VNAA Solicits Member Comments on the Proposed Home Health Rule Comment via Email: Register for August 7 All-Member Call
Tuesday, July 30, 2013
by: VNAA Policy Team

Section: Quality and Educational Programming

VNAA is soliciting comments from members on the proposed home health rule. Please review VNAA’s analysis and submit comments via email to Katy Barnett at kbarnett@vnaa.orgno later than August 6.  
In addition to emailing comments, please register for the August 7 all-member conference call to review VNAA’s response to the proposed rule. To register for this call please click here.

Listed below are highlights from VNAA’s summary.   Please review the full analysis by clicking here.
Rebasing:The rule proposes a 3.5 percent rebasing cut for each of the next four years (FY 2014, 2015, 2016, and 2017). This equals a total cut of 14 percent if the rebasing cuts go forwards as proposed, which is a much deeper cut than VNAA believes is justified.

The immediate impact of rebasing will be tampered by the fact that VNAA and other home health associations were able to convince Congress to incorporate a 4-year phase-in and 3.5 percent annual cap on payment changes resulting from rebasing. Moreover, for this year, most of that 3.5 percent cut is mitigated by a proposed 2.4 percent market basket increase. This, combined with other factors that are favorable to nonprofits, further reduce the total impact of rebasing.
The result is an estimated, gross impact on freestanding, nonprofit agencies of -.8 percent (half the cut facing free-standing, for profits or 1.7 percent) and -1.1 percent for provider based nonprofit agencies.
Quality:The Centers for Medicare and Medicaid Services (CMS) proposes to add two new quality measures based on CMS claims data rather than agency reported OASIS data. Both new measures relate to CMS’ interest in reducing re-hospitalizations and overall hospital costs. The first new measure is re-hospitalization during the first 30 days of home health care. The second is emergency department use without hospital readmission during the first 30 days of home health care. CMS proposes to provide feedback on these measures to home health agencies in 2014 and add them to Home Health Compare for public reporting in 2015.

CMS simultaneously proposes to remove some OASIS-based measures from CASPER reports that it believes are redundant and which will allow for the addition of other unspecified measures in the future.
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