ways that may even interfere with the jurisdictional requirements of Article 36 (an area of concern that HCA is working to address in other venues).
We encourage you to share this document at PPS committee meetings and VBP stakeholder or partnership interactions so that the committees: know more about what home care does; learn some data on home care’s success in meeting PPS and VBP outcomes goals; and understand the regulatory structure that governs home care.
When sharing this document, we also encourage you to present agency-specific data and narratives to support your organization’s successes in achieving the broader points about home care’s value-proposition.
The document can be downloaded in two PDF formats. One format is a four-page document that can be printed and stapled in standard paper size. The other format is designed for 11-by-17-inch printing, front and back, so that it can be produced as a bi-fold. (HCA is happy to assist if you have difficulty printing this piece or need HCA to mail you copies.) Links are below:
- Standard (8.5-by-11-inch), four-page format: https://hca-nys.org/wp-content/uploads/2016/06/Dont-Reinvent-the-Wheel-4-page-color.pdf
- 11-by-17-inch bi-fold: https://hca-nys.org/wp-content/uploads/2016/06/Dont-Reinvent-the-Wheel-one-page-color.pdf
Want to co-brand?
Also, HCA is happy to work with you to include your logo on this piece so that it is a co-branded document with your organization’s imprint alongside HCA’s logo.
Please contact HCA’s Communications Director Roger Noyes if you are interested in co-branding with HCA. Just send an e-mail to email@example.com and we’ll work with you to make this document as effective as possible for your purposes by inserting your logo along with HCA’s.
As you read in Friday’s ASAP newsletter, HCA recently sent a letter to New York’s Congressional Delegation expressing firm objections to a recently announced “prior-authorization” demo for Medicare home health services.
We are asking Congress to weigh in with the U.S. Centers for Medicare and Medicaid Services (CMS) to rescind this disastrous rule, but we need your help to echo our concerns with your Congressional representatives.
Today, HCA has posted a message to our Legislative Action Center allowing you, your staff, your board, and others to write Congress in opposition to CMS’s proposal. This message stresses: access-to-care impacts of the rule; the unprecedented overreach of presumptive pre-payment audits at the outset of care; the steering of authority from provider-level care-transitions teams to third-party bureaucrats contracted for prior-authorization; and the fact that existing audit problems (like denials for obscure documentation rules) would be extended to the prepayment phases of initiating care.
Please send this message today. It takes about a minute of time and we need hundreds of providers to write Congress to ensure that our voices are heard. All you need to do is visit the campaign link at http://p2a.co/jwEDFGY, enter your contact information and click “Send Email.” Please urge your staff to do the same.
HCA is excited to formally introduce Bring The Vote Home New York (BTVH-NY).
HCA President Joanne Cunningham previewed this new campaign at HCA’s Annual Conference earlier this month. Today we are formally launching New York’s version of this national initiative, which is helping home care patients get registered and able to vote, so their voices are heard in the political process.
Bring the Vote Home is taking place in states across the country, including New York. In essence, the campaign offers an easy process for your staff to distribute forms during home visits so their patients can register and receive an absentee ballot. HCA is sponsoring the New York part of the campaign. Continue reading “HCA Invites You to Bring The Vote Home-NY”
HCA and provider association colleagues (the Health Care Association of New York State and the Medical Society of the State of New York) are co-sponsoring a free June 2 webinar, facilitated by National Government Services (NGS), outlining Medicare home health eligibility and documentation requirements.
The webinar runs from 10:30 a.m. to noon and you can register here.
Since the inception of the Medicare home health face-to-face rule, HCA has been at the forefront of efforts to seek a repeal of the requirement or, barring repeal, changes to the rule that would ease the duplicative and costly documentation mandate for home care providers
The U.S. Centers for Medicare and Medicaid Services (CMS) has released a final rule that covers many aspects of Medicaid managed care.
The rule and fact sheets are at https://www.medicaid.gov/medicaid-chip-program-information/by-topics/delivery-systems/managed-care/managed-care-site.html.
The rule covers long term services and supports (LTSS); care coordination; provider screening and program integrity; subcontractual relationships; quality; beneficiary information and appeals; delivery system reform efforts; and other areas.
