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  NAHC Report: Issue# 2741, 9/3/2015
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NAHC Submits Comments on CMS Proposed Rule: Case Mix Cut, Value-Based Purchasing, and Quality Measures
NAHC Prepares Comments on Medicare Proposal to Bundle Joint Replacement Payments
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NAHC Submits Comments on CMS Proposed Rule: Case Mix Cut, Value-Based Purchasing, and Quality Measures

The National Association for Home Care & Hospice (NAHC) submitted formal comments on September 3, 2015, to the Centers for Medicare & Medicaid Services regarding its proposed rule that includes the calendar year 2016 Home Health Prospective Payment System (HHPPS) rate update, the Home Health Value-Based Purchasing (VBP) pilot program, and several quality measures for the Home Health Quality Reporting Program. In a letter to CMS, NAHC identified numerous problems with CMS’ proposed rule in each category, and provided specific recommendations to improve the proposed rule.

HHPPS Proposed Case Mix Weight Change Adjustment

NAHC identified several factors that demonstrate CMS’ estimate of “real” and “nominal” case mix change to support its proposed rate reduction is “unreliable.” First, NAHC stated, “CMS did not evaluate any of the 921 variables previously considered in earlier adjustments for years 2012-2014 contemporaneous with the case mix change years in issue. Instead, CMS used its outdated earlier analysis that had applied an evaluation that synchronized the case mix change years under review with the consideration of the level of ‘real’ case mix changes during that same time period.” This is problematic, NAHC stated, because “the historical analyses conducted by CMS demonstrate that the level of ‘nominal’ case mix weight change is not consistent from year to year and had instead, varied greatly.” NAHC stated that CMS’ “reliance on the findings from an unrelated time period is improper to support the proposed two-year adjustment and it is essential that CMS conduct an evaluation of the level of ‘nominal’ change for the specific time period in issue rather than applying an unreliable surrogate.” In addition to the lack of an updated analysis, NAHC stated that the variables evaluated “fall short” of being “reliable indicators.”

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NAHC Prepares Comments on Medicare Proposal to Bundle Joint Replacement Payments

The National Association for Home Care & Hospice (NAHC) has drafted comments that will be submitted in response to CMS’s proposal to establish a 90 day episode “bundling” program in 75 MSAs focused on patients with complete knee and hip replacements. Under that proposal, hospitals in the designated areas will face the opportunity for financial rewards and penalties when the overall Medicare spending on patients receiving these joint replacements from their facilities are greater than or less than the established Target Price. Among the services included within the “bundle” are home health services and hospice care.

The draft comments can be found here.

Under the proposal, all providers will continue to be paid under the current fee for services payment model applicable to their provider sector. In other words, Medicare will still pay home health agencies under the current episodic prospective payment model and hospices under its per diem payment model.

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The Largest Home Care and Hospice Marketplace in the World!

Register Today!

NAHC’s Annual Meeting, October 28-30 in Nashville, Tenn., is approaching quickly! We’re proud to bring together not only thought leaders and innovators for our panel discussions and education sessions, but also to our Expo, the largest home care and hospice marketplace in the world.

This year’s Expo is expected to feature nearly 200 specialists and vendors who understand the issues and challenges agencies are facing, and are there to talk with you about solutions. The conference includes 7.5 hours of time, including meals, set aside exclusively for attendees to spend in the Expo, networking with exhibitors.

The array of regulatory and other issues facing home care and hospice, such as changes with the OASIS-C1 data sets and the ICD-10 Coding Manual, adjustments in HHCoP’s and their QAPI requirements, and developments in telehealth regulation, can be tricky to navigate. The Expo at NAHC’s Annual Meeting is the best way to explore potential vendors and specialists who can help you address real problems in your business and care more effectively for your patients.

REGISTER NOW: Join us in “NAHCville” Tennessee, October 28-30!

  • Take an active role in bringing solutions back to your agency.
  • Network with experts about services and products making a real difference.
  • Gain valuable skills to make home care and hospice a better industry.

The Meeting begins at 4:30pm on October 28 for our first education session, so make plans to arrive on Wednesday and stay through the closing party on Friday, October 30.

Booking your hotel and registering for the conference is just one click away.

Remember, special rates at the Gaylord Opryland expire on September 28, 2015!

Visit or follow us on Twitter at @OfficialNAHC for the latest updates on our session topics, exhibits, and faculty.

VNA Care Network & Hospice, Inc. Southborough, MA

Reporting to the Chief Financial Officer/Chief Operating Officer the Controller will oversee and actively participate in the accounting, budgeting, cost reporting, accounts payable, billing and cash flow systems of the Network and affiliates. BS Accounting and CPA required.  Minimum 3-5 years of experience in health care financial management. Home Care experience preferred.

Please forward your resume and cover letter with salary requirements to Ann Bohac, HR Recruiter VNA Care Network & Hospice at    or visit our website at


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