NAHC President Submits Progress Report to the Board
October 3, 2013 12:36 PM
NAHC President Val J. Halamandaris recently issues a 12-point progress report to NAHC Board of Directors.
Below is the Report’s ten-point overview on NAHC’s Campaign for Responsible Rebasing.
The Campaign for Responsible Rebasing.
The proposed revisions in the Medicare Prospective Payment for Home Health issued by CMS were a major disappointment. They were issued in response to a provision in the ACA requiring “rebasing” which contemplated a top to bottom look at how to make the program better, to increase its efficiency, to create and reward positive incentives, to increase access to care among beneficiaries, and to control costs not only in home health, but in the Medicare program overall.
Our first action was a statement of unity issued on behalf of NAHC, the Partnership for Quality Home Healthcare, and the Visiting Nurse Associations of America. We complained that CMS did not do its job. There was nothing resembling a comprehensive analysis of the Medicare home care program. CMS made it only about the money.
Our second point was that the cuts they put forward were draconian and will reduce senior's access to care. On the basis of limited or outdated data for only one year based on only some 700 of the more 10,000 available cost reports, CMS concluded that payments were too high, recommended the maximum possible 3.5 percent cut for each of the next four years or a total of 14 percent which computes to approximately percent $22 billion in cuts. Nor, does there seem to be any embarrassment on the part of CMS for imposing the $22 billion in cuts on top of $78 billion in cuts imposed on the home care patients since 2009. In their proposed rule, they blame Congress for the amount of the cut. We are fighting against these illegitimate rule revisions in order to protect the patients who need care. It is also our hope to prevent the legacy of this administration from being one known for a reduction of home care, the program most needed to meet the needs of the 78 million baby boom generation by over $100 billion.
Third, NAHC has produced the data which shows that by 2017, when the full effect of these cuts is realized, only three states will show positive Medicare margins: Connecticut with .3 percent, Georgia with .2 percent and Tennessee with 1.6 percent. Moreover, the percentage of agencies who will be in the red run from Hawaii with 100 percent, New York at 89.9 percent and Oregon at 87.2 percent on the high end to lows of Rhode Island at 38.l percent, Connecticut at 47.l percent, and Tennessee at 51.3 percent. The national Medicare average will drop to - 9.77 percent. We have pointed out that unlike hospitals or nurses homes, home health cannot fall back on passing along higher fees to private insurance, or private payors because this segment of our industry remains very tiny.
Fourth, we have pointed out that CMS did not undertake an analysis of the impact of their rule on small businesses. As defined by the Small Business Administration, this includes organizations with operating revenue of less than $10 million a year. Small businesses employ 57 percent of the private workforce representing 44 percent of U.S. payroll. A report produced by Dobson DeVanzo and Associates for the Partnership of Home Health Quality and Innovation concludes that the rule will adversely effect small agencies to be at a significant disadvantage. They recommend that the rule be revised to ensure the financial stability of small home health agencies. We have been working with both the SBA and related Congressional Committees. The latter have authority that we put in motion in l997 to set aside any regulations which adversely effect small businesses.
Fifth, working with VNAA, we released their study which shows that the proposed “rebasing” cuts may result in undermining both access to and actual care to patients in rural and underserved agencies. Medicare beneficiaries, especially those who qualify for home care by definition must be homebound. They are older, sicker and poorer than the Medicare population as a whole and a great deal more vulnerable.
Sixth, NAHC has produced data showing: l) that according to the Bureau of Health Statistics, the most needed jobs in America over the next ten years will include home health aides, personal care assistants, and nurses; 2) that there are over 1,140,402 jobs in the home health industry nationwide; 3) that as of 2011, home health had a $4.7 trillion impact on payroll and labor income; 4) in July, home health generated nearly 4,000 new jobs according to the Bureau of Labor Statistics. This was almost two-thirds of all new jobs created in the ambulatory health care services sector last month; 5) increased demand for home healthcare jobs are expected to grow 5.5 times faster than all other non-farm industries for the remainder of the decade. The point is that many new employees will be needed in home health to meet the growing needs of the 78 million
U. S. baby boom generation. Home health has provided a major boost to the economy, but this rate of growth will be jeopardized by the proposed draconian rules which will undermine the infrastructure which meets patient's needs and simultaneously creates jobs.
Seventh, in addition to the collaboration of three national home care organizations who have embraced the goal of blunting the new rule, NAHC had long ago built a strong coalition among consumer and senior citizens organizations. NAHC was the first provider based organization admitted to be part of the consumer based Leadership Council on Aging Organizations (LCAO).
We have been meeting with some 70 members of LCAO who have rallied to our support. For example, AARP in their August 26, 2013 comments to the “rebasing” rules indicated their support: “AARP is concerned about the potential impact of the reduced HH PPS payments on Medicare beneficiary access to home health services and on the quality of these services. Home health services are of tremendous importance to Medicare beneficiaries since these services help beneficiaries stay in their homes and avoid more expense skilled nursing facility care. These services can also help beneficiaries avoid hospital admissions or re-admissions and visits to emergency departments, all of which have significant implications for Medicare expenditures.”
Eighth, we have worked together hosting joint press conferences, issuing joint press releases, and educating members of Congress and their staff. We have joined together in educational meetings, such as those hosted by NAHC for Senators Ron Wyden, Dick Durbin the Deputy Majority Leader, John Cornyn, the Deputy Minority Leader and Pat Roberts.
Ninth, NAHC has utilized its Home Healthcare Nurses Association to energize home care nurses to take action in opposition to the new proposed rules. The top 50 nurses, one from each state, were selected. Ten finalists were selected. The stories of these heroic nurses which involved their caring for patients were published in a recent issue of CARING Magazine.
Tenth, our mantra is, “It is all about the patients.” Through our Members and State Association members, we have been collecting stories of patients and their families. The more we can make the case of how important home care is in their lives, the more successful we shall be in getting Congress to reject the proposed rule. Letters are being circulated by our friends soliciting signatures of members of Congress. We shall press on until we have the majority of the House and Senate that signs onto this crusade for basic fairness. Another goal is for us to look back years from now and remember the actions that we took together to avoid the attempted dismantling of the Medicare home health benefit. We have been here before. We won then and we intend to win this time as well because we know that our cause is just.
For more information on CMS’ flawed rebasing proposal – as well as resources for home health and hospice advocates – please visit NAHC’s Legislative Action Network