Last July, HCA had submitted extensive comments on the then proposed rule, which can be viewed at https://hca-nys.org/letters-and-comments/comments-on-medicaid-managed-care-proposed-rule
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 will be reviewing the final rule – which, including public comments and CMS’s responses, is over 1,000 pages – to learn if the issues we raised were addressed, and to determine which provisions will affect managed care in New York.
A full summary of the provisions is provided below. Continue reading “Final Medicaid Managed Care Rule Released “
OMIG has released its 2016-17 Work Plan, detailing the areas of focus in the Medicaid program for State Fiscal Year April 1, 2016 to March 31, 2017.
According to OMIG, this year’s Work Plan continues a focus on organizing work according to categories of service. Building on the 2015-16 Work Plan, OMIG continues to utilize its Business Line Teams across a number of areas, including but not limited to the Delivery System Reform Incentive Payment Program (DSRIP), Managed Long Term Care, Transportation, Home and Community Care Services, and Managed Care.
Further, OMIG will continue to emphasize provider outreach and education, particularly focusing on providers having proactive compliance programs that will prevent or, when necessary, detect and address abusive practices.
The 2016-17 WorkPlan, and plans from previous years, are at: https://www.omig.ny.gov/index.php/information/work-plan. It outlines several areas of focus in home care, LTHHCP and CHHA rates, compliance program review and managed care.
The following are some areas of OMIG focus in the 2016-17 Work Plan follow. Agencies should use these targeted activities, along with the OMIG audit protocols and other materials on the OMIG’s website, to strengthen their ongoing compliance work. Continue reading “OMIG 2016-17 Work Plan Now Available”
HCA this week submitted comments in strong support of long-sought proposed changes to the state’s physician order and billing deadlines for home care. Our comments are at https://hca-nys.org/wp-content/uploads/2016/04/DOHsProposal_90DayPhysicianOrderFlexibilit-March28.pdf.
These proposed changes, initiated and drafted by HCA, have been a long time in the making, and HCA this year succeeded in getting the Department of Health to consider these vitally needed changes. The proposal would align the state’s deadlines with the broader timetables allowed under Medicare. The proposed changes were further recommended and advanced by the Home and Community-Base Care Workgroup. They would apply to CHHAs, LHCSAs and LTHHCPs.
As HCA President Joanne Cunningham said in a statement to Crain’s Health Pulse in February, when the proposed rule was posted, “We appreciate the state’s support for a sensible timeline that has worked under Medicare. This proposal ensures that providers and physicians can focus on the initiation or modification of the care itself.” Continue reading “HCA’s Comments Voice Strong Support for Physician Signature, Billing Flexibility Proposal”
HCA this week submitted a strongly worded comment letter opposing a prior authorization demo for Medicare home health services being floated by the U.S. Centers for Medicare and Medicaid Services (CMS).
We are also part of a nationwide effort, in collaboration with partner state associations throughout the country, weighing in jointly on the rule, all calling for the rule to be rescinded. Continue reading “HCA Opposes CMS Prior Authorization Proposal”
This week, President Obama released his 2017 proposed budget. While the provisions are not expected to pass as part of the budget, various provisions could become part of other Congressional actions, and HCA will remain vigilant in monitoring such legislation.
A summary of the health provisions is at http://www.hhs.gov/sites/default/files/fy2017-budget-in-brief.pdf. Additional information is at https://www.whitehouse.gov/omb. Continue reading “President Obama Releases 2017 Proposed Budget”
Updated January 25, 2016
HCA’s State Advocacy Program is on February 1 and 2 in Albany. Below are some resources to register and learn more about what HCA is seeking as part of the state budget process and 2016 legislative session. Please check this page regularly for updates.
HCA invites you, one of New York’s exceptional home care leaders, to attend our 2016 Advocacy Day for Home Care Leaders on February 1-2 in Albany.
The program begins at 6 p.m. on the evening of February 1 with a special fundraising reception hosted by HCA’s Political Action Committee (PAC) for Senate Health Committee Chairman Kemp Hannon who will address attendees, followed by our main Advocacy Day program on February 2 beginning at 9:30 a.m.
