Home Health Industry Comments on CMS’ Latest Bundled Payment

Posted on Sunday, October 30, 2016 1:32 PM

Home health providers and associations have strong feelings towards CMS’ bundled payment models. Most of the industry requests that CMS needs to lighten up on the homebound requirement for patients.

The Alliance for Home Health Quality and Innovation voice their opinions that the homebound requirement shouldn’t apply to patients that experience improvement in the middle of a 60-day episode, which results in no longer being homebound. A waiver would permit home care to continue until the episode ends, recommends Teresa Lee, the Alliance’s executive director.

Overall, 175 comments were submitted before the October 8 deadline.

CMS plans to provide lump-sum payments to hospitals for patients with the following:
• Acute myocardial infarctions
• Coronary artery bypass grafting surgery
• Surgical hip/femur fracture treatment

The models are proposed to run from July 2017 through the 2021 calendar year.

NAHC urges CMS to hold off on models

In a letter signed by Bill Dombi, vice president for law for the National Association for Home Care & Hospice (NAHC) and Mary Carr, NAHC’s vice president for regulatory affairs, NAHC encourages CMS to delay the models until they have received proper tests results.

“It is perplexing why CMS would go forward with plans to create and test three new pending episode payment models that would impact a significant number of Medicare beneficiaries and providers without clear evidence of the effectiveness of these models,” the NAHC letter states.

State associations voice their concerns

The episode payment model CMS intends to use in its latest bundling tests doesn’t include any safe harbor or waiver protection from the federal anti-kickback statute, civil monetary penalty law or prohibitions in the physician self-referral law, notes Mary Grause, the Healthcare Association of New York State’s president.

Pennsylvania Homecare Association, CEO Vicki Hoak, specifically asked CMS whether those hospitals can “tell patients there are ‘preferred’ providers” or that patient’s choice is limited to a short list of their ACO partners.

For the full article, please see the October 31, 2016 Home Health Line Edition.

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