NAHC Receives Clarification on CMS Policies for Home Health Agencies

The National Association for Home Care & Hospice ( NAHC) has received additional clarification on Medicare coverage policies for home health agencies. Earlier this month NAHC reported on responses from the Centers for Medicare & Medicaid Services (CMS) on several key outstanding question. In that report NAHC noted follow-up was needed on two of CMS’…

CDC Provides New Guidance on COVID Vaccine Needs of Homebound Patients

The National Association for Home Care & Hospice (NAHC) has been urging the Centers for Disease Control and Prevention (CDC0 to recognize the special COVID-19 vaccine needs of homebound individuals and we are pleased to report that this has happened. New guidance from the CDC covers training of staff to deliver the vaccine, vaccine administration, safe storage of the vaccine, and pre-vaccination planning for the vaccination of homebound patients.

While this recognition is significant, the CDC has yet to address how home care companies access vaccines for purposes of administration to homebound individuals. Last week, NAHC President William A. Dombi wrote to new CDC Director Rochelle P. Walensky, MD, MPH, to urge action on getting vaccines to home care agencies so their homebound patients may receive the vaccine in a timely manner.

The 12 million Americans who are homebound and receive care from home health agencies, home care providers, and hospices are not capable of travelling to a local or state health department, a mass immunization site, or the local pharmacy to receive vaccination. This large population of America’s most vulnerable need to the vaccine to come to them or they will likely not receive it.

These Americans and their families and loved ones would helped enormously if the CDC could address  the essential issue as to how home care providers can access the vaccine for their patients.. We recognize that vaccine access is a need that goes well beyond homebound patients. Still, the known action to date by the CDC and state officials does not appear to consider this population at all. The recent expansions of access through pharmacies and mass immunization sites is a great improvement in vaccine access, but it does not help the 12 million homebound patients, virtually all of whom fall into a high priority classification.

More than 90 percent of home care and hospice providers are freestanding and not a part of the health systems that have received a vaccine supply. Those facilities have used vaccines for their inpatients and health care staff. Similarly, the vaccines provided to nursing home residents through the CDC partnership with Walgreens and CVC does not go to homebound patients.

NAHC represents most of the companies that provide health care in the home and we stand ready to work with the CDC is developing a viable plan of action to get America’s homebound population vaccinated. We worked extensively with the Department of Health & Human Services (HHS) and CDC in the distribution of the BINAX rapid tests in home care, the administration of infused therapeutics, and the prioritization of vaccines to home care staff. NAHC and HHS should consider us constructive partners in the vaccine administration, too.

NAHC is not insisting that homebound patients get special access. Rather, we are urging CDC to never allow these Americans to be forgotten. To effectively provide vaccinations to the homebound may require direct supply to the home care and hospice health care companies that care for these patients on a daily basis. There may be other options in administering the vaccine, but it is apparent it is necessary to develop a plan to make it happen. NAHC is ready to participate in developing that plan as we bring a knowledge and experience base that can be very helpful. Our members tell us that patients and their families are asking how and when the homebound population will gain access to the vaccine. We should at least be able to tell them that such a plan is in development.

NAHC has been in contact with CDC to ensure homebound patients receive fair access to the COVID vaccine and the enormous competencies of home health, home care, and hospice providers are tapped to make that effort a complete success. NAHC will continue to engage with the CDC on this matter and keep readers updated in NAHC Report and the Private Duty Source.

CDC Provides New Guidance on COVID Vaccine Needs of Homebound Patients

NAHC urges CDC to help get vaccine to home health, home care, hospice patients Find the new CDC guidance on NAHC’s COVID-19 News & Resources page! The National Association for Home Care & Hospice (NAHC) has been urging the Centers for Disease Control and Prevention (CDC0 to recognize the special COVID-19 vaccine needs of homebound…

Members of Congress Push for More HCBS Funding

With the next COVID-19 relief package currently under development and possibly coming with a significant price tag, upwards of $1.9 trillion as requested by the Biden administration, many elected officials and stakeholder groups are proposing increased funding to Medicaid home and community based services (HCBS). Similar proposals have been made in earlier versions of COVID-19…

NAHC Urges White House, Congressional Action on Palliative Care Priorities for 2021

The National Coalition for Hospice and Palliative Care, of which the National Association for Home Care & Hospice (NAHC) is a member, recently submitted a comprehensive set of legislative and regulatory recommendations to the Biden Administration and to key leaders of the 117th Congress.  The recommendations lay out the policy agenda that the Coalition intends…

NAHC to Congress: Minimum Wage Hikes Must Not Outpace Reimbursement Rates

On February 9th, the National Association for Home Care and Hospice sent a letter to leaders in Congress of both parties, outlining recommendations as legislators consider an increase in the minimum wage to $15 per hour. Twenty-eight state home care and hospice associations joined NAHC in signing the letter. An increase to the federal minimum…

Biden Orders Review of Trump Admin Public Charge Rule

President Biden announced on Tueday, February 2, an executive order directing federal agencies to review the previous administration’s immigration policies, including the public charge rule, which was initially proposed by the Trump administration in September 2018 and finalized it August of 2019.