HCA presents Your Admission to HCA 2016, a simple process for renewing your membership. Simply:
- Complete an online form.
- Provide your contact information and select your dues category (corresponding to your agency’s current annual revenue).
- Based on your responses to this online form, we will either mail you an invoice or contact you about alternative payment methods (i.e. credit card).
Find your membership category and complete the online form at the links below.
- Non-government-sponsored CHHA, LTHHCP, LHCSA members: RENEW NOW
- County or government-sponsored home care agency members: RENEW NOW
- Associate members: RENEW NOW
- Vendor members: RENEW NOW
If you are not yet a member of HCA — or want to learn more about HCA’s accomplishments in 2015 — please download our member value statement and annual report called ‘Outcomes’ & ‘Process’ Measures: How HCA is Working for You.
Questions about HCA Membership can be directed to:
Senior Director of Membership
HCA participated in a meeting yesterday with the state Department of Health (DOH) officials to review DOH-revised survey instruments for home care agencies and hospices for completion and tracking during public emergencies.
Specific parts of a multipart survey process are designed by DOH to be put into motion in emergencies depending on the nature, extent and details of the emergency.
The sections of the survey include basic agency and patient information, agency surge capacity resources and/or assistance needs, evacuation and repatriation information, and others.
The Department also reviewed a survey intended for completion by hospice providers to determine the status and extent of emergency preparedness planning.
The Department also plans to issue in the next several months a Dear Administrator letter reminding, clarifying and stipulating for providers the required contact persons and roles for indication on the Health Commerce System (HCS). HCA reminds providers to check their agency’s contacts currently listed/required for the HCS to be sure that all such individuals and related information is accurate and up to date.
HCA’s home care agencies and hospices can review the draft surveys at the links below and provide HCA with any further comments on the survey, which we, in turn, will add to our feedback to the Department.
- Home Care Emergency Evacuation Survey
- Home Care Emergency Repatriation Survey
- Home Care Emergency Survey: Agency Form
- Home Care Emergency Survey Capacity Form
- Home Care Abbreviated Emergency Response Provider Survey
- Hospice Emergency Planning Survey
DOH plans an HCS emergency preparedness drill this spring using the revised survey tools. HCA requested and DOH agreed to conduct a webinar, likely to be held in February, providing a walk-through of the surveys and an opportunity for exchange with the home care sector.
For further information, please contact Al Cardillo at firstname.lastname@example.org.
During a state Department of Health (DOH) Managed Care Policy and Planning meeting this week, DOH provided key updates on changes it is implementing in the Fully Integrated Duals Advantage (FIDA) Program which home care provider contractors and plans should take note of. The changes are as follows:
- Passive enrollment is suspended until further notice, except in limited circumstances (such as plan drops out of FIDA).
- DOH will be monitoring the effect of these changes prior to expanding enrollment into region 2 (Suffolk and Westchester) and does not expect it to start until after mid-2016.
- The coverage continuity period for out-of-network providers remains 90 days or until a Person Centered Service Plan (PCSP) is developed and implemented, whichever is later.
- Plans may use the existing MLTC schedule for completion of a participant’s Uniform Assessment (UAS) if the Participant is transferring from a sister MLTC/PACE/MAP plan; i.e., each FIDA enrollee transferring from a sister plan need not complete a new assessment until six months from the date of their last MLTC assessment.
- The FIDA plan must contact the participant and review any available medical record and claims history from the pre-enrollment period to determine changes in health status, health event, or needs that would trigger an updated UAS.
- If an updated UAS is required, it will be conducted within six months of the last UAS, and development of PCSP implemented within 90 days following the enrollment effective date.
- All other participants have a PCSP deadline of 90 days from the enrollment effective date.
Assurance and Participant Satisfaction
DOH/CMS and the Contract Management Team (CMT) will evaluate the FIDA Plan’s IDT delivery and operations. Specifically, the CMT will assess a Plan’s IDT performance against the following existing measures:
- In the last six months, did anyone from the participant’s health plan, doctor’s office, or clinic help coordinate care among these doctors or other health providers?
- How satisfied is the participant with the help in coordinating care in the last year?
