HCA Vice President for Finance and Management Patrick Conole has prepared a comprehensive memo on the proposed fiscal year (FY) 2022 hospice rule recently issued by the U.S. Centers for Medicare and Medicaid Services (CMS). Continue reading “HCA Memo on Proposed FY 2022 Hospice Rule “
HCA asks all members to call their State Senators. Request them to immediately contact Senate Majority Leader Andrea Stewart-Cousins to reconsider the Senate’s home care wage proposal, substituting it with HCA’s alternative plan in the budget.
The Senate’s wage mandate proposal has gained new momentum since the weekend, and HCA understands that it is being directly discussed at the legislative leaders level in budget negotiations.
“While we appreciate the intent of new proposed state budget legislation to increase aide wages, the proposal now under consideration in New York’s state budget would not sufficiently cover the full cost of this new mandate for home care provider employers in New York State, many of whom are operating at negative margins,” HCA recently told McKnight’s Long Term Care News regarding legislation proposed in the state budget.
On the heels of last week’s Medicaid and health budget hearing, HCA urges all home care and hospice providers to connect with your state representatives today urging the restoration of funds in the budget using HCA’s Legislative Action Center here.
HCA calls for restoration of workforce and service funds, as well as a ‘Home Care First’ policy to meet rising demand for home care in pandemic
ALBANY — At a time when home care providers face a 50% workforce recruitment-and-retention funding cut and other reductions in New York’s budget, HCA has issued a new report showing the devastating impact of COVID-19 on home care operations and workforce amid a rising demand for services and escalating new costs for Personal Protective Equipment (PPE) and other needs. Continue reading “As NY Budget Proposes 50% Workforce Funding Cut, New HCA Report Shows Devastating Impact of Pandemic on Home Care Finances and Access “
HCA’s 2021 advocacy agenda has several components, supported by draft legislative bill language. These proposals are all condensed in a short-form version or one-pager highlighting HCA’s main areas of priority in an easy-to-read format for state legislators. Continue reading “HCA Issues One-Page State Budget Priority Briefing Document for 2021 Advocacy “
HCA has completed our most comprehensive State of the Industry Report to date — one of our centerpiece documents for HCA’s 2021 advocacy efforts. Continue reading “Read HCA’s 2021 ‘State of the Industry’ Report on Home Care, Hospice & MLTC Finances and Operations “
ALBANY – The Board of Directors of the Home Care Association of New York State (HCA) has unanimously adopted a resolution urging home care and hospice provider vaccination efforts for COVID-19. Continue reading “NY Home Care Association Board Unanimously Adopts Resolution Urging Provider Vaccination Efforts for COVID-19”
HCA Vice President for Finance and Management Patrick Conole has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposed 2021 payment rule for home health. The comments can be downloaded here.
The proposed rule includes updates on a mix of longstanding payment-related programs and structures, but, due to the COVID-19 pandemic, left the existing 2020 Patient-Driven Groupings Model (PDGM) intact.
CMS is expected to finalize the rule, following the comment period, in late October, with the rule going into effect on January 1, 2021.
In comments to the U.S. Centers for Medicare and Medicaid Services (CMS), HCA focused on three principal areas of the proposed hospice rule for fiscal year (FY) 2021: hospice wage index updates and revisions based on new Core-Based Statistical Area (CBSA) designations published by the Office of Management and Budget (OMB) in 2018; CMS’s proposed elimination of the Service Intensity Add-on (SIA) budget neutrality factor; and upcoming changes to the hospice election statement, along with a new addendum requirement.
HCA Vice President for Finance and Management Patrick Conole submitted comments to the U.S. Centers for Medicare and Medicaid Service (CMS) on CMS’s interim rule regarding home care and hospice “regulatory revisions” that have been issued in response to the public health emergency.
In our comments, HCA recognized CMS’s efforts thus far on regulatory relief and waivers, including CMS’s responsive interpretation of the “homebound” status definition in light of COVID-19, new allowances for non-physician practitioners to order home health services, and the modest expansion of remote telecommunications services to help shield against exposure risk and to help augment care.
On this latter area, however, HCA made several recommendations. We noted the recently extended or expanded flexibilities, permissions and payments for telehealth by other practitioners that should be likewise provided broadly to home health and hospice providers whose patients and staff also face infection exposure risks.
