CY 2023 HH PPS Proposed Rule and New Resources Now Available; Sample Reports Coming Soon

June FAQs Now Available The June edition of the Expanded HHVBP Model Frequently Asked Questions (FAQs) is now available to assist home health agencies (HHAs) in understanding common terms used in the expanded Model and requirements under the Calendar Year (CY) 2022 Home Health Prospective Payment System (HH PPS) final rule. The document is available…

Hospice Notes for July 13, 2022

Congress is facing a packed few weeks in the lead-up to the monthslong August recess. The potential revival of a slimmed-down reconciliation package sought by Senate Democrats remains top-of-mind for many DC watchers. While nothing is concrete at this point, it unfortunately appears likely that any smaller party-line reconciliation bill will omit major funding investments in Medicaid home-and-community-based services (HCBS). Last year’s House-passed Build Back Better Act included $150 billion for HCBS, seen as a transformative injection of resources that would increase access and better support the frontline home care workforce.

NAHC continues to work with other diverse coalitions to push for the inclusion of HCBS funding in any emerging deal.

Elsewhere on Capitol Hill, the House Appropriations committee recently approved a number of FY2023 government funding bills, including the Labor, Health and Human Services, Education, and Related Agencies (LHHS) package that contains discretionary spending for federal health programs. While it is certain that future Senate-side bipartisan negotiations will ensure any final government funding package that will ultimately become law will differ from what the House Appropriations committee has cleared, it is still instructive to keep track of the Democrat-led House deal, as it provides insight into that group’s policy priorities. A few provisions relevant to home-based care providers, detailed in the bill’s accompany report, include the following (note -many of these are merely signaling in nature, as opposed to explicitly directive):

  • Medicare Coverage of Home-based Extended Care Services.—The Committee encourages CMS to consider options to improve extended care services for Medicare beneficiaries, such as through home-based extended care by home health agencies (bottom of pg 184)
  • Patient Access to Home Health Care.—The Committee supports the intent of the network adequacy rules of CMS for Medicare Advantage organizations and for Medicaid managed care organizations under 42 C.F.R. 438 and 457 to maintain a network of qualified providers sufficient to provide adequate access for covered services to meet the health care needs of the patient population served. The Committee requests a report within 180 days of the date of enactment of this Act on regulatory actions related to network adequacy (bottom of pg. 186)
  • Home Health Aides.—The Committee recognizes that home health aides (HHAs) are the foundation of professional home-based caregiving, and that the growing population of disabled, chronically ill, and elderly Americans receiving home-based care requires a skilled and highly trained HHA workforce prepared to manage complex care needs. The Committee encourages HHS to explore how HHAs are meeting clinical competencies necessary to provide high-quality home-based care (pg. 221)
  • Direct Care Workforce Demonstration.—The Committee provides $3,000,000 for a Direct Care Workforce Demonstration project, to reduce barriers to entry for a diverse and high-quality direct care workforce, including providing wages, benefits, and advancement opportunities needed to attract or retain direct care workers. (pg. 211)
  • Dementia Care Management Model.—The Committee urges the Center for Medicare & Medicaid Innovation (CMMI) consider how best to test a Medicare dementia care management model. The Committee encourages CMMI to continue working with stakeholders to find a way to test a value-based dementia care management model that could reach dementia patients across the stages and include coordinated care management and caregivers. The Committee requests an update not later than one year after the date of enactment of this Act on the progress for this model. (pg. 180)

The bill also includes several provisions that would help to increase the health care workforce. Among other things, the bill includes: nearly $2 billion in new money for the Department of Labor, including for apprenticeship programs, Workforce Innovation and Opportunity state grants, and Senior Community Service Employment; $15,6 billion in new money for HHS to enhance nursing workforce development and other health care programs; and enhanced funding for targeted programs of the Administration on Community Living.

The Committee also adopted a manager’s amendment from House Appropriations Committee Chairwoman Rosa DeLauro (D-CT), that added language to the committee report that urges the Health Resources and Services Administration  (HRSA) to “address the skilled care workforce needs of seniors through existing workforce education and training programs.”