- What is the percentage of participants discharged from a hospital who were readmitted within 30 days, either for the same condition as their recent hospital stay or for a different reason?
- What is the percentage of patients 65 years or older discharged from any inpatient facility and seen within 60 days following discharge by the physician providing on-going care, who had a reconciliation of the discharge medications with the current medication list in the medical record documented?
- What is the total percentage of all participants who saw their primary care doctor during the year?
- What is the percentage of participants in FIDA who reside in a nursing facility (NF), wish to return to the community, and were referred to preadmission screening teams or the Money Follows the Person Program?
- What is the number of nursing home-certifiable participants who lived outside the NF during the current measurement year as a proportion to those during the previous year?
- Follow-up required after hospitalization for mental illness.
- CMS has committed to an upward adjustment related to the Medicare Part A and B rates for all of 2016 and 2017.
- The 2016 rates are not yet final but will be retroactive to January 1, 2016.
- CMS will send rate letters to plans explaining the adjustment.
- CMS is conducting additional analysis of the Part D bids.
- CMS is open to reconsidering the assumptions used in determining the adjustment for calendar year 2016 based on revised projections of enrollment and recent experience in the demonstration.
- The quality withhold (QW) is effective upon execution of the Three-way Contract Amendments.
- The 2015 and 2016 quality withhold (QW) payments will be tied to participation through December 31, 2016. This will essentially add a new criterion to the QW calculation that excludes an organization from receiving QW amounts if the organization does not participate at least through 2016. (QW amounts are 1 percent of rate in 2015 and 2 percent in 2016).
- For any plans that do not continue through December 31, 2016, quality withhold amounts from 2015 and 2016 will be pooled and added to amounts earned by FIDA plans participating on January 1, 2017 (based on 2016 performance).
- The participant has a right to choose the make-up of its Interdisciplinary Team (IDT) and its members. The IDT can consist of just a care manager and participant, or broader, with a variety of members (from the original IDT list).
- IDT members may meet at different times. The care manager may separately meet with different IDT members in developing the PCSP.
- Provider participation in an IDT is adjustable, depending on member availability, items being discussed in a given meeting, or the needs, wishes, and goals of the participant.
- Primary care providers may sign off on a completed PCSP without attending IDT meetings.
- Plans have authorization over any medically necessary services included in the PCSP that are outside of the scope of practice of IDT members.
- IDT training will be encouraged, but not
- Plans develop their own procedures for communication among IDT members.
- Plans retain responsibility for effective and efficient information sharing among providers (including non-IDT participants), including any PCSP revisions.
- DOH/CMS and the Contract Management Team (CMT) will evaluate the FIDA plan’s IDT delivery and operations.
- FIDA plans must meet Medicare-Medicaid Plan Model of Care (MOC) elements and consistently update MOCs to reflect changes to the IDT policy.
- The CMT will assess a Plan’s IDT performance against specific data collected and percentages calculated.
- Completion of the bi-weekly and monthly dashboards is no longer required.
- DOH/CMS will streamline several reporting measures (e.g., NY1.1, NY1.2, and NY2.1) based on the new IDT policy (to be released). Changes to these measures would be applicable beginning with the 4th quarter of 2015 (October – December) reporting period.
Plans now have authorization to do the following:
- Market multiple lines of business under the Medicare Marketing Guidelines.
- Provide a written or verbal comparison (either DOH/CMS prepared or plan-prepared) among their MLTC (Partial, PACE, MAP) and FIDA programs.
- Conduct outbound FIDA marketing calls to individuals enrolled in any other Medicaid or Medicare product line with the plan or company.
- Organize in-person appointments if they are solicited by the individual.
- Conduct promotional activities and make nominal gifts at the Medicare Marketing Guidelines levels ($15).
- Send, with a prior approval from DOH/CMS, FIDA educational materials (e.g., letters, newsletters, etc.) to participants who have opted out.