On Tuesday, May 5, HCA’s Director for Public Policy, Alyssa Lovelace, testified remotely before the New York City Council’s Committee on Civil Service and Labor on Int. 1918-2020, New York City legislation that would mandate “premium pay” for essential workers. Continue reading “HCA Testifies Before NYC Council Members on Premium Pay Legislation”
A statement from HCA President Al Cardillo
“I greatly commend the New York State Department of Health for employing a broadly flexible and visionary use of telehealth through home health providers to promote patient care as well as worker and patient safety in the COVID-19 emergency.” Continue reading “NY Has Allowed Medicaid Home Telehealth Flexibility to Keep Patients & Staff Safe in COVID-19; Washington Should Follow Suit for Medicare”
HCA has joined forces with four partner groups representing long term care and managed care organizations on a letter (see here) to the Cuomo Administration calling for Personal Protective Equipment (PPE) distribution and prioritization protocols inclusive of home care. We also sought approval of recommended measures to safely provide care where PPE or staffing are insufficient, such as the enlistment of alternate care providers, voluntary plan-of-care changes, and other flexibilities.
The Home Care Association of New York State (HCA) has again surveyed home and community-based providers in New York State — at the COVID-19 epicenter — to learn more about specific impacts of the health emergency on home and community-based services delivered to nearly 900,000 New Yorkers. Our latest report is called Phase II COVID-19 Survey: Summary of Impact on Home and Community-Based Entities, Staff and Patients in New York State.
Our latest survey, finalized on April 6, further examines: the number of suspected or confirmed COVID-19 cases among home care staff and patients; what agencies are doing to cope with equipment shortages; percentage changes in patient counts due to COVID-19; the numbers (in ranges) of patients refusing care for fear of exposure; what agencies are doing in cases where patients are refusing care; projected financial impacts for the foreseeable future; and more.
In a just-completed HCA survey on the COVID-19 crisis, nearly 300 home care providers in every region of New York State report that they collectively serve more than 14,100 priority level 1 patients in the community. These are patients who, without home care, would face a rapid, immediately life-threatening deterioration in their existing health condition or would need to be transferred to another setting, such as hospitals or nursing homes already stretched to capacity. Many of these most at-risk patients are homebound, or dependent on technology or ventilators, with severe life-limiting conditions. Continue reading “March (Phase I) Report: Home Care Needs Priority Supplies, Regulatory Flexibility & Emergency Aid for COVID-19 Response”
HCA has issued our 2020 State of the Industry report. Consistent with past reports, we find that the vast majority of community-based providers and Managed Long Term Care (MLTC) plans are operating with negative or negligible margins.
Providers carry an average accounts receivable of 69 days outstanding. Also, about a quarter of direct caregivers leave home care organizations for a variety of reasons, with turnover rates as high as 63 percent, imposing major unreimbursed costs on organizations.
“The fiscal pressures facing New York’s Medicaid budget are rightfully an area of concern that HCA readily shares,” HCA concludes. “However, state policymakers should not overlook other correlative trends impacting home and community-based services,” noting new obligations and responsibilities like minimum wage changes and the expansion of MLTC benefits for which “state Medicaid funds … have fallen short while nevertheless adding to the state’s budget pressures.” Continue reading “HCA Report Outlines Fiscal Pressures Facing Home Care, Hospice, MLTC”
“The home care system, which serves close to 900,000 New Yorkers, needs to be represented on the Governor’s Medicaid Redesign Team (MRT), a process that, very swiftly, is expected to devise $2.5 billion in Medicaid cost savings.”
“Today, HCA is meeting with legislators during our state advocacy day in Albany to bolster support for productive cost-savings proposals in Medicaid. These warrant consideration.” Continue reading “A Statement from HCA President & CEO Al Cardillo on HCA’s State Advocacy Day, Medicaid, the MRT”
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”
HCA Vice President for Finance and Management Patrick Conole yesterday sent comments to the U.S. Centers for Medicare and Medicaid Services (CMS) on its proposed 2020 payment rule for home health.
The proposed rule includes updates on a mix of longstanding payment-related programs and structures, alongside the major structural overhaul known as the Patient-Driven Groupings Model (PDGM).
CMS is expected to finalize the rule, following the comment period, in November, with the rule going into effect on January 1, 2020.