The most hospice and palliative care-specific bills in Congress right now include the Palliative Care and Hospice Education and Training Act (PCHETA) (S.4260) and the Expanding Access to Palliative Care Act (S. 2565). PCHETA would bolster the serious illness professional workforce and boost palliative and hospice research funding, while S.2565 would require CMMI to test a dedicated community-based palliative care demonstration informed by the recently-ended, hospice-only Medicare Care Choices Model (MCCM). Both bills are currently Senate-only at this point, and we need your continued advocacy and outreach to continue to garner co-sponsors for these important policies. Use NAHC’s grassroots outreach campaigns to ask your Senators to support these bills.

Elsewhere in DC, much of the policy conversation on palliative care in particular is occurring within CMMI. In light of the Innovation Center’s strategic refresh late last year, it has become apparent that leadership there is focused on streamlining their demonstration portfolio and developing ways to better integrate specialty care (which is how they conceptualize palliative care) into broader, population health-style models, primarily the ACO programs.

Recently, CMMI posted a blog that broadly spells out their early vision for this kind of integration. In the piece, they specifically write: “Until more ACOs can assume full risk, collaborative care codes, as currently used in behavioral health, could support integration and co-location of some specialty care, such as palliative care.”

NAHC, in tandem with other members of the National Association of Hospice & Palliative Care, continues to work with CMMI to explore how best to support and scale home and community-based palliative care.

NAHC to CMS: Maintain NP/CNS Authority to Certify Home Health

The National Association for Home Care & Hospice (NAHC) and a group of likeminded organizations have written to Brian Slater, Director of the Division of Home Health and Hospice in the Center for Medicare Centers for Medicare & Medicaid Services (CMS) to reiterate our strong support for the authority of nurse practitioners (NPs) and clinical…

CMMI Releases 5th Annual Home Health VBP Report

The Center for Medicare  and Medicaid Innovations (CMMI) has released the fifth Home Health Value-Based Purchasing (HHVBP) model annual report. The report shows  that total performance scores were 7% higher among agencies in HHVBP states than agencies in non-HHVBP states in 2020, a decrease in unplanned hospitalizations, ED visits leading to inpatient admission, and skilled…

Congress Expected to Pass Bill to Avert Major Medicare Cuts

The US House of Representatives passed legislation during the evening of Tuesday, December 7, that would delay significant payment cuts to Medicare providers. The Senate is expected to vote on and pass the bill in the next few days, where it would then be sent to the President’s desk to be signed into law. Assuming President Biden receives the bill, he will sign it into law.

This would represent a major advocacy win for NAHC and our members. By helping stave off the devasting rate reductions that were slated to start on January 1, 2022, Congress is recognizing that providers of all kinds, including home health agencies and hospices, continue to be historically challenged by the pandemic and unprecedented workforce shortages. Should the bill become law as expected, the delay in cuts will support the ability of NAHC members to continue serving patients and families at a time when high-quality home-based care has never been more necessary.

“NAHC commends the House for coming together to address these backward rate cuts. We now encourage our friends in the Senate to follow suit and swiftly pass this bill so home-based care providers across the country can continue to serve their communities without a major payment reduction imminently looming over their heads” said National Association for Homecare & Hospice President Bill Dombi.”

Text of the House bill can be found HERE.

The most relevant Medicare payment provisions in the House-passed bill include:

  • A three-month delay of the entire planned 2% Medicare sequester payment reductions, to be in effect January 1, 2022 – March 31, 2022 (i.e. no sequester-related payment reductions in effect for first 3 months of 2022)
  • A three-month, 1% reduction in Medicare sequester payment reductions, in effect April 1, 2022 – June 30, 2022 (i.e. a 1% across-the-board sequester-related payment reduction for Q2 of 2022)
  • A one-year delay until 2023 of the entire planned so-called PAYGO sequestration cuts, which were set to go into effect as a result of the budget deficit impact of the last major COVID-19 legislative relief package passed in March 2021. PAYGO cuts were estimated to be around $36 billion for Medicare providers.