- Plans may submit enrollment requests to Maximus (consistent with MLTC procedure). Maximus will process the enrollment and send letters, which include Independent Consumer Advocacy Network Independent Consumer Advocacy Network Independent Consumer Advocacy Network Independent Consumer Advocacy Network (ICAN) contact information, to the individuals that: 1) confirms the Participant’s enrollment in FIDA; 2) informs the Participant that choice counseling is available through Maximus; and 3) informs the participant of the option to switch or disenroll from a FIDA Plan at any time.
- Plans may remain on the phone when prospective participants call Maximus.
- Plans do not have to include both the plan phone number and enrollment broker number in their marketing materials.
ADA Attestation Form
- No provider should be terminated from a FIDA plan network for not answering in the affirmative to elements on the form.
- The form is to help FIDA participants identify which providers offer specified accessibility features.
- Completion or non-completion of the form, or responding in the affirmative to elements included therein does not alter existing obligations to comply with the Americans with Disabilities Act (ADA).
- FIDA plans must maintain a complete and accurate provider directory, including information collected by the form. FIDA plans have discretion on how to address provider refusals to complete the form.
- DOH will release the full set of FIDA Reforms, including an updated IDT policy.
- Reforms are effective immediately unless otherwise stated.
- Plans should make sure that they participate in the Friday FIDA plan conference calls.
This post provides an October 2015 emergency preparedness update for the home and community services sector. It coordinates information from several recent state and regional emergency preparedness communications. (You can download this update in memo format as a PDF here.)
HCA is a collaborative partner to the New York State Department of Health for statewide emergency preparedness efforts. HCA thanks the Office of Health Emergency Preparedness (OHEP), the Office of Primary Care and Health Systems Management (OPHSM), the regional Health Emergency Preparedness Coalitions (HEPCs) and the Regional EP Training Centers (RTCs) for this ongoing partnership, support and resource.
The state Department of Health (DOH) has yet again issued its monthly Medicaid Global Cap report. This latest report, for July, covers the period ending July 31 and beginning at the start of the fiscal year: on April 1.
It finds that overall spending for this period was $4 million below Medicaid Global Cap projections, across all sectors, a difference of $5.984 billion in actual spending versus $5.988 billion in estimated spending for the four-month period. Continue reading “July Medicaid Global Cap Report: Spending $4M Under Projections”
The Office of the National Coordinator for Health Information Technology (ONC) has released the updated Federal Health IT Strategic Plan 2015-2020 at http://www.healthit.gov/policy-researchers-implementers/health-it-strategic-planning. Continue reading “Final Federal Health IT Strategic Plan 2015-2020 Released”
The state Department of Health (DOH) has posted a summary of the Nursing Home Transition and Diversion (NHTD) and Traumatic Brain Injury (TBI) Transition Workgroup meeting held on August 24 and Frequently Asked Questions (FAQs) related to the Workgroup.
The materials are available at http://www.health.ny.gov/health_care/medicaid/redesign/mrt_90.htm. Continue reading “NHTD & TBI Transition Workgroup Materials Posted”
The New York State Office for the Aging (SOFA) is conducting a survey related to state legislation that authorizes it to study the feasibility of creating an Office of Community Living “with the goal of providing improvements in service delivery and improved program outcomes that would result from the expansion of community living integration services for older adults and persons of all ages with disabilities.”
A primary component of this effort is data and information collection through working with stakeholders. SOFA has developed a stakeholders group and is holding public forums throughout the state.
SOFA is conducting a survey of consumers and providers about the possibility of creating a new state Office of Community Living. The provider survey is at https://bostonu.qualtrics.com/jfe/form/SV_b28zoikIEQnU2BD.
More information on this effort is at http://www.aging.ny.gov/CommunityLiving/index.cfm.
The state Department of Health is expanding the NYSE-CON application to allow pre-opening inspections for Certificate of Need (CON)-approved projects, utilizing the “Regional Office” tab in NYSE-CON.
The Regional Office tab, available since May 2015, is accessible when CON projects have been approved and contingencies have been satisfied.
The tab now enables applicants to create project phases, attach documentation for DOH review prior to the pre-opening inspection, and receive communications from DOH staff regarding the preopening inspection.
Additional information can be found at http://www.health.ny.gov/facilities/cons/nysecon/.
Questions can be directed to email@example.com.
