Here We Go Again

Clinical

by | Nov 8, 2024 | Clinical, CMS, Editorial, Medicare Advantage, Regulatory

by Tim Rowan, Editor Emeritus

OIG Accuses Medicare Advantage Providers of Padding Patient Assessments...Again

“Hello, this is your Medicare Advantage company calling. I am one of their clinicians and it is time for us to update your health assessment. If you will agree to a home visit, we will send you a $50 gift card to CVS.”

This phone call my brother received is typical, increasingly common, and not necessarily on the up-and-up, according to a new report to CMS from the Department of Health and Human Services Office of the Inspector General (OIG). OIG found that these home visits, known in the insurance industry as “Health Risk Assessments,” (HRA) when coupled with HRA-related claims data, increased Medicare Trust Fund payments to MA companies $7.5 billion in 2022 and twice that in 2023. Most of it went to the top 20 companies.

Concerned woman on a telephone call

The October 2024 report, “Medicare Advantage: Questionable Use of Health Risk Assessments Continues to Drive Up Payments to Plans by Billions,” accuses the industry as a whole of improperly padding payments by “finding” new health conditions during these HRA’s that may indicate the need for additional care at additional cost to the company. It questions the use of MA plan employees doing these assessments instead of relying on the customer’s primary care physician’s reports.

OIG references CMS’s own report, “Part C Improper Payment Measure (Part C IPM) Fiscal Year 2023 (FY 2023) Payment Error Rate Results,” to determine that gross overpayments to Medicare Part C plans in 2023 amounted to just over six percent of total payments, or $14.6 billion. The net increase to MA plans, after adjusting for underpayments, brought the percentage to 4.62. Total 2023 payments to MA plans came to $275,605,962,817.

The report also points out that identifying additional customer need during an HRA does not necessarily translate into the insurance company paying for additional care.

OIG Recommendations

In addition to implementing prior OIG recommendations, the new report asks CMS to:

    • Impose additional restrictions on the use of diagnoses reported only on in-home HRAs or chart reviews that are linked to in-home HRAs for risk-adjusted payments,
    • Conduct audits to validate diagnoses reported only on in-home HRAs and HRA-linked chart reviews, and
    • Determine whether select health conditions that drove payments from in-home HRAs and HRA-linked chart reviews may be more susceptible to misuse among MA companies.

CMS concurred with OIG’s third recommendation but rejected the other two.

While the entire 38-page report is well-worth reading, OIG has also published a one-page summary.

At this year’s annual conference of The National Alliance for Care at Home, the new merger of NAHC and NHPCO, a number of education sessions were devoted to teaching Home Health agency owners how to negotiate with Medicare Advantage plans in order to minimize losses and better care for patients who chose those plans. Comments included the high rate of care denial, unreasonable prior authorization policies, and slow payments as compared to traditional Medicare. Other healthcare entities have chosen a potentially more effective response: Just Say No. 

Hospital systems have had enough

According to a roundup of recent decisions by large and small healthcare systems in Becker’s Hospital CFO Report (10/25/24), no fewer than 30 healthcare providers are severing their relationships with one or more MA plans, with another 60 who told Beckers they are seriously considering the same move.

Doctor tears up contract

States Have as Well

A sister publication, Becker’s Payer Issues, reported in its October 23 edition that more and more states are issuing fines against MA plans for violations ranging from excessive denied claims to collection of co-pays when none was required.

How Much Longer?

All of this demands a serious question. How much longer will Home Health continue to tolerate abuse by these giant, for-profit payers now that a different path forward has been paved by hospital systems and state regulatory arms? The loudest voice for Home Health to join the “Just Say No” movement over the last few years has been that of Bruce Greenstein, CTO of LHC Group. Following his company’s acquisition by UnitedHealth’s Medicare Advantage division, Optum, his less loud message is to work with MA plans to teach them what Home Health is and what it can do for them.

