NAHC Recommends “Guiding Principles” to House Subcommittee for Improving Post-Acute Care
Submits Official Subcommittee Hearing Statement on Post-Acute Care Reform
April 17, 2015 09:41 AM
The National Association for Home Care & Hospice (NAHC) submitted a statement to the House Energy & Commerce Subcommittee on Health, which convened a hearing today to discuss the topic of post-acute care (PAC) delivery, including proposed legislation—the Bundling and Coordinating Post-Acute Care (BACPAC) Act (H.R. 1458). In an official hearing statement submitted for the record, NAHC recommended guiding principles for Congress to reform PAC in such a way that improves care for seniors and extends the financial viability of the program.
The NAHC principles for evaluating any PAC reform proposal included:1) individuals should have access to care in the least restrictive and clinically appropriate care setting; 2) the original right of Medicare beneficiaries to have the freedom to choose any qualified provider should be preserved; 3) payment and service model reforms should be developed with the participation and input of all stakeholders; 4) any pre-existing, nonessential regulatory barriers to full success of the reforms should be removed; 5) with the great diversity in the Medicare population, any payment model should rely on a robust risk adjustment that fairly reflects the nature of the population served in the model; and 6) systemic reform should follow the pilot testing of multiple reform model options that are designed to determine the best path forward.
NAHC stated that Congress should learn from ongoing demonstration projects before moving forward with systemic change affecting access to and quality of care. NAHC said the demonstration projects, which were authorized under the Affordable Care Act (ACA) and are currently being tested through the Centers for Medicare and Medicaid Innovation, will provide valuable guidance on how to reform the post acute care system.
“These demonstration programs offer the promise of increased understanding of what works and what does not,” NAHC said in its statement. “Proceeding otherwise creates avoidable risks for Medicare and vulnerable Medicare beneficiaries. Congress should monitor the bundling pilotprogramauthorizedby [the ACA]to ensure that we learn all that is possible before instituting systemic reform.”
NAHC said Congress should evaluate the bundling innovationsto ensure there are no adverse impacts on access to or quality of care. One area of concern to monitor is any change in the administrativeburden onbeneficiaries and providers. Another possible result to monitor is the creation of multiple payment systems, which could cause uneven Medicare coverage for patients with the same needs.
NAHC said the BACPAC Act “adds to the dialogue” and expressed appreciation to its cosponsors. NAHC also applauded specific portions of the bill that would take advantage of home care innovations, as well as waive the homebound and face-to-face physician encounter documentation requirements. However, with the demonstration projects still ongoing, NAHC cautioned that moving forward with any bundling legislation, including the BACPAC Act, would be premature.
“In line with NAHC’s longstanding position of advancing innovative reforms, we are supportive of the intended goals of BACPAC and appreciate the efforts of its sponsors,” NAHC said. “We are concerned, however, that implementing nationwide PAC bundling at this time would be a massive systemic change without the benefit of the knowledge we stand to gain through the thousands of providers engaged in ongoing PAC bundling models. As such, while BACPAC is an example of bundling to be considered, it is a time for learning what it takes to create the most successful reforms rather than for prematurely imposing an untried, systemic model of payment and service that would affect the care and lives of over 5 million Medicare beneficiaries who use PAC care annually.”
NAHC also expressed concerns with specific aspects of the legislation, including: it excludes Medicare physician services from bundling; it defers much of the design of PAC bundling to federal agencies; and it fails to integrate with the IMPACT Act with regards to developing uniform assessment tools to enable bundling in the PAC setting.
Members of Congress serving on the Subcommittee echoed NAHC’s concerns about the BACPAC Act. Subcommittee Ranking Member Gene Green (D-TX) said that, while bundling payments has the potential to improve efficiency and facilitate care coordination, it is important to finish testing the new models.
“There is widespread agreement that new claimant and delivery models are necessary to improve our health care system and achieve better patient outcomes,” Green said. “As providers and CMS are in the process of testing new models, there is still much work to do. This work is ongoing and now is the time to dedicate resources toward building the knowledge base to help our understanding and inform decision making. There are many potential policies to pursue and using the lessons learned from the recent efforts is an important step. This must be done before considering large-scale adoption of reform. Simply bundling payments in advance of this work would be premature.”
Congressman Frank Pallone (D-NJ) reiterated the need to learn and collect data from the current demonstration models before moving forward with the BACPAC Act or any other bundling legislation. “We do not have any common and comparable data across post-acute care providers to determine which patients fare best in which settings, or even what appropriate levels of care are for patients of various acuity,” Pallone said. “While there are many interesting policy ideas in this arena, we need to learn from the ACA efforts underway and the data being collected as a result of the IMPACT Act and provide enough time to ensure the models work in a way that doesn’t compromise access to high quality services for our beneficiaries.”
A number of witnesses reflected similar concerns. You can view the full list of witnesses and their testimony here.
In addition to stating the need for the demonstration projects and outlining guiding principles for PAC reform, NAHC proposed a community-based model for PAC care bundling. “Given the evidence regarding the importance of involving home health providers early in the care transitions process, the most effective bundling model integrates community-based care providers such as home health agencies into the hospital discharge planning process upon the admission of a qualified patient to the hospital. The home health agency would be responsible for a comprehensive evaluation and PAC planning process that is designed to determine whether a patient is medically appropriate and feasible for discharge to the community.”
You can read NAHC’s full statement, which was included the subcommittee’s official record.