Category: Letters and Comments

HCA Comments on 2018 HHPPS, with Focus on HHGM Payment Cuts

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

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

HCA Supports Delay in Home Health CoP Changes

HCA has written comments in support of an April 3, 2017 proposed rule that would extend the deadline for implementation of the new home health conditions of participation (CoPs).

HCA was among the first associations to formally call for a delay in the new CoPs, which are slated for a July 13 start date. Notably, we gained strong support from New York Congressional Rep. John Faso who wrote to CMS calling for a six-month delay. Within days of Rep. Faso’s letter, CMS issued the April 3 proposed rule to implement the delay, triggering a public comment period to gain stakeholder responses about whether to suspend implementation until January 13, 2018.

The new CoPs are the most sweeping changes to federal home health regulations in 20 years, and HCA has recently held education programs to prepare providers for the rules, which touch on virtually all aspects of an agency’s operations. In seeking a delay, HCA and others stressed the incredibly short timeframe for providers to prepare and the fact that CMS, still, has yet to circulate Interpretive Guidelines that would further outline the enforcement process for these new regulations.

Read our letter of support here: https://hca-nys.org/wp-content/uploads/2017/05/Medicare-CoPs-proposed-rule-delay_comments_final_051117.pdf.

HCA Calls on Congress to Oppose ACA Repeal and Replacement Bill, With Its Deep Cuts to Medicaid  

As Congress continues to deliberate on the Republican-led health care plan, HCA late last week sent a letter urging New York’s Congressional Delegation to oppose the bill’s current iteration, with its dramatic proposals to overhaul the Medicaid program.

Our letter joins the growing chorus of hospital and community health groups, insurance representatives, practitioner organizations and consumer groups “who recognize that this bill would deprive citizens of life-saving coverage, recklessly destabilize insurance markets, and create a fiscal crisis for states like New York,” writes HCA President Joanne Cunningham. Continue reading “HCA Calls on Congress to Oppose ACA Repeal and Replacement Bill, With Its Deep Cuts to Medicaid  “

HCA President Responds on MedPAC Recommendations to Cut, Rebase Medicare Home Health Rates

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”

HCA Submits Comments on HHPPS Rule for Medicare Home Health

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

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

HCA Comments on CMS Pre-claim Review Demo

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

HCA Comments on 2017 Hospice Proposed Rule

This week, HCA submitted extensive written comments on the 2017 proposed rule for Medicare hospice payment updates, wage index changes and quality reporting recently posted by the U.S. Centers for Medicare and Medicaid Services (CMS). You can download the comments here.

One concern addressed in our comments relates to CMS’s Medicare Choice Model (MCCM), where Medicare beneficiaries and dually eligible beneficiaries are able to receive hospice-like support services from certain hospice providers while concurrently receiving services provided by their curative care providers. Continue reading “HCA Comments on 2017 Hospice Proposed Rule”

HCA’s Comments Voice Strong Support for Physician Signature, Billing Flexibility Proposal

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 Opposes CMS Prior Authorization 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”

HCA Comments on CMS Discharge Planning Proposed Rule

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

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

You can download the comments here.

HCA Comments on 2016 HHPPS Proposed Rule

HCA has submitted extensive comments (see here) on the U.S. Centers for Medicare and Medicaid Services (CMS) proposed rule for the 2016 Home Health Prospective Payment System (HHPPS). The comments address such areas as the continued methodology flaws in CMS’s rebasing of Medicare home health rates, including the incorporation of a “case-mix-creep” adjustment that appears to adjust the rebasing cuts to a level beyond that authorized by Congress. We also seek CMS action to address the lack of a comprehensive impact analysis for rebasing and the failure of rebasing to incorporate all usual and necessary indirect and direct costs in CMS’s analysis. The comments also address concerns with the Medicare face-to-face rule, CMS’s value-based payment proposal and several other detailed, technical aspects of the proposal.

Comments on Medicaid Managed Care Proposed Rule

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

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

HCA Comments on Hospice Proposed Rule

HCA has submitted our comments on the 2016 proposed rule for Medicare hospice payment updates, wage index changes and quality reporting recently posted by the U.S. Centers for Medicare and Medicaid Services (CMS). Our comments can be read here.

On the payment side, our comments specifically address several items in the proposed rule, including: revisions to the routine home care rate, the service intensity add-on payment, the inpatient aggregate cap accounting year timeframe, and the wage index which is particularly problematic and in need of revision.

We also provide item-by-item comments on quality reporting elements of the proposed rule, such as the Hospice Quality Reporting Program (HQRP) data submission process and future quality measures; the impact of Consumer Assessment of Healthcare Providers and Systems (CAHPS) survey results on 2017 payments (an unfunded mandate in need of reimbursement support); and the reporting of diagnoses on hospice claims.

 

Comments on Proposed Home Health Conditions of Participation

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

HCA Comments to CMS on Proposed 2015 HHPPS Rule

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

HCA Urges CMS to Extend Comment Deadline on Proposed CoPs

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

HCA Letter to the Governor’s Office in Support of Essential Personnel Bill

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