Under the public charge rule the Department of Homeland Security (DHS) expanded what criteria it considered to be a public charge when evaluating an immigrant’s application for citizenship. Under the previous standard applicants could be denied if they were expected to be “primarily dependent on the government for subsistence. In expanding the criteria, DHS specified a list of prior usage of common government benefits to be taken into account for evaluation, including: temporary assistance for needy families (TANF), section 8 housing, federal housing subsidies, and certain Medicaid benefits. In addition, DHS would evaluate an applicant’s likelihood of need of public assistance in the future. These points of criteria include age, health, family size, and financial means.

This rule proved to be controversial since its proposal with many labeling it a “wealth test” for immigrants, and as a means to limit immigrants to the United States. The rule was challenged in court, eventually rising to the Supreme Court, which ultimately ruled in favor of allowing the regulation to be implemented. However, in August 2020 a federal court issued a temporary injunction that in-effect blocked implementation of the public charge regulation due to the COVID-19 pandemic. Under the injunction, as long as there is a public health emergency related to the pandemic, the regulation was barred from application, implementation, and enforcement. (See NAHC Report for more information.)

The public health emergency remains in effect, having been renewed most recently in January 2021.  

The National Association for Home Care and Hospice filed comments with DHS on the proposal expressing concerns that the rule could prove damaging to the home care and hospice providers that often rely on immigrants to work as caregivers, an occupation notoriously facing workforce shortages. It is estimated that about 30 percent of the home care workforce is comprised of people born outside the United States.

“This proposal will result in fewer eligible home care workers, as immigrants tend to serve as a sizable proportion of the personal care and assistance aides workforce,” writes NAHC in its comments on the proposed rule. “These workers often qualify for public assistance through programs such as Medicaid and the Supplemental Nutrition Assistance Program (SNAP). The typical annual income for these non-skilled workers falls below the guidelines for a two-member household as included in the proposed rule, and their eligibility for public assistance will also be counted as negative factors in determinations. Barring Immigrants on the basis of public assistance will only exacerbate an already prevalent workforce shortage leaving many employers unable to care for patients in need. This will cause patients to seek out more costly institutional settings for the same care they could have received in their home.”

“A reversal of this policy by the Biden Administration should help increase the home and community-based services workforce at a time when home care demand is rising,” said NAHC President Bill Dombi, in reaction to the news.

According to the best estimates, about 30 percent of the home care workforce is comprised of people born outside the United States, about evenly split between naturalized American citizens and non-citizen immigrants. “This is a strong indication that immigrants will play an important role in addressing the substantial workforce challenges home care will face in the coming years. According to the U.S. Bureau of Labor Statistics, home care workers rank in the top five fastest growing occupations. By 2026 the demand for home care workers is projected to increase by over one million.”

Due to low reimbursement rates offered by government programs like Medicaid or the Veterans Administration, compensation for home care workers is limited and a majority of them qualify for some form of public assistance. (About 30 percent qualify for SNAP and 30 percent qualify for Medicaid.)

The Biden executive order also rescinds a memorandum requiring family sponsors to repay the government if relatives receive public benefits. The order requires agencies to conduct a top-to-bottom review of recent regulations, policies, and guidance that have set up barriers to our legal immigration system.

CMS Answers Key Home Care Questions

The Centers for Medicare & Medicaid Services (CMS) has provided the following responses to several outstanding questions submitted by the National Association for Home Care & Hospice (NAHC) . NAHC submitted the questions after receiving requests for clarification on these issues from its membership. Question #1 There is confusion based on the regulations below. Section…

Biden Orders Review of Trump admin Public Charge Rule

President Biden announced on Tueday, February 2, an executive order directing federal agencies to review the previous administration’s immigration policies, including the public charge rule, which was initially proposed by the Trump administration in September 2018 and finalized it August of 2019. Under the public charge rule the Department of Homeland Security (DHS) expanded what criteria it considered to…

NAHC Wants Your Input for 2021 Legislative & Regulatory Agendas

The policy staff of the National Association for Home Care & Hospice (NAHC) and its affiliates — the Hospice Association of America (HAA), the Home Care & Hospice Financial Managers Association (HHFMA), and the National Medicaid Action Council — are in the process of developing their agendas for legislative and regulatory activities in the coming…