The U.S. Centers for Medicare and Medicaid Services (CMS) has posted a transmittal that provides detailed information on its Medicare Care Choices Model (MCCM).
The transmittal is at https://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R121DEMO.pdf.
Under MCCM, Medicare and dual eligible beneficiaries with advanced cancers, chronic obstructive pulmonary disease, congestive heart failure, or HIV/AIDS who meet hospice eligibility requirements under the Medicare hospice benefit will be eligible to receive palliative care services from certain hospice providers while concurrently receiving services from curative care providers. Continue reading “Transmittal Issued on Medicare Care Choices Model”
This week, the U.S. Centers for Medicare and Medicaid Services (CMS) Office of Minority Health unveiled the first CMS plan to address health equity in Medicare. Its plan focuses on six priority areas and aims to reduce health disparities in four years.
The Equity Plan focuses on Medicare populations that experience disproportionately high burdens of disease, lower quality of care, and barriers accessing care. These include racial and ethnic minorities, sexual and gender minorities, people with disabilities, and those living in rural areas.
The six priority areas include expanded collection and analysis of standardized data; integration of equity solutions across CMS programs; developing approaches to reduce disparities; health care workforce; improving communications and language access for those with limited proficiency; and increasing the physical accessibility of health care facilities.
To learn more, visit: https://www.cms.gov/About-CMS/Agency-Information/omh/index.html.
Medicare has contracted with a Supplemental Medical Review/Specialty Contractor (SMRC) that is evaluating medical records and related documents to determine whether claims were billed in compliance with coverage, coding, payment, and billing practices.
However, some providers may not be getting the medical records because the provider address is incorrect or because they do not know about the SMRC.
New York’s Medicare Administrative Contractor, National Government Services (NGS), urges all providers to update their addresses in the National Plan and Provider Enumeration System (NPPES). The SMRC uses this source to mail additional development requests (ADRs) for medical records; an incorrect address can result in records being returned and, as a result, claims being denied.
NGSConnex and IVR Systems Not Available this Weekend
NGS also reports that, due to scheduled maintenance, NGSConnex and the Interactive Voice Response System (IVR) systems will not be available this weekend.
For further information, contact Patrick Conole at (518) 810-0661 or firstname.lastname@example.org.
Home care and personal care spending slightly above projections
The state Department of Health (DOH) has issued its June 2015 Medicaid Global Spending Cap Report.
It shows overall spending to be $11 million less than projected for the current fiscal year through June. (The current state fiscal year began on April 1, 2015 and ends March 31, 2016.) Continue reading “DOH Releases June 2015 Global Cap Report”
eMedNY has notified providers of rate changes for certain services under the Nursing Home Transition and Diversion (NHTD) waiver program. Also, the state Department of Health (DOH) has announced a stakeholder group for the transition of the NHTD and Traumatic Brain Injury (TBI) programs to managed care.
The following rate changes were implemented July 13 and are effective retroactive to April 1, 2015: Continue reading “Some NHTD Rates Change: New TBI Rates Coming Soon”
The state Office of the Medicaid Inspector General (OMIG) has posted revised (July 3, 2015) audit protocols for the Traumatic Brain Injury (TBI) program.
They are available at https://www.omig.ny.gov/images/stories/audit_protocols/tbi_protocol_7_3_2015.pdf.
The protocols cover: missing/incomplete service plan; missing documentation of service; billed more hours than authorized or documented; incorrect rate code billed; services performed by unqualified staff; staff training not completed; failure to meet health requirements; and other issues.
HCA members providing TBI services are strongly advised to review the revised audit protocols for compliance purposes.
National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), has recently posted the following information to its website.
- Impact of Sequestration on Hospice Aggregate Cap – NGS has drafted a notice that includes an example informing hospice providers of how sequestration will be handled within the aggregate cap determinations starting with the 2013 cap calculation and beyond. NGS will calculate the aggregate cap determinations by adding the sequestration and net reimbursement amounts together found on the Provider Statistical and Reimbursement (PS&R) report to determine the pre-sequester reimbursement amount. The pre-sequester reimbursement amount will be compared to the allowable Medicare payment amount which will determine the hospice’s pre-sequester payment in excess of the cap amount. If there is a pre-sequester payment in excess of the cap, that amount will be reduced by 2 percent. This amount cannot be greater than the sequestration amount found on the PS&R report. Therefore, these two amounts will be compared and the lesser of the two will be applied to the calculation.
