NAHC-NHPCO Alliance Submits Comments on Hospice CARE Act Draft Legislation

NAHC Report

The NAHC-NHPCO Alliance submitted a comment letter to the office of Representative Earl Blumenauer (D-OR-3) regarding the discussion draft of the Hospice Care Accountability, Reform, and Enforcement Act (Hospice CARE Act), which focuses on hospice payment reform and program integrity. The NAHC-NHPCO Alliance recognizes the importance of strengthening program integrity to combat bad actors, while also ensuring that access to care is not negatively impacted and quality providers are not unduly burdened.

NAHC and NHPCO have worked closely with Rep. Blumenauer for years on these issues and remain committed to continuing the dialogue to achieve optimal outcomes for hospice providers and the continued delivery of quality end-of-life care for patients and their families. 

We have always been a strong advocate for safeguarding the integrity of the hospice benefit to ensure continued availability of hospice services for future generations. Likewise, we have long emphasized a need to improve the benefit to meet the evolving needs of beneficiaries and their families, ensuring they receive compassionate, person-centered end-of-life care.

We thank all the Alliance members who provided feedback and input for our comments. We expect Rep. Blumenauer’s office to review all the submissions when considering modifications to the draft and then to formally introduce legislation some time before the November elections. The Alliance expects future opportunities to provide feedback and will keep our members updated at every step, continuously seeking input and guidance.

CMS Releases Guidance on New Medicaid Payment Rate Transparency Requirements

NAHC Report

• The services subject to the transparency requirements as well as clarifying that Managed Care is not included;

• Exclusions from the transparency requirements, such as value-based payment arrangements or individually negotiated rates that are not pre-determined prior to execution;

• Processes and standards to delineate the service-specific portions of a bundled payment;

• The requirements regarding the payment rate disclosure for homemaker, home health aide, personal care, and habilitation services, including:

• The mandate to publish a standardized hourly payment rate for service units other than an hour (ie: translate 15 minute rates into the hourly equivalent or daily rates of service into the hourly amount);

• Clarifying that providers and states do not have to publish the hourly rate paid to the direct care worker; and

• Providing additional information on how states should identify the specific services and billing codes subject to the payment rate disclosure.

• The Interested Parties Advisory Group (IPAG), which the state must establish by 2026, that will consult on payment rates for homemaker, home health aide, personal care, and habilitation services. Of note, Alliance members should be aware that Medicaid providers are not a required member of the group and that individual states must make the determination of which entities to include. We strongly encourage Medicaid-enrolled providers to engage with their states and advocate for robust provider inclusion on the IPAG.

• Procedures and requirements for states that seek to reduce payment rates, including new data analysis and reporting requirements for those services, such as many home care services, without a comparable Medicare service.

On Friday, July 12, the Centers for Medicare & Medicaid Services (CMS) released guidance to states on the steps needed to ensure compliance with rate transparency provisions of the Medicaid Access Rule. The guidance touches upon several items important to NAHC-NHPCO Alliance members and homecare providers, including:

The guidance is online at: https://www.medicaid.gov/medicaid/access-care/downloads/ffs-prov-final-rule-guidance.pdf.

Without Proper Post-Acute Care Relationships, MA Plans Are Leaving Money on The Table

Home Health Care News | By Andrew Donlan

Health plans generally do not have great visibility into their members’ care after an acute health event. Even when they do, many aren’t confident in the post-acute care provider that’s serving their member.

These findings come from a new survey of health plans conducted by the post-acute care technology company WellSky.

Specifically, the survey found that:

• Only 37% of respondents (health plans) manage members in a post-acute setting after discharge from acute care. The majority attempt to manage care internally rather than partnering with vendors or other post-acute networks.
  
  
• Just 33% of respondents reported that “the majority” of their members are discharged to “high-performing” post-acute care facilities.
  
  
• 43% of respondents expressed “moderate confidence” that their members receive the appropriate level of care post-discharge.

The health plan respondents – which were Medicare Advantage (MA) plans – ranged from those with 115,000 members to those with over seven million members.

“These findings reinforce what we continue to hear from payers regarding how important it is for MA plans to have greater visibility and proactive influence into their members’ discharges to ensure they are being sent to not only the right level of care, but to high-performing post-acute providers for a member’s specific conditions,” Andy Eilert, president of payer and emerging markets at WellSky, said in a statement. “This will help plans achieve lower total cost, enhanced quality of care and improved member outcomes.”

This is noteworthy information for home health providers, who are trying to negotiate on higher ground with MA plans. Quality home health care can reduce the Medical Loss Ratio for health plans. If those plans don’t have much visibility into where their members are getting post-acute care – in other words, lacking solid partnerships – or are having members use subpar providers, that leaves room for opportunity.

Home health providers that can establish relationships with MA plans, where they can take a certain number of patients in a given market, can negotiate for better rates or a better payment setup than they currently have.

That, in turn, can help bridge the gap between MA’s rates for home health services and traditional Medicare’s rates…

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Unfulfilled MA Referrals for Home Healthcare Can Lead to ‘Grave Consequences,’ Study Finds

McKnight’s Home Care | By Adam Healy
 
Medicare Advantage patients who are referred to but never receive home health services experience higher mortality rates and lower readmissions compared to those who received such services, according to a new study published in the American Journal of Managed Care.
 
The researchers examined 2,876 acute hospital discharges occurring between January 2021 and October 2022 that included home health referrals. Of these, 2,115 referrals led to the patients receiving home healthcare. The remaining 761 referrals did not lead to home health visits. On average, those who received the recommended home healthcare experienced better outcomes compared to those who did not.
 
“Those members who receive home health services may benefit from additional attention and assistance from healthcare workers, who may in turn advocate for members and escalate situations that could be life-threatening,” the researchers wrote. “Members who are referred to home health but who do not receive services do not receive the same attention and care as their counterparts, and this could have grave consequences.”
 
Unfulfilled home health referrals were associated with lower chances of survival among MA patients at 30, 90 and 180 days. Patients who received home health care had an average mortality rate of 2% at 30 days. That compares to 3% among those whose home health referral was not fulfilled. At 180 days, home health patients had a 11% mortality rate, compared to 14% in the other cohort.
 
However, patients receiving home health care also experienced higher per-member per-month care costs, at an average of $787. Additionally, members who received home health had higher readmission rates, on average, compared to those who did not.
 
Unfulfilled home health referrals can occur for a variety of reasons, according to the researchers. One common reason is that members who do not understand home care services, or who might be uncomfortable with letting clinicians into their homes, may refuse home health. For these patients, the researchers recommended better education, including discussions during hospital stays about what to expect from home health providers after acute care discharge.
 
Also, some home health providers may have trouble contacting or locating referred clients, the study noted, which can lead to unfulfilled referrals. In this situation, case managers can play an important role in connecting home health providers with their referred patients, according to the researchers.