VNAA continues to press both the Centers for Medicare and Medicaid Services (CMS) and Congress for resolution to the face-to-face documentation challenges faced by our members. This week, VNAA submitted comments to CMS on the draft standardized templates and emphasized our ongoing concerns about the excessive requirements placed on home health agencies. VNAA will also participate in an in-person meeting with CMS to discuss possible solutions.
In its comments, VNAA asserts, as presented, the templates are unworkable due to their length, the burden of collecting this amount of information and the voluntary nature of the templates. VNAA expressed concerns that few to no clinicians will use them and instead, expect that fewer physicians will refer patients to home health care. As a result, beneficiaries who need and prefer to receive high quality, safe care in their homes (at a fraction of the cost to the Medicare program than other settings of care) will see reduced access to this care. You can read our full comments here. We have also met with a range of stakeholders, including the National Association for Home Care & Hospice, the Partnership for Quality Home Healthcare, the Alliance for Home Health Quality and Innovation, and the American Medical Association, to discuss opportunities for collaboration in our efforts before CMS and the Hill. We will continue to update you as we work towards a solution.