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.
“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”
ALBANY — Coinciding with today’s state legislative hearing on the health and Medicaid budget, the Home Care Association of New York State (HCA) today released the findings of our annual financial and trends report for the home and community-based care sector, which serves approximately 500,000 patients and families in New York State.
The report is culled from the latest available state Medicaid financial reports and a survey of providers. It shows: financial margins; revenue and cost cycle and accounts receivable data; workforce turnover and vacancy rates; access issues; and more.
“The data reveals urgent vulnerabilities and needs in the vital in-home safety-net,” said HCA President Al Cardillo in prepared testimony to the Legislature today. (The report is here; HCA’s testimony is here.)
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.
Rule would limit, deny immigration for those on public assistance, with implications for home care patients and the individuals who support them
HCA today commented on a new federal proposal that would limit or deny permanent legal status to immigrants if they rely on a wide range of government services, such as Medicaid, food assistance, and housing assistance. Our comments seek exemptions of individuals employed or seeking employment as home care or personal care aides. Continue reading “HCA Seeks Home Care Exemption in Federal “Public Charge” Rule Change”
The U.S. Centers for Medicare and Medicaid Services (CMS) has finalized the biggest change in funding and reimbursement for Medicare home health services in two decades.
Of nationwide concern, this new system is front‐loaded with provider cuts tucked in by unverified CMS predictions about future provider behavior in a system not even yet implemented. Home care in New York State needs your support on bipartisan legislation (H.R. 6932, S.3545 and S.3458) to ensure that this reimbursement overhaul does not jeopardize services for seniors who rely on home care.
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”
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”
HCA this week voiced support for a proposal to add non-skilled in-home supports as a supplemental benefit under Medicare Advantage (MA).
Our comments — to the U.S. Centers for Medicare and Medicaid Services (CMS) — also include recommendations for implementation of this potentially transformative change. HCA’s comments can be downloaded here.
CMS recently announced the proposal in a notice to MA plans on 2019 payment changes, saying that it intends to expand the scope of the “primarily health related supplemental benefit standard.” Such an expansion would cover services or items that “diagnose, prevent, or treat an illness or injury, compensate for physical impairments, act to ameliorate the functional/psychological impact of injuries or health conditions, or reduce avoidable emergency and health care utilization.”
Underscores adverse impact of proposed cuts, eligibility changes, structural limits and urges support for process improvements, home care licensure standards, workforce and infrastructure
ALBANY — HCA President Joanne Cunningham testified today before a joint legislative panel on the Medicaid and health areas of the state budget. Her testimony, on behalf of HCA’s home care, hospice and Managed Long Term Care providers and plans, is available at https://hca-nys.org/wp-content/uploads/2018/02/201819HCAStateBudgetTestimonyUpdatedFeb132018.pdf.
Of primary concern in this Executive Budget are the proposed cuts and program changes that impact MLTCs and home care, Ms. Cunningham said.
“Virtually the entire long term care Medicaid and Medicare patient population in New York State has been moved under the care of MLTCs and their providers. The Administration has removed most other options,” Ms. Cunningham said. Continue reading “HCA Testifies at Health State Budget Hearing on Behalf of Home Care, Hospice and MLTC “
HCA has issued our 2018 Budget and Legislative Action Proposals. These include the following broad areas:
- Reject Budget Cuts and Harmful Program Actions to MLTCs and Home Care
- Support Budget Proposals to Reimburse Minimum Wage & Health Care Infrastructure
- Develop Appropriate, Actuarially Sound and Timely Payment for MLTCs and Providers Address Workforce Needs in Home Care and Hospice
- Maintain NY Licensure Standards for Home Care — and Act Against Scofflaws
- Utilize Home Care’s Expertise to Yield Savings in Community and Public Health
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.
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”
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”
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”
HCA submitted extensive comments this week on the U.S. Centers for Medicare and Medicaid Services proposed rule for the 2017 Home Health Prospective Payment System (HHPPS). You can download the comments here.