Based on 2019 levels of Medicare spending for home health and hospice ($18.1 billion for home health; $20.9 billion for hospice), NAHC roughly estimates that the total savings across the two programs associated with this legislation reaches ~$1.85 billion.

The sequester-related delays in this bill are paid for by bumping up the sequester payment reduction amounts in the year 2030, and the PAYGO cuts are delayed for only one year until 2023. While this particular bill is very welcome news, the annual stress and threat of continued Medicare cuts is an ongoing challenge to home-based providers’ stability and predictability. NAHC is committed to fighting against harmful payment reductions and advancing sensible long-term sequestration relief.

There are other Medicare-related payment policies in the bill as well, including the maintenance of a 3 percent pay bump for Part B providers through 2022 under the Medicare Physician Fee Schedule, the delay of payment reductions tied to the clinical laboratory fee schedule, and a one-year postponement of Center for Medicare & Medicaid Innovation’s radiation oncology payment model demonstration.

Congress Expected to Pass Bill to Avert Major Medicare Cuts

The US House of Representatives passed legislation during the evening of Tuesday, December 7, that would delay significant payment cuts to Medicare providers. The Senate is expected to vote on and pass the bill in the next few days, where it would then be sent to the President’s desk to be signed into law. Assuming President…

Congressional Activity Reflects Strong Interest in Palliative Care

A series of bicameral and bipartisan actions in Congress in recent weeks has signalled strong support for the expansion and strengthening of palliative care in the United States.

As the population ages and more people live longer with greater disability and disease, policymakers are increasingly motivated to build out the palliative care infrastructure so that more patients and families can access these vital services that address the stress and symptoms of serious illness. The COVID-19 pandemic and the suffering it has caused have also spotlighted how the status quo system falls short when it comes to addressing what matters most to very sick patients and families, and have bolstered the interest and argument for more and better palliative care across settings.

Provider Training in Palliative Care Act

On September 29, Senators Jacky Rosen (D-NV) and Lisa Murkowski (R-AK) reintroduced the Provider Training in Palliative Care Act (S.2890), which would make changes to the Health Resources and Services Administration’s (HRSA) National Health Service Corp (NHSC) program to make it easier for participating providers to pursue additional fellowship training in palliative care. The NHSC provides scholarships and loan repayment to healthcare professionals practicing at approved sites located in/or serving Health Professional Shortage Areas (HPSAs) throughout the United States. NAHC is a strong supporter of this bill, recognizing the critical need to bolster the palliative skills of the health care workforce.

“NAHC applauds Senators Rosen and Murkowski for reintroducing the Provider Training in Palliative Care Act. Home-based providers of every kind, including those that deliver high-quality palliative care to people with serious illness, are facing unprecedented workforce challenges,” said Bill Dombi, President of the National Association for Homecare and Hospice. “We need creative solutions to expand training opportunities in the kind of holistic, person-and-family centered services that palliative care can provide. By making it easier for National Health Service Corp providers to pursue palliative care education, the bill would increase access to this much-needed care in some of the country’s most underserved communities.”

On October 5, Senator Jeff Merkley joined Rosen and Murkowski in co-sponsoring the legislation.

Palliative Care and Hospice Education and Training Act

Keeping with the drumbeat around supporting the palliative care frontlines, Senator Tammy Baldwin (D-WI) and Representative Yvette Clarke (D-NY-9) recently wrote to congressional Democratic leaders to request that the massive and still-developing reconciliation package include policies to boost and better prepare the serious illness workforce to meet the demands of the future. In a letter, the policymakers urged leadership to use the Palliative Care and Hospice Education and Training Act (PCHETA) as the foundational legislation for these negotiations.

PCHETA would promote education and research in palliative care and hospice, increase the number of palliative care professionals, and implement an awareness campaign to educate the public on its benefits. Passing PCHETA has long been a NAHC policy priority, and we strongly support the inclusion of the bill, or parts of it, in a broader social spending reconciliation package.

