VNAA Sends Comment Letter to MedPAC on Proposed Recommendations
Monday, January 28, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On January 18, VNAA sent a letter to the Medicare Payment Advisory Commission (MedPAC) chairman Glenn Hackbarth commenting on the Commissions proposed recommendations for their March 2013 Report to Congress.

MedPAC’s recommendations are for 2014. No change would not take effect unless Congress passes legislation or the Centers for Medicare and Medicaid Services (CMS) takes regulatory action so adoption is far from certain. To review the MedPAC staff reports from the January 10-11 meeting, please click here.

VNAA continues to urge the Department of Health and Human Services to use its ability to put a temporary moratorium in place in geographic areas with aberrant patterns of use in both home health and hospice.

Home Health

With regard to home health, VNAA expressed strong concern that MedPAC was mischaracterizing Medicare home health as a long-term benefit.  VNAA also noted that cost comparison of therapy under the Medicare home health benefit and therapy provided under Medicare Part B in outpatient settings is both misleading and inaccurate. 

VNAA again noted that access to home health agencies cannot be defined based on zip code as many vulnerable patients are avoided by profit-seeking agencies because the their high cost.     

VNAA objected strongly to the Commission’s call for accelerated rebasing noting difficulties with substandard cost reporting and the need to incorporate information from the CMS Vulnerable Patient Study.  VNAA also share with MedPAC the results of the VNAA and VNSNY study of patients which identified specific variables associated with high cost care that are not currently accounted for in the prospective payment system (PPS).

VNAA continues to strongly disagree with MedPAC’s recommendation that a home health co-payment be required for patients admitted to home health without a prior hospitalization which would negatively impact access to home health for vulnerable patients.  


VNAA strongly disagreed with the Commission’s recommendation to eliminate a payment update to hospice for 2014. Based on the Commission’s own data regarding margins, nonprofit hospices have low margins compared to their for-profit counterparts; 13.4 percent for for-profits, 7.6 percent for nonprofits and 3.2 percent for home health based hospices. The elimination of a payment update would hurt nonprofits, which serve the most vulnerable patients including short stay patients which are often the most costly.

VNAA supports the Commission’s efforts to adjust hospice payment to better address the cost of short stay patients with the conditions that: 1) redistribution of dollars reflects actual costs, 2) the change is budget neutral and restores dollars to the system, and 3) protections are in place against fraud and abuse.

To review the comment letter submitted to MedPAC, please click here.  
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