The comments address such areas as the continued methodology flaws in CMS’s rebasing of Medicare home health rates, including the incorporation of a “case-mix-creep” adjustment that appears to adjust the rebasing cuts to a level beyond that authorized by Congress. We also seek CMS action to address the lack of a comprehensive impact analysis for rebasing and the failure of rebasing to incorporate all usual and necessary indirect and direct costs in CMS’s analysis. Continue reading “HCA Submits Comments on HHPPS Rule for Medicare Home Health”
While the U.S. Centers for Medicare and Medicaid Services (CMS) has revised the Medicare Prior Authorization of Home Health Services Demonstration to now become a Pre-Claim Review Demonstration, HCA believes the revised Demonstration would still create unnecessary obstacles to care, increase system wide costs, and jeopardize the quality of care that patients receive. Download our July 20, 2016 comments to CMS on the proposal.
HCA 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”
On January 25, 2016, HCA published a two-page document outlining our “asks” of the Legislature for the 2016-17 State Budget and legislative session. The requests, in a document called “Priority Asks: Position Home Care to Meet the State’s Policy Goals,” include the need for reimbursement support and programmatic changes to support home care in a changing state health care policy environment.
On January 25, 2016, HCA published a financial condition report of New York’s home care community. The report, called “Risk Factors: What You Need to Know about the Financial Condition of New York’s Home Care Community,” is based on an analysis of state cost report and statistical data, accompanied by a survey of New York’s home care providers.
On January 25, 2016, HCA delivered testimony on the proposed State Budget before a joint legislative health committee. HCA’s testimony is available here.
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.
On July 7, the U.S. Centers for Medicare and Medicaid Services (CMS) issued proposed payment changes for home health in a regulation known as the Home Health Prospective Payment System (HHPPS) rule for calendar year (CY) 2016.
Given the expanding need and importance of home health care as our population ages, most would expect the proposed rule to include policy changes that improve the value of Medicare home health services for patients and taxpayers. This regulation, unfortunately, proposes significant funding cuts that will directly harm home health agencies and the homebound Medicare beneficiaries receiving such critical services in all areas of New York.
This publication spells out four reasons why this proposed rule is concerning, and why we need Congress to act.
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 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.
The Home Care Association of New York State (HCA) strongly supports legislation, S.5852/A.8200, amending chapter 6 of 2015 in further support of telehealth services in New York.
New York’s home telehealth program and providers have been national leaders in applying this innovative technology to the care and medical management of patients, demonstrating improved patient outcomes, avoidance of preventable hospital and emergency room use, cost-savings to the system, and other critical health and system benefits.
HCA applauds Senator Young and Assemblywoman Russell for sponsoring and championing the passage of chapter 6, which effective January 1, 2016, provides for telehealth coverage under insurance policies and Health Maintenance Organization (HMO) contracts in the state. HCA further commends the sponsorship of the S.5852 amendments which are critical to ensuring that provisions set forth related to home care under chapter 6 function as intended for patients and for the goals of the new law.
The amendments – introduced in both houses (S.5852/A.8200) – ensure that the new article of public health law created for telehealth in Chapter 6 does not inadvertently conflict with home telehealth provisions otherwise existing elsewhere in statute for home care.
The state’s Legislative session ends on June 17. During this crunch time, HCA is working to amend any bills of concern. We are also pushing hard on priority bills that HCA and partner associations have advanced to support home care.
We need your help. The Legislature won’t be compelled to act unless they hear from you, their constituents.
As you know, HCA’s Legislative Action Center is an easy-to-use online tool for reaching your legislators. Now that it is crunch time, we need all HCA members to take just a minute or two to advocate for home care.
Legislative intro occurs as DOH posts interim EPS rates, retroactive to April 1
As the state legislative session enters its final days, HCA, working with association partners, has succeeded in advancing bipartisan legislation (S.5878 Hannon/A.8171 Gottfried) that would limit the impact of CHHA Medicaid rebasing for the Episodic Payment System (EPS).
The introduction of this legislation occurred at the same time that the Department separately posted the interim EPS rebasing rates to the Health Commerce System (HCS). Continue reading “HCA Gains Intro of Bill to Limit EPS Rebasing”
Major opportunities and challenges alike mark the next two, closing weeks of the State Legislative Session, scheduled to conclude June 17.
In this wind down of the annual legislative calendar, the state Senate and Assembly will be considering significant issues that both directly and indirectly impact home and community-based care, many with huge implications for this sector.
