VNAA submits comments on FY 2014 Home Health Proposed Rule
Tuesday, August 27, 2013
by: VNAA Advocacy Team

Section: Public Policy and Advocacy

On Aug. 26, VNAA submitted comments on the CY 2014 Home Health Proposed Rule. Here are the primary areas of concern for VNAA:

VNAA’s key concerns with the proposed rule are as follows:
1)      The proposed payment reductions are in direct conflict with existing health care reform goals that seek to prevent initial hospitalizations and readmissions through close coordination among all providers including primary care providers and community based resources such as home health care providers.
2)      The methodology utilized by CMS to calculate home health margins is severely flawed and does not include critical factors such as the impact of sequestration and other payment reductions totaling over $72.5 billion between 2011-2020.
3)      CMS utilized a “cost-based” approach that does not consider the significant, non-reimbursed costs associated with patient care including health information technology, regulatory compliance, staff training, etc.
4)      CMS did not conduct a complete impact analysis of the proposed payment reduction, choosing instead to consider only one year of impact and providing no substantive analysis of the state-by-state or urban versus rural care impact.
5)      CMS did not appropriately consider the impact on or needs of vulnerable populations served by the Medicare home health benefit and specifically by the nonprofit home health delivery system.
6)      CMS proposes quality measures for home health care providers that do not align with current measures for other care settings, have not been approved by leading measure development organizations, and are not appropriately risk-adjusted.
7)      CMS proposes to eliminate certain ICD-9 does that are necessary for highly complex, post-acute care patients.
8)      CMS chose to rebase separately on episodes and did not consider the full impact on Low Utilization Payment Adjustments (LUPAs), Outliers or small and rural agencies. In addition, hospital based wage index flaws continue to disadvantage home health agencies while a majority of hospitals are exempted. 

VNAA worked in concert with its members and other national organizations to prepare comments.  VNAA was able to influence other national organizations on key issues including concerns on rebasing, quality and codes.   A draft copy of VNAA’s comments was distributed to members on Friday to provide a template that members could use for their own comments. 

Click here to read VNAA’s full comments on the proposed rule.
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