Contact Your Member of Congress: Impact Analysis Tools Available to Help Make the Case
Tuesday, September 3, 2013
by: Policy Team

Section: Quality and Educational Programming

VNAA is working to prevent significant payment reductions contained in the proposed Medicare home health payment regulation released July 3. Briefly, the proposed rule outlines a 14 percent cut to home health payments through rebasing over four years, at a rate of 3.5 percent per year. The proposed cuts would dramatically cut access for vulnerable patients and have a grave impact on nonprofit providers.

Sen. Debbie Stabenow (D-Mich.) and Reps. David McKinley (R-W.V.) and Doris Matsui (D-Calif.) are currently circulating "Dear Colleague" letters calling for a rollback of the dramatic cuts. But many more senators and representatives need to sign these letters before CMS will listen. Be sure to customize your communications to show the impact of cuts for patients you serve as well as jobs that will be lost.

ACTION NEEDED: Please take a moment to: 1) Make your members of Congress aware of how much the 14 percent cut will negatively impact vulnerable patients and your agency, 2) Ask your senators and representatives to sign on to one of the "Dear Colleague" letters noted above and 3) send your feedback on communications with Congress to

A number of documents are now available on VNAA's website to assist members in their rebasing advocacy, including:

Individual State Profiles

Issue Overview: Proposed Home Health Prospective Payment System (HHPPS) Regulation

Infographic: Home Health Cuts Don't Add Up

Impact Overview: Projected 2017 Home Health Medicare Margins

Medicare Rebasing: Impact on Medically Underserved Communities

Use VNAA's Contact Congress system to send a message to your members of Congress, or call your members of Congress at 202-224-3121.

VNAA’s Comments on the HHPPS Regulation
In comments submitted to the Centers for Medicare and Medicaid Services (CMS) on Aug. 26, the Visiting Nurse Associations of America (VNAA) strongly opposed a proposed rebasing plan that would cut the Medicare home health benefit by 14 percent from 2014 to 2017, with a 3.5 percent cut each year. VNAA made the case that the Affordable Care Act (ACA) gave CMS considerable flexibility to determine how to rebase Medicare home health reimbursement.  A reduction of 14 percent is unjustified from a data perspective, will curtail access to care for many vulnerable patients and is in direct conflict with the goals of health care reform to improve outcomes and beneficiary health and keep the cost of health care down. 

VNAA called upon CMS to use more current home health cost reports as well as consider the total cost of care and other cuts of $72.5 billion from 2011 through 2020.  In addition, VNAA urged CMS to complete a full impact analysis for all four years of proposed cuts, and provide a substantive analysis of the state-by-state impact as well as the impact of urban versus rural care.  

Also critical, VNAA urged CMS to finalize a study mandated by Sect. 3131 of the ACA to determine the cost of care for vulnerable populations. In a similar study, funded by the Community Health Accreditation Program (CHAP) and conducted by VNAA and the Visiting Nurse Service of New York (VNSNY), costs for clinically complex patients exceeded reimbursement by 40 percent.  

To see the full VNAA Comments, please click here
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