Community-Based Palliative Care Demonstration

In addition to these actions focusing on existing workforce challenges, a group of ten U.S. House members from the powerful Ways & Means committee recently penned a letter to CMS Administrator Chiquita Brooks-LaSure, calling for the agency to launch a community-based palliative care (CBPC) demonstration pilot run out of the Center for Medicare and Medicaid Innovation (CMMI). NAHC and other stakeholders in the hospice and palliative care community have been advocating for such a demonstration, and we are grateful for these House leaders’ efforts to encourage CMS to finally bring it to fruition. The letter cites research showing how CBPC not only improves the quality of life for patients and families, but also can reduce unnecessary and unwanted utilization that drives up costs for people with serious illness. As a matter of process, the members write that CMS could either create a new standalone CBPC model, or build upon the success of the existing Medicare Care Choices Model (MCCM). MCCM has been operating for 5 years, and is testing the quality and cost impacts of allowing hospice patients to receive hospice-like palliative care services without having to give up disease-focused “curative” treatments.

recent MCCM evaluation found that demo has reduced Medicare expenditures by $26 million while maintaining a high-quality of care and increasing the likelihood of participating beneficiaries electing the hospice benefit.

CMMI Lays out New Vision for Value-Based Care Demonstrations

NAHC is encouraged by aspects of CMMI’s new vision At a virtual event in late October, Centers for Medicare & Medicaid Services (CMS) leaders, including Administrator Chiquita Brooks-LaSure and Center for Medicare and Medicaid Innovation (CMMI) Director Liz Fowler, unveiled the agency’s refreshed strategic vision for developing, implementing, and evaluating new care delivery and payment…

Congressional Activity Reflects Strong Interest in Palliative Care

A series of bicameral and bipartisan actions in Congress in recent weeks has signalled strong support for the expansion and strengthening of palliative care in the United States. As the population ages and more people live longer with greater disability and disease, policymakers are increasingly motivated to build out the palliative care infrastructure so that…

Webinar: Unleashing the Capabilities of MAOs to Deliver Health Innovation for Older Adults in Underserved Settings

  • Thursday, October 7
  • 2:30PM – 4:00PM ET
  • REGISTER

As part of a broader partnership, CMMI, the Office of the Assistant Secretary for Health (OASH) and the Administration for Community Living (ACL) are jointly sponsoring a webinar titled, Unleashing the Capabilities of MAOs to Deliver Health Innovation for Older Adults in Underserved Settings on October 7 from 2:30-4:00 PM ET to highlight the emerging, numerous opportunities for MAOs to support beneficiaries in more fully meeting their care needs and goals through novel approaches and services enabled by technology.

The webinar will provide an overview of the data supporting these opportunities and will include a panel of three speakers from payer organizations, each of whom will provide an overview of their experience and results in innovating in the use of technology to address unmet enrollee health needs.

Panelists include:

  • Mona Siddiqui MD, MPH, Senior Vice President for Enterprise Clinical Strategy and Quality at Humana, who will discuss Humana’s approach to the use of data and predictive modeling to proactively engage and provide care for the highest risk and most vulnerable populations;
  • John Wiecha, Medical Director, Senior Products Division at Point32Health, representing the newly combined organizations of Harvard Pilgrim Health Care and Tufts Health Plan will provide an overview of a recent pilot project to improve dementia care through a digital caregiver support program; and
  • Caesar A. DeLeo, MD, MHSA Vice President & Executive Medical Director Strategic Initiatives, Highmark Health Enterprise Clinical Organization, Highmark BCBS who will discuss Highmark’s experience with telemedicine to approach substance use disorders during the pandemic and results from a five-year data driven program addressing appropriate opiate prescribing through profiling and academic detailing.

The webinar offers attendees the opportunity to gain a better understanding of the evidence and potential of several technology-enabled services in improving access, quality and outcomes of care, including, importantly, for underserved populations and will provide MAOs with insights more broadly on the challenges and solutions in design, implementation and evaluation of innovative and technology-enabled service.

MAOs that are considering such innovations who may wish to target the use of technology-enabled and/or other services based on chronic illness and/or Low-Income Subsidy (LIS) status through the VBID Model are encouraged to attend.