CMS Provides Another Opportunity for Burden Reduction Recommendations

The Centers for Medicare & Medicaid Services (CMS) has issued a Request for Information (RFI) seeking new ideas from the public on how to continue the progress of the Patients over Paperwork initiative. This RFI provides an opportunity for home health and hospice providers to submit recommendations for relief from burdensome regulations and policies. CMS…

NAHC Wants Your Input for 2019 Legislative & Regulatory Agendas

The policy staffs of the National Association for Home Care & Hospice (NAHC) and its affiliates — the Hospice Association of America (HAA), the National Medicaid Action Council, and the Private Duty Home Care Association (PDHCA) — are in the process of developing their agendas for legislative and regulatory activities in the coming year. NAHC,…

NAHC Seeks Hospice Input on Impact of CMS Regulatory Relief Proposals

As reported in NAHC Report on September 18, 2018, the Centers for Medicare & Medicaid Services (CMS) has proposed changes designed to reduce regulatory burdens for hospice providers.  NAHC and its affiliate, the Hospice Association of America (HAA), are preparing comments on the proposed changes and would like your feedback. We have developed an online…

Get Critical Insights into the CMS Interpretative Guidelines for the Home Health Conditions of Participation!

In September 2018 NAHC presented a webinar on the CMS interpretative guidelines for the home health conditions of participation (HHCoP) and the response was overwhelming. In fact, we were actually overwhelmed with more requests to join the webinar than we could handle at the time. Therefore, we will be re-running the webinar for members-only on…

Education at Day 3 of the NAHC Conference Shows You How to Keep Your Agency on the Right Side

Health care is perhaps the most-regulated industry in the United States and staying on the right side of all the laws and regulations that exist can seem like a bigger job than actually caring for patients. Fortunately for those who attended the 2018 Home Care and Hospice Conference and Expo in Grapevine, Texas, the experts…

NAHC’s 2018 Regulatory Blueprint for Action Available for Online Reference

Since the early days of the National Association for Home Care & Hospice (NAHC), the organization has maintained a “Regulatory Blueprint for Action,” which contains regulatory policy positions held by NAHC.  This compendium is revised by NAHC staff on an annual basis; the revisions take into account recommendations submitted by NAHC members, affiliated state associations…

NAHC Webinar on Impact of the New Budget on Home Care and Hospice

Please join the National Association for Home Care and Hospice (NAHC) on Thursday, February 15, 2018 at 2:00 PM Eastern for a discussion called “The Latest Policy and Budget Developments in Home Care and Hospice.” The issues covered in this webinar are the result of legislation signed into law by President Trump last week, the…

NAHC’s Mary Carr on the Regulatory Outlook for Home Care

Mary Carr, Vice President for Regulatory Affairs at the National Association for Home Care & Hospice (NAHC) spoke to Annie Erstling of Forcura about home care regulation. Mary picks the one home health regulation she would most like to see simplified and urges agencies, particularly smaller ones, to join a home care association in order…

HHGM Proposal Not Finalized in CMS’ 2018 Prospective Payment System Rate Update

The Center for Medicare & Medicaid Service has issued the Calendar Year (CY) 2018 Home Health Prospective Payment System Rate Update final rule on the Federal Register, public inspection page.

CMS indicates that based on the comments received it is not finalizing the HHGM proposal for a new payment model in 2019at this time.

Although this is not the full equivalent of withdrawing the proposal,  it is a clear victory for the home health community that took action to stop the rule from becoming final. NAHC thanks every one who has fought this good fight with us.

“The National Association for Home Care & Hospice extends its sincere thanks to CMS for its serious consideration of the home health community’s concerns regarding the proposed payment model,” said NAHC President William A. Dombi. “CMS’s actions today will help preserve access to care for the three and a half million Medicare beneficiaries who rely on home health services every year. NAHC stands ready to work with CMS to improve the payment model that is the key to continued access to high quality and cost-efficient care in the home for our most vulnerable citizens.”

2018 HHPPS Rate Update

CMS is finalizing a standardized episodic payment rate for 2018 of $3,039.64, which is slightly higher than the proposed rate of $3,038.43. The difference in the rates reflects a change in the budget neutrality factors from the proposed to the final rule for the wage index and case mix weight recalibrations. CMS recalculated these using more recent data available for the final rule.  A slight increase is also reflected in the per visit rates for 2018.

As expected, the rates reflect a market basket update of 1% along with case mix creep adjustment of .97 percent. CMS maintains the proposed outlier policy and a non-routine supply conversion factor of $53.03 as proposed.

Home Health Value Based Purchasing Program  (HHVBP)

CMS finalized the proposed changes to the HHVBP program. The OASIS based Drug education on All Medications will be removed beginning with payment year three.  In addition, CMS finalized the number of completed HHCAPHS surveys that will be used for the HHVBP from 20 to 40 and will apply the 40 survey threshold to payment year one.

Home Health Quality Reporting Program (HHQP)

CMS finalized the majority of the proposals related to the HHQRP beginning in 2019. The exceptions were to not finalize the standardized assessment item for Cognitive Function and Mental Status; Special Services, Treatments, and Interventions; and Impairments.

A more detailed NAHC Report to follow on the changes to the HHQRP.

NAHC Asks CMS for Regulatory Relief for Home Health in Puerto Rico

The National Association for Home Care & Hospice (NAHC) has written a letter to Seema Verma, Administrator of the Centers for Medicare and Medicaid Services (CMS) seeking regulatory relief for home health providers located in Puerto Rico. Specifically, NAHC is requesting that CMS further delay the implementation date for the home health conditions of participation (HHCoPs) by an additional six months, until July 13, 2018, for agencies affected by Hurricane Maria.

CMS issued a final rule entitled “Medicare and Medicaid Programs: Conditions of Participation for Home Health Agencies” published in the Federal Register on January 13, 2017. The published effective date for the final rule was July 13, 2017, and a new rule delays the effective date until January 13, 2018. An extension in the effective date had been sought by the home health community as the changes required are extensive and costly.

In the case of Puerto Rico, recovery efforts from the devastation caused by Hurricane Maria are expected to continue for many more months. The destruction to the infrastructure (no electricity, running water, etc.) in many regions throughout the island make it nearly impossible to carry out continuity of existing business plans much less implement new policies, procedures, and operations required by the sweeping regulatory changes in the revised HHCoPs.

To compound the problem, CMS just recently released a draft of the new HHCoP interpretive guidelines for public comment with the expectation that a final version will not be available until December. This time frame is insufficient for the typical home health agency to adopt policies and processes, but for home health providers in Puerto Rico a delay in the implementation date is imperative if compliance expectations are to be met.

Please stay tuned to NAHC Report, as we will update this story as developments warrant.