Important Statement on Medicare Home Health Final Rule

Posted on

FOR IMMEDIATE RELEASE

 Media Contact: Thomas Threlkeld
Director of Communications
202-547-7424/ tom@nahc.org

 

Statement of NAHC President William A. Dombi Regarding the Medicare Home Health Rule Issued Today

PLEASE NOTE: The National Association for Home Care & Hospice (NAHC) will present a webinar explaining all important aspects of the Medicare Home Health Rule on Wednesday, November 6, 2019 at 3:00 PM Eastern. Register here.

(October 31, 2019) CMS late today issued the Final Rule for the 2020 payment model, PDGM, including rates of payment that would start January 1, 2020. The new payment model had been finalized in its design in the 2019 rulemaking cycle. The Final Rule offers some minor tweaks in the payment model and sets out 2020 payment rates. The rule also includes unrelated adjustments in other rules affecting home health, including the 2021 home infusion therapy benefit, quality measures, and the Home Health Value Based Purchasing Demonstration program.

NAHC is greatly heartened by CMS’s modification of the 2020 payment rates to reflect a much more realistic view that any behavior changes in coding or service utilization would not occur instantaneously and in full starting January 1, 2020. In reducing the 2020 adjustment from 8.39% to 4.36%, CMS has given the home health community a chance to safely transition to the dramatically new payment model. NAHC extends its thanks and appreciation the CMS for its thoughtful consideration of the community’s comments in the rulemaking process. We will be working with CMS closely to assess actual behavior changes throughout 2020 and to help develop the standards for determining whether future adjustments may be justified.

The Bipartisan Budget Act of 2018 requires that the home health payment model reform be budget neutral. While it permits behavioral adjustment to payment rates, NAHC believes that assumption-based rate calculation should not occur because of the high risks of error and the creation of an incentive to change behavior solely to maintain Medicare revenues. Instead, NAHC supports adjustments only after actual behavioral changes have occurred. The modifications made by CMS in the behavior adjustment are still based on assumptions, but the revised assumptions are a definite improvement over the proposed ones.

NAHC supports sensible payment reform. While the PDGM payment model reforms include sensible changes, the behavioral adjustment remains a concern, albeit to a reduced level. There is bipartisan, bicameral legislation pending, S. 433 and HR 2573, that can help resolve these concerns fully. A NAHC “thank you” goes out to the sponsors of these bills as they also weighed in with CMS to secure the important and crucial change in the behavior adjustment in the rulemaking process.

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About National Association for Home Care & Hospice (NAHC)

The National Association for Home Care & Hospice (NAHC) is the voice of home care and hospice. NAHC represents the nation’s 33,000 home care and hospice providers, along with the more than two million nurses, therapists, and aides they employ. These caregivers provide vital services to Americans who are aged, disabled, and ill. Some 12 million patients depend on home care and hospice providers, who depend on NAHC for the best in advocacy, education, and information. NAHC is a nonprofit organization that helps its members maintain the highest standards of care. To learn more, visit nahc.org.

NAHC Statement on Office of Inspector General Report on Hospice

Posted on

FOR IMMEDIATE RELEASE

 Media Contact: Thomas Threlkeld
Director of Communications
202-547-7424/ tom@nahc.org

NAHC Statement on Office of Inspector General Report on Hospice

The National Association for Home Care & Hospice (NAHC) supports action taken in recent years to increase hospice providers’ accountability for delivery of high-quality care, including through imposition of a mandate for more frequent surveys. However, the finding of the Office of Inspector General (OIG) sends a clear message that more action is required to safeguard vulnerable hospice patients. The Centers for Medicare & Medicaid Services (CMS), states, accrediting organizations, hospice associations, and hospice providers must all address existing gaps in oversight of hospice quality of care so the problems cited in the report are eliminated. NAHC fully agrees that safety of hospice patients cannot be compromised.

While a methodical and comprehensive approach to this issue is clearly warranted, corrective efforts should be tailored (and prioritized) based on the nature of a hospice’s deficiency. The egregious examples of harm discovered by the OIG require an immediate focus on the small number of providers with incidents of jeopardizing patient safety. CMS should employ a variety of methods to address these agencies’ failings, including subjecting them to the closest of scrutiny until they are able to demonstrate the ability to meet quality standards and the conditions of participation on an ongoing basis.

The vast majority of hospice providers are able to meet quality of care standards, but some still fail to meet all the Hospice Conditions of Participation upon survey. It is important to note that virtually all these deficiencies are addressed in short order by hospice providers. However, we believe that some of the OIG’s proposed recommendations may help some providers avoid these issues on the front end, and could contribute to improvements in the overall quality of care provided to hospice patients. NAHC strongly supports the OIG’s recommendation that CMS provide hospices education about common deficiencies and those that pose particular risks to beneficiaries. Historically there has been limited education available to providers in these areas, and information directly from CMS is vital to maintaining a continuing understanding of quality of care requirements. Direct educational offerings also provide a unique opportunity for give and take between CMS and the hospice community around quality and survey issues.

A number of the OIG’s recommendations center on increased public availability of hospice survey data for use by consumers, referring providers and others. It is our understanding that CMS is working to build the capacity of Hospice Compare to incorporate this type of information. NAHC recognizes the value of such transparency and the benefit that this type of information can supply, but strongly believes that such action should only be taken when data from all survey organizations is available for posting, the data is comparable across hospice providers, and the data is displayed in a clear and understandable way.

The OIG’s reports provide all stakeholders an important opportunity to examine ways to create more coherent, consistent, and responsive processes for addressing quality of care under hospice. NAHC looks forward to working with its members to thoroughly examine and respond to the OIG’s recommendations, as well as to work with CMS and other stakeholders to ensure quality care for hospice patients.

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About National Association for Home Care & Hospice (NAHC)

The National Association for Home Care & Hospice (NAHC) is the voice of home care and hospice. NAHC represents the nation’s 33,000 home care and hospice providers, along with the more than two million nurses, therapists, and aides they employ. These caregivers provide vital services to Americans who are aged, disabled, and ill. Some 12 million patients depend on home care and hospice providers, who depend on NAHC for the best in advocacy, education, and information. NAHC is a nonprofit organization that helps its members maintain the highest standards of care. To learn more, visit nahc.org.