VNAA submitted comments on Friday to the Ways and Means Subcommittee on Health Chairman Kevin Brady (R-TX) on the Hospitals Improvements for Payment (HIP) Act of 2014 discussion draft. Rep. Brady unveiled the draft legislation, focusing on comprehensive Medicare reform, in late November seeking stakeholder input.
Title I of the discussion draft has a number of provisions that seek to improve the Recovery Audit Program in response to the high rate of claim denials and backlog of appeals. VNAA encouraged that the draft also apply the same provisions to the Medicare Administrative Contractors (MACs). VNAA requested that the legislation to address the specific context of home health agencies:
- Include a six month moratorium (January 1, 2015 - June 30, 2015) on new MAC audits for the face-to-face requirement. This will provide HHAs and the MAC auditors with sufficient time to transition to the new documentation requirements.
- Require that CMS conduct additional MAC training on areas where there are a high number of denials, including the face-to-face documentation for home health claims, to assist in uniform application of CMS policies across MACs.
- Offer HHA's the option to settle with CMS for claims that were denied by MACs due to insufficient documentation related to the face-to-face narrative requirement.
- Require that 100 percent of funds recouped due to claim denials be returned to CMS. If all or a portion of recouped funds may be kept by the MAC (or other auditor), the MACs will be incentivized to deny as many claims as possible.
VNAA will to work with the Ways and Means Subcommittee on Health to incorporate the suggested improvements to the legislation. To see the final letter please click this link.