SPECIAL REPORT: Senators Call for Pre-Claim Review Demonstration Delay and Changes
September 1, 2016 04:24 PM
A bipartisan pair of senators from Florida today wrote to Andy Slavitt, Acting Administrator for CMS, expressing concerns with the Medicare home health pre-claim review (PCR) demonstration project. The letter from Senators Bill Nelson (D) and Marco Rubio (R) calls for the Florida demonstration (expected to begin October 1) to be delayed to allow for sufficient time to monitor and evaluate the demonstration’s effects in Illinois. This letter comes on the heels of reports of significant problems and consequences with the PCR demonstration so far in Illinois. NAHC and the Home Care Association of Florida worked closely with the Senators’ offices to gain their support on the effort to rescind the pre-claim review project.
The letter from the senators highlighted the need to protect patients and expressed concerns “this demonstration may restrict beneficiary access to timely services, divert clinical resources to paperwork management, and incur high administrative costs.” In addition to requesting a delay, the letter recommended a scaled-down version of the PCR demonstration, should it move forward. The senators also called attention to simpler changes that could improve documentation error rates.
Senators Nelson and Rubio previously joined their colleagues in sending a letter to CMS expressing concern for the original proposal of the initial prior authorization proposal.
The text of the letter expressing concerns about the PCR demonstration is below:
Dear Acting Administrator Slavitt,
We write to express our concerns regarding the Centers for Medicare and Medicaid Services’ (CMS) Pre-Claim Review Demonstration (PCRD) being implemented in five states, including Florida, for home health services. While the PCRD modestly modified the earlier prior authorization proposal, we remain concerned this demonstration may restrict beneficiary access to timely services, divert clinical resources to paperwork management, and incur high administrative costs. We urge CMS to delay expansion of PCRD into Florida and the other states until CMS, stakeholders, and Congress have the opportunity to evaluate and understand the impact of the demonstration in Illinois.
It is important that we learn whether the demonstration improves documentation error rates without adversely impacting patient access to care. The potential October 1, 2016 start date in Florida should be delayed to allow for sufficient time to monitor and evaluate the demonstration’s effects in Illinois.
We share your concern with the improper payment rate and your commitment to protecting taxpayer funds while also improving program integrity. Yet, we are concerned that the PCRD may not fully address the root cause of these errors. We have heard from stakeholders who believe there are simple changes that can be implemented to achieve the goal of reducing improper payments, including the identification of the nature and cause of documentation errors and implementing targeted changes to underlying policy.
Should CMS subsequently choose to move forward with a PCRD in Florida, we encourage you to consider a scaled-down approach that would be less resource intensive for smaller home health agencies, better protect patients, and essentially achieve comparable outcomes. For example, home health providers in our state have suggested a random selection of a small percentage of Request for Anticipated Payment submissions for pre-claim review. This would require all home health agencies to be ready to comply with the PCRD, alleviate the workload on MACs and providers, and provide CMS with the same information it currently seeks through implementation of the PCRD.
Thank you for your attention to this matter. We look forward to working with you to improve improper payments without disrupting patient care or access.
You can read the Senators’ actual letter, which NAHC has been working on for months, right here.