Olson: The impact of federal policy on home health

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Olson: The impact of federal policy on home health

Tue, 02/13/2018 - 10:31am -- tim

by Jill Mazza Olson, Executive Director VNAs of Vermont Vermont's not-for-profit home health agencies are deeply engaged in their local communities and they are active partners in Vermont's health care reform efforts. This week was a reminder that federal policy has an enormous impact on the services our home health agencies provide and the people they serve.

We are still working with our national associations to analyze fully the impact of  H.R.1892, the Bipartisan Budget Act that was passed last week by both chambers of Congress and signed into law by the President. Some important highlights: This law extended a variety of Medicare programs including the home health rural add-on; funded the Children's Health Insurance Program for an additional four years over the last "continuing resolution" (for a total of 10 years); and set in motion a significant payment reform process in the home health sector. The bill also ended months of uncertainty by extending funding for the highly successful Nurse Family Partnership, a program Vermont has embraced. Click HERE for a link to our August article about the program.

National home health experts are calling the payment changes in the bill a "mixed bag." The rural add-on was restored for 2019, but it will be phased out over the next several years. In Vermont, the rural add-on will be 3 percent in 2019, 2 percent in 2020 and 1 percent in 2021. It will be entirely phased out in 2022. Earlier payment reform proposals included industry-wide cuts. The final package is budget-neutral across the industry. The impact on individual agencies, however, could be positive or negative. The model will take effect in 2020; earlier proposals called for a 2019 implementation date. The payment model will shift from 60-day payment episodes to 30-day payment episodes. The draft 2019 home health prospective payment system rule----slated for release over the summer---will fill in the details.  

On the regulatory reform front, the bill moves the current Medicare Face-to-Face visit documentation requirement in the right direction. Currently, CMS only considers the physician record when determining the home health agency's compliance with this requirement. This is a frustrating practice----the home health agency's reimbursement depends on the documentation; the physician's does not----and physicians are already overburdened with documentation requirements. The bill directs CMS to consider the home health agency's record in conjunction with the physician's documentation. Unfortunately, the bill says, "the Secretary may use documentation in the medical record of the home health agency as supporting material," rather than "shall."

Hospice patients and providers will benefit from the provision that allows physician assistants (PAs) to serve as attending physicians under the Medicare hospice benefit. Advanced Practice Registered Nurses can already serve in this capacity.

We will work closely with our national partners to the analyze impact of the budget on our member agencies and advocate for accompanying regulations that best serve Vermonters.