Posted on Monday, December 28, 2020

As the Biden administration prepares to take over the White House, home health and hospice providers are looking to the future and deciding what issues are most important on their agendas.

NAHC will be a regular presence in the halls of capitol hill advocating on all things home care and hospice. From a home health perspective, we have prioritized reimbursement for telehealth services via the HEAT Act, the Choose Home proposal, and an extension of the rural add-on.

  • HEAT Act – NAHC has long held the position that telehealth, and corresponding reimbursement, should be integrated into the Medicare home health benefit. In October that belief took a big step towards realization with the introduction of the Home Health Emergency Access to Telehealth (HEAT) Act. If enacted, the HEAT Act would grant the Centers for Medicare and Medicaid Services (CMS) the authority to issue waivers allowing for the reimbursement of telehealth services under the home health benefit. CMS would determine what services could be conducted via telehealth, as well as what the equivalency would be between an in-person visit and a telehealth visit for payment purposes.
  • Choose Home Proposal – While not necessarily a new concept, the idea has been refreshed and tailored to meet the challenges presented by the COVID-19 pandemic. In essence, Choose Home would provide expanded services and supports as part of the home health benefit for a patient population that is otherwise eligible for the skilled nursing benefit upon hospital discharge, but could be served by home health with added services and supports in the home. These could include personal care services, meal delivery, and non-emergent transportation among many others. An assessment tool would be used by hospital discharge planners and home health representation to identify eligibility and appropriateness.
  • Rural Add-on – Starting in January, home health delivered in rural areas will see a percentage decrease in the rural add-on. Services provided in a frontier county (defined as a maximum of 6 individuals per square mile) will receive a two percent add-on, while all other rural areas will receive a one percent add-on. This decrease is part of Congress’s targeted, phase-out policy for the rural add-on as included in the Bipartisan Budget Act of 2018. NAHC has, and will continue to advocate for a three percent add-on for all rural services.

From a hospice perspective, NAHC expects the most legislative action around the following items:

  • Hospice Survey Legislation – Following the release of two Office of the Inspector General reports in July 219, NAHC worked with Members of both the Senate and House of Representatives on legislation that would strengthen and standardize the hospice survey process with the goal of increasing transparency and accountability to all involved parties, as well as remediation tools CMS can employ when needed for deficient providers. Momentum behind this work stalled with the onset of the COVID-19 pandemic in March, but has picked up again in recent weeks as the Congress returns attention to non-COVID related matters.
  • MedPAC Recommendations – In recent months, the Medicare Payment Advisory Commission (MedPAC) has begun to focus on what they believe to be high financial profit margins, as well as long lengths of stay and live discharge rates. To counter these trends the commission has begun exploration into recommendations that would address high profit margins and long lengths of stay, through a site-neutral payment model, and questionable outlier utilization patterns among some hospices with development of compliance thresholds. Differences on these topics proved strong at a recent MedPAC meeting suggesting agreement on policy recommendations to the Congress would not develop seamlessly. If formal policy recommendations are approved by MedPAC, the Congress would still need to act on it for it to be realized as law.
  • Technology-based flexibilities – In the early days of the COVID-19 pandemic, CMS took action to provide waiver-based temporary regulatory relief that provided health care professionals with time and resources to optimize their care delivery, spend more time with their patients and less on paperwork, and provide caregivers with additional tools for care delivery. Those relaxations proved effective and well-received by patients and caregivers alike. In the months since, momentum has developed behind transitioning select regulatory flexibilities to becoming permanent fixtures of the Medicare program. One such policy is the use of telehealth in performing the face-to-face recertification for hospice eligibility. This has long been a NAHC position. Application of the concept during the pandemic has demonstrated effectiveness and has been well received by hospice patients.

 

Source: NAHC Report

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