Proposed Medicare rule for home health will jeopardize access to care
Tuesday, August 27, 2013
by: Visiting Nurse Associations of America

Section: Face to Face

WASHINGTON—Aug. 26,2013—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.

Tracey Moorhead, President and CEO of VNAA, noted: “The Affordable Care Act (ACA) gave CMS considerable flexibility to determine how to rebase Medicare home health reimbursement. However, CMS has proposed the maximum reduction outlined in the statute. 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.”

In formal comments, VNAA calls upon CMS to use more current home health cost reports, to consider the cost of care (including costs associated with mandated reporting and documentation requirements) and to consider other cuts of $72.5 billion impacting the benefit between 2011 and 2020. VNAA further urged CMS to complete a full impact analysis for all four years of proposed cuts, provide a substantive analysis of the state-by-state impact as well as the impact of urban versus rural care. VNAA cites concerns that rural providers will be especially hard hit under the proposed HHPPS rule: a targeted 3 percent add-on that helps to offset the high costs of serving rural patients will expire in 2015, meaning that rural patients will see a 17 percent cut in the benefit in 2016 and 2017.

Finally, and most critically, 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. 

The Medicare home health benefit, established in 1965, allows certified home health agencies to address the clinical care needs of homebound beneficiaries. The benefit is a critical component in efforts to avoid primary hospitalizations and prevent unnecessary re-hospitalizations. VNAA believes the Medicare home health benefit offers important opportunities to meet the goals of health care reform to improve outcomes and beneficiary health and keep the cost of health care down.


About VNAA: VNAA is a national association that supports, promotes and advances nonprofit providers of home and community-based healthcare, hospice and health promotion services to ensure quality care for their communities. VNAA members share a mission to provide cost-effective and compassionate care to some of the nation's most vulnerable individuals, particularly the elderly and individuals with disabilities. Learn more at

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