For Immediate Release: April 20, 2015
Roger Noyes (HCA) (518) 810-0665
Stacy Connors (IHA) (518) 348-7443
ALBANY, NY – To promote health care system integration, State Senator Kemp Hannon (R-Nassau) has advanced an important new program in this year’s state budget that supports home health care providers, hospitals and physicians as they work together on collaborative models.
The Home Care Association of New York State (HCA) and the Iroquois Healthcare Alliance (IHA) – which represent home care providers statewide and hospitals and health systems in the upstate region, respectively – applaud the Senator for his sponsorship of this vital initiative and look forward to continuing to work with the Senator on program implementation post-budget.
This initiative was previously introduced as standalone legislation (S.1110) and later adopted as a new program in the state budget, complementing related state health care policies. It specifically creates and devotes a statute within the Public Health Law to support “Hospital-Home Care-Physician Collaboration” programs. Such collaboratives could also include long term care facilities, behavioral health, supportive housing and other interdisciplinary providers.
“Collaboration among health care providers is essential to good care,” said Senator Kemp Hannon (R-Nassau). “For patients who require care at home, collaboration must include the home health care providers as this program does.” Continue reading “Home Care and Hospital Associations Applaud Senator Hannon’s ‘Hospital-Home Care-Physician Collaboration Program’ in State Budget”
HCA urges the New York Congressional Delegation to cosponsor the “Home Health Care Planning Improvement Act” and press for full Congressional action on this bipartisan measure. Currently, NPs and other advanced practice health professionals work closely with physicians to ensure that patients receive necessary care for many Medicare-covered services. They are increasingly providing services to Medicare beneficiaries in rural and underserved areas. In particular, they serve a vital need in communities where physician shortages exist, as they are sometimes more available than physicians to expedite the required paperwork to ensure that care to beneficiaries will be initiated and continued.
Congress should permanently extend the 3 percent Medicare rural add-on for home health services delivered in rural areas so that access to skilled home and community based care is not threatened. Congress should also closely monitor the adequacy of the Medicare home health prospective payment system (PPS) payment so that agencies can continue to provide care to Medicare Home Care Association of beneficiaries in rural areas.
A home health copayment is, in effect, a “sick tax” that harms access to care for vulnerable seniors on fixed incomes, many of whom have multiple chronic conditions, live alone, and need home care to prevent health or safety risks that would otherwise require higher-cost services. If charged a copay, many seniors on fixed incomes will refuse the added charge on their benefits and opt out of vital home care services that help prevent hospitalization, ER visits and other emergent care.
As a condition of payment for Medicare home health coverage, Section 6407 of the Affordable Care Act of 2010 (ACA) establishes that a patient must have a face-to-face (F2F) encounter with the physician who certifies the need for home health services. The encounter also can be provided by certain non-physician practitioners, such as physician assistants and nurse practitioners, and it must occur no more than 90 days prior to the home health start-of-care date or within 30 days after the start of care. However, when a non-physician practitioner provides the encounter, the patient’s physician must still certify that the encounter occurred and compose documentation detailing the finding from the encounter in addition to any documentation produced by the non-physician practitioner. Continue reading “Repeal or Reform the Physician Face-to-Face Encounter Requirement for Home Health”
Beginning in January of 2014 and continuing in 2015, home care providers have been subject to enormous new cuts imposed by the U.S. Centers for Medicare and Medicaid Services (CMS) under CMS’s Home Health Prospective Payment System (PPS). Continue reading “NY Home Care Hit with Growing Medicare Operating Losses Under CMS Rebasing Cuts, Threatening Access to Care”
HCA Executive Vice President Al Cardillo delivers testimony before a joint legislative budget panel on the 2015-16 Executive State Budget.
“Home care is vital to new, priority state policies, and to the evolving health care delivery and payment models”
HCA writes a letter to the Cuomo Administration with comments on a new state budget proposal which seeks to move all health care payments from fee-for-service models to value-based models.
The U.S. Centers for Medicare and Medicaid Services (CMS) has proposed the first new changes to the Medicare home health Conditions of Participation (CoPs) in years. The CoPs haven’t been changed since 1989, and this new set of changes includes sweeping new requirements related to patients rights, quality reporting and other areas affecting the operation of most home care agencies.
