NAHC Submits Comments on House Ways and Means Committee’s Draft Legislation on Home Health Copayments
August 14, 2013 04:26 PM
The National Association for Home Care & Hospice (NAHC) recently submitted comments on the House Ways and Means Committee’s draft legislation on adding a home health copayment to Medicare. The House Ways and Means Committee has jurisdiction over the Medicare program, and NAHC’s comments come in response to Chairman Dave Camp’s (R-MI) request for public feedback on such a proposal.
For more information on the draft legislation, as well as the request for public comment, please see NAHC Report from July 25, 2013.
In its comments, NAHC states that:
“Congress eliminated the home health copayment in 1972 for the very reasons it should not be resurrected now. The home health copayment in the 1960s and 1970s deterred Medicare beneficiaries from accessing home health care and instead created an incentive for more expensive institutional care. Reinstating the home health copay today would undo the progress made in efforts to reduce unnecessary hospitalizations and nursing home stays.”
NAHC’s comments then expand on reasons why a home health copayment should be rejected, including:
Home health copayments would create a significant barrier for those in need of home care, lead to increased use of more costly institutional care, and increase Medicare spending overall. The Urban Institute’s Health Policy Center found that home health copays “…would fall on the home health users with the highest Medicare expenses and the worst health status, who appear to be using home health in lieu of more expensive nursing facility stays.”Similarly, a study in the New England Journal of Medicine found that increasing copays on ambulatory care decreased outpatient visits, leading to increased acute care and hospitalizations, worse outcomes, and greater expense. The same adverse health consequences and more costly acute care and hospitalizations would likely result from the imposition of a home health copay. Studies have shown that Medicaid copays can backfire with beneficiaries avoiding care leading to higher Medicaid overall costs. According to an analysis by Avalere, a home health copayment could increase Medicare hospital inpatient spending by $6-13 billion over ten years.
The burden of a home health copayment would disproportionately impact the most vulnerable—the oldest, sickest, and poorest Medicare beneficiaries. About 86 percent of home health users are age 65 or older, 63 percent 75 or older, and nearly 30 percent 85 or older. Sixty-three percent are women.Home health users are poorer on average than the Medicare population as a whole. Home health users have more limitations in one or more activities of daily living than beneficiaries in general. The Commonwealth Fund cautioned that “cost-sharing proposals, such as a copayment on Medicare home health services, could leave vulnerable beneficiaries at risk and place an inordinate burden on those who already face very high out-of-pocket costs.”
Copayments as a means of reducing utilization would be particularly inappropriate for home health care. Beneficiaries do not “order” home health care for themselves. Services are ordered by a physician who must certify that services are medically necessary, that beneficiaries are homebound and meet other stringent standards. There is no evidence of systemic overutilization. Adjusted for inflation, home health spending on a per patient basis and overall Medicare spending on home health is less today than in 1997. The Medicare home health benefit has dropped from 9.5 percent of Medicare spending in 1997 to 5.9 percent and serves a smaller proportion of Medicare beneficiaries today than in 1997.
The deadline for the public to submit comments to the Ways and Means Committee is this Friday, August 16, 2013. All NAHC members are encouraged to submit their own comments to email@example.com and voice their opposition to the proposal to resurrect the home health copayment.