Current Issues in Home Health and Hospice Advocacy

Home Health

• VNAA Summary of Proposed Rule for Medicare Home Health for Calendar Year (CY) 2015: On July 7, 2014, CMS published in the Federal Register its Proposed Rule for Medicare Home Health for Calendar Year (CY) 2015. The rule proposes multiple changes to the home health payment rates as well as significant changes in other home health policies including face-to-face documentation, therapy assessment schedules, and requirements for OASIS data submission. The proposed rule also introduces CMS’ preliminary plan for a value based purchasing pilot in 2016 and requests industry input on the approach being considered.

Face-to-Face Encounter Documentation ToolkitNew

Below are links to a toolkit created by VNAA to help your agency address face encounter documentation issues to your local member of Congress. The toolkit includes a sample press release template for your customization and a sample letter to the editor or blog posting. If you need further assistance or have questions on communicating with the media, please feel free to contact VNAA.

• Draft letter to your member of Congress including talking points on the impact of face-to-face on home health providers and VNAA’s recommendations.
• Draft letter to HHS and CMS from your agency and/or your member of Congress
• Study by the Office of the Inspector General on face-to-face encounters | Talking Points
• Letter to CMS from Massachusetts Medical Society, Home Care Alliance of Massachusetts, Atrius Health and Partners Health Care
• Letter to CMS from New Hampshire Medical Society, Home Care Association of New Hampshire, New Hampshire Hospital Association and New Hampshire Medical Group Management Association

• VNAA Letter in Support of the Telehealth Enhancement Act of 2013 (HR 3306)
• Rebasing Dear Colleague Letters (Senate | House): On Sept. 25, members of the U.S. Senate and House of Representatives sent a letter to Marilyn B. Tavenner, Administrator of the Centers for Medicare and Medicaid Services, regarding the 2014 Home Health Perspective Payment System (HHPPS) and its proposed implementation of the rebasing provision.
• Congressional Post-Acute Letter: On August 19, VNAA submitted comments in response to a request for information issued by the joint Congressional committees of health care jurisdiction. The letter, released June 19, invited VNAA and other post-acute providers and stakeholders to submit comments on ways to address substantial variations in Medicare spending, utilization, quality and profit margins within the post-acute care (PAC) sector.
• CMS:  Proposed Rule on Emergency Preparedness Standards for Medicare and Medicaid Facilities For Home Health and Hospices : On December 27, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule to create consistent emergency preparedness requirements for most health care providers participating in Medicare and Medicaid.
  • VNAA Executive Summary of Final Emergency Preparedness Rule
• Final Home Health Rule for CY 2014: On November 22, the Centers for Medicare and Medicaid Services (CMS) released its final home health rule.
  • VNAA Executive Summary of Final HHPPS Rule
• Home Health Proposed Rule for CY 2014: On July 6, the Centers for Medicare and Medicaid Services (CMS) released its proposed home health rule that would take effect for calendar year 2013. Consistent with practice over the past few years, this proposed rule includes both the usual payment update proposals and an assortment of other changes to home health and hospice rules, ranging from trivial to very significant.
  • VNAA Summary of the HHPPS Rule
  • Impact Overview – Projected 2017 Home Health Medicare Margins
  • Infographic – Home Health Cuts Don’t Add Up
  • Issue Overview – Proposed Home Health Prospective Payment System (HHPPS) Regulation
  • Medicare Rebasing – Impact on Medically Underserved Communities
     

Hospice and Palliative

• Medicare Part D and Hospice Drug Coverage
  The Center for Medicare and Medicaid Services (CMS) recently issued guidance for Medicare-certified hospices and Part D plan sponsors to establish a procedure to limit instances in which Part D plans inappropriately cover prescription medications related to a hospice beneficiary’s terminal condition. VNAA has been very active in response to this issue which creates confusion and delays in obtaining necessary medications for hospice beneficiaries. VNAA has met with CMS officials and also with Congressional staff in conjunction with a multi-stakeholder coalition of hospice organizations, Part D sponsors, pharmacists and consumer advocates. VNAA is closely aligned with these stakeholders in calling for a reversal of the new CMS policy on Part D coverage determinations for hospice beneficiaries.
  • Joint Letter to Centers for Medicare and Medicaid Services re Final 2014 Guidance on Part D Payment for Drugs for Beneficiaries Enrolled in Hospice
• FY2015 Payment Rule’s Payment Model Reform
  • VNAA Comment Letter to CMS re FY2015 Hospice Wage Index and Payment Rate Update; Hospice Quality Reporting Requirement and Process for Appeals for Part D Payment for Drugs for Beneficiaries Enrolled in Hospice
  • MedPAC Comment Letter to CMS re FY2015 Hospice Wage Index and Payment Rate Update
• Fiscal Year 2014 Proposed Rule for Medicare Hospice Wage Index, Payment and Quality Measures: On April 29, the Centers for Medicare and Medicaid Services (CMS) posted its proposed rule governing wage index and quality measures provisions for Medicare Hospice for FY 2014 beginning on October 1, 2013. The rule was published in the Federal Register on May 10.
   

Other

• VNAA Comments to the Senate Commission on Long-Term Care: In a letter to the Commission on Long-Term Care on Aug. 27, 2013, VNAA shared its guiding principles to reform the delivery of long term supports and services today and for future generations. The Commission was established under Section 643 of the American Taxpayer Relief Act of 2012 (P.L. 112-240), signed into law on Jan. 2, 2013.
• Program Integrity: VNAA in conjunction with its members developed a white paper consisting of proposals to reduce the incidence of abuse in the Medicare program and enhance the quality of care agencies provide. VNAA began this project anticipating that the growth in reported abuse of the Medicare home health benefit would require action and that VNAA could and should take a leadership position.
• Rural Issues: VNAA has been very active on rural and underserved health issues over the past year and will continue to be active in the coming year through the formation of a new interest group focused on helping rural home health and hospice members’ access opportunities through agencies like the Health Resources and Services Administration (HRSA) as well as network with each other.
• VNAA Vulnerable Patient Study: VNAA, in collaboration with the Center for Home Care Policy and Research of Visiting Nurse Services of New York, has completed a study that analyzed data on a range of patients that VNAA members treat and the costs associated with providing care to these patients