HCA’s annual financial condition report is a signature publication in our state advocacy efforts. The report combines a rigorous analysis of Medicaid cost reports — which are a financial reporting instrument that home care agencies are required to submit to the state — with a survey of HCA’s members seeking their responses on financial, policy and programmatic trends in home care.
Driving Health Care Improvement and Savings through Home Care is HCA’s 2015 State Budget policy statement where we highlight key areas of needed financial, regulatory and programmatic support for the home care system. These policies fall into several main areas:
- The need for state officials to move promptly on home care-managed care regulatory relief and realignment measures already in the cue as part of the state’s Home Care Regulatory Workgroup process;
HCA comments on the proposed 2015 home health prospective payment system rule which establishes the Medicare home health payment and regulatory policy for 2015. The proposed rule extends the cuts previously enacted under the federal “rebasing” regimen and makes some changes to the Medicare home health physician face-to-face rule documentation requirements.
HCA requests an extended comment period that would provide more time for the industry to vet CMS’s proposed rule revising the Medicare and Medicaid Conditions of Participation (CoP) for home health agencies. The current December 8, 2014 comment deadline does not offer adequate time to obtain crucial feedback from the home health agency members in the field, who have been operating under the existing home health CoPs since 1989.
HCA and LeadingAge New York write to the state’s Medicaid Director regarding Safety Net concerns in the Delivery Reform Incentive Payment (DSRIP) program, as well as some recommendations regarding the attribution methodology whereby patients are assigned to DSRIP networks.
HCA writes to the Governor in support of A.6530-B (Cusick)/S.4719-B (Lanza), which passed both houses of the Legislature. The legislation will help ensure vital access to care for home health and hospice patients during emergencies, as well as support the overall operation of the health system in responding to disasters.
This special publication outlines the core problems with the Medicare face-to-face requirements and HCA’s solution to streamline the documentation process, ensuring physician oversight of home care services and Medicare integrity without jeopardizing payment and service access.
HCA President Joanne Cunningham delivers testimony before a joint legislative budget panel on the 2014-15 Executive State Budget. HCA’s priorities are as follows:
- Regulatory streamlining and alignment are needed to support the efficiency, quality, orderly structure and payment of home care services under managed care.
- Services, including mandated home care wage laws (under the Wage Parity Law) and service delivery regulations, must be appropriately funded and reimbursed.
- Budget language is needed to support innovative hospital-home care models for patient services, system improvement and community health.
- “Essential Personnel” status is vital for supporting home care and hospice personnel during emergency response.
This special publication provides a summary of all the major home care system transitions that have occurred in the past year, including the managed care transition, the opening of the Certified Home Health Agency certificate of need process, home health payment changes, regulatory changes and more. Along with this policy background, HCA reports on the financial condition of the home care industry using data from a statewide survey and an analysis of financial reporting instruments.
The U.S. Centers for Medicare and Medicaid Services (CMS) has issued a plan for the “rebasing” of Medicare home health payments. Rebasing is a process of resetting the statistical base for payments and it will result in major cuts that will further drive New York home care providers into the red. This issue briefing paper summarizes the rebasing process, its impact on home health providers and a legislative call to action for a more rational approach.
Home care agencies, nurses, therapists and home health aides played a vital role in response to Hurricane Sandy, reaching vulnerable patients in need of services, supplies or assistance with evacuation. Their efforts in the lead‐up and aftermath of this unprecedented storm show what an essential asset home care providers are during times of crisis — just as they provide critical supports to elderly, disabled and chronically ill patients each and every day. In this publication, HCA collects a series of press reports where national and local media highlighted the work of New York home care providers during and after the storm to ensure the safety of patients.
Using one common factor of cost-savings — the 30-day hospital readmission rate — Simione Healthcare Consultants worked with HCA on an analysis which found that the total annual cost savings of innovative care-transitions programs implemented for a defined cohort of patients at just five home care agencies in New York State amounted to an estimated $1.3 million in averted hospital expenses annually.
Home telehealth involves the use of technologies in the home that allow patients to receive education and daily monitoring of vital signs and/or video visits from a registered nurse or therapist. Thus, it could be said, that home telehealth extends the eyes, ears and touch of home care, bringing specialized medical monitoring to people who need it, as a supplement to in‐person home visits. These technologies save countless health care dollars by helping to reduce hospitalizations and the use of emergent care services.