On July 28, the Uniform Assessment System (UAS-NY) online application was upgraded from version 7.18 to version 7.23.
Upon login to the UAS-NY, users are presented with a list of all required and recommended training courses that are completed and not completed. Users will now have the option to “Show All Courses” or “Hide Completed Courses.”
Version 7.23 will limit the timeframe for creating an assessment. Users may only initiate an assessment if the Assessment Reference Date is no more than 30 days prior to the current date. For example, if the current date is July 24, 2015, a new assessment may be initiated if the Assessment Reference Date is between June 24, 2015 and July 24, 2015.
The state Department of Health (DOH) has posted a General Information System (GIS) message to advise local departments of social services (LDSS) that an annual review of managed care exemption (91) and exclusion (90) Restrictive/Exception (R/E) entered codes should take place.
With most Medicaid populations transitioning into mandatory managed care, DOH stresses the importance of placing an end date on 90/91 R/E codes to avoid impeding managed care enrollment.
The GIS is at http://www.health.ny.gov/health_care/medicaid/publications/pub2015gis.htm (see GIS 15 MA/012).
Livanta has been operating as the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) since August 1, 2014. It is responsible for reviewing all Medicare discharge appeals and quality of care concerns for beneficiaries in many states, including New York.
Livanta has created a bulletin which offers several important reminders regarding standards of practice for physical therapy (PT) and discharge appeals.
Livanta has asked us to share this latest bulletin with our provider membership and we recommend that you forward this information to the appropriate staff in your agencies. It is at https://hca-nys.org/wp-content/uploads/2015/08/PTDischargePlanningReminderFinal.pdf.
For further information, contact Patrick Conole at (518) 810-0661 or email@example.com.
The Public Health and Health Planning Council (PHHPC) met on August 6 where it approved all of the following items:
- One application for a change in ownership by a CHHA that serves the general population in Greene, Orange, Ulster and Westchester as well as the developmentally disabled population in Dutchess, Putnam, and Sullivan.
- Under another application, the same entity proposes a change in ownership of its CHHA and LTHHCP that serves western New York.
- Applications by 29 entities (8 outside of the New York City metropolitan area) to establish a LHCSA; and
- Applications by 10 LHCSAs for a change in ownership (including 3 outside of the New York City metropolitan area).
The meeting materials are at https://www.health.ny.gov/facilities/public_health_and_health_planning_council/meetings/2015-08-06/.
This week, the U.S. Centers for Medicare and Medicaid Services (CMS) announced the participants in the Medicare Care Choices Model.
The Choices Model provides Medicare beneficiaries who qualify for coverage under the Medicare hospice benefit and dually eligible beneficiaries who qualify for the Medicaid hospice benefit the option to elect to receive supportive care services typically provided by hospice, while continuing to receive curative services. Continue reading “Medicare Care Choices Model Awards Announced”
The National Association for Home Care and Hospice (NAHC) reports that the federal Occupation Safety and Health Administration (OSHA) has issued Instructions for general enforcement policies and procedures to be followed when conducting inspections and issuing citations related to occupational exposure to tuberculosis (TB). Continue reading “OSHA Issues Revised TB Inspector Instructions “
The U.S. Centers for Medicare and Medicaid Services (CMS) has made available, beginning July 20, provider-specific comparative data reports for Home Health Agencies.
The Program for Evaluating Payment Patterns Electronic Report (PEPPER) summarizes claims data statistics for areas that may be at risk for improper Medicare payments. PEPPER is a free report comparing an agency’s Medicare billing practices with other agencies in the nation, Medicare Administrative Contractor (MAC) jurisdiction, and state. Agencies can use the data to support internal auditing and monitoring activities. Claims statistics include:
- Average case mix
- Average number of episodes
- Episodes with 5 or 6 visits
- Non- Low Utilization Payment. Adjustment (LUPA) payments
- High therapy utilization episodes
- Outlier payments