Statement from Dr. Landers

In his inaugural address to The Alliance last month, new CEO Dr. Steven Landers called for our entire industry and everyone taking a paycheck from it to join him in advocacy. We fully support that call to action, recognizing that no national association can influence lawmakers and CMS regulators without member support, but he was referring to Medicare rules and payment structures. As we know, that includes less than half of Medicare beneficiaries today. Thanks to deceptive TV ads during open enrollment every year, that number will continue to shrink.

Widespread Advocacy

We need to turn at least part of our advocacy focus to the dominant payers, the MA divisions of insurance companies. Read the Beckers report on the 30 healthcare systems that have torn up their MA contracts. Read the companion report about the epidemic of care denials. Yes, it is a David vs. Goliath story, with even the largest organizations in Home Health dwarfed by the size of the payers. As so many hospital systems have shown, however, it is possible to switch from begging for a few more cents per visit to forcing a plan to beg you to take their patients.

It will only work though if everyone does it. We have already lost LHC Group, and Optum is in the final stages of adding Amedisys to their stable. Out of 11,000 HHAs, there is still a chance we have a united voice loud enough to be heard and taken seriously.

Final Thoughts

One of their improper cost-cutting tactics is routine care denial. For example, the Labor Department alleged that UnitedHealth subsidiary UMR denied all urine drug screen claims from August 2015 to August 2018 without determining whether a claim was medically necessary. In my brother’s case, following his wife’s HRA by her MA company, with no additional care offered, he made the tough choice to put her on in-home hospice care. The assessing nurse immediately detected she had a UTI and ordered the appropriate antibiotics. She responded quickly and may be discharged from hospice soon. Hospice care, of course, is paid by traditional Medicare, not Medicare Advantage.

Tim Rowan, Editor Emeritus

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com or contact Tim at Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com

UnitedHealth Study: Is Medicare Advantage Killing Seniors

CMS

by | Oct 25, 2024 | CMS, Editorial, Medicare Advantage, Regulatory

by Tim Rowan, Editor Emeritus

Is Medicare Advantage Killing Us?

Dr. Steve Landers has long been eloquent in his speaking and writing about the importance of Home Health over the years. Though I was already impressed, I gained a new level of respect this week. Simultaneously with his debut as CEO of the new Alliance, Dr. Landers released an article about a recent study on the impact of Medicare Advantage on Medicare beneficiaries.

It is an article that everyone in our healthcare sector should read.

In “Home Health Cuts and Barriers are Life and Death Issues for Medicare Beneficiaries,” Dr. Landers points readers toward a study conducted by Dr. Elan Gada of UnitedHealthcare’s Optum Group. The results are disturbing. That the findings were released by a Medicare Advantage company is surprising.

Yes, Virginia, Home Healthcare Really Does Save Lives

Landers cited the study’s primary finding. “Medicare Advantage beneficiaries in their plan who did not receive needed home health care after hospitalization were 42% more likely to die in the 30 days following a hospital stay than those who received the prescribed care.” If a drug proved to be as effective as post-discharge home healthcare in saving lives, Landers wrote, “it would dominate the news, restricting access would be considered immoral, and health officials would be pushing its adoption.”

Medicare Advantage Enrollees Go Without

There are a number of reasons a hospital discharged patient might not receive home healthcare, including system issues and patient refusal. However, Dr. Gada’s study also discovered that MA customers go without post-discharge home health at a higher rate than traditional Medicare beneficiaries. Traditional Medicare beneficiaries go without in-home care about 25% of the time. Medicare Advantage beneficiaries 38% of the time. Landers notes that this data is a few years old and that the denial rate for MA customers is likely higher today.

Stop the Killing

We know the life-saving impact of post-hospital home healthcare. The question becomes: how does our little corner of the U.S. healthcare system help regulators and payers to know it as well as we do? At this week’s inaugural conference of the National Alliance for Care at Home, at least three education sessions discussed Medicare Advantage. All three offered strategies for negotiating with insurance companies and surviving under their oppressive rate structures and their frequent care denials.

UnitedHealth Group Medicare Advantage Landers

These Are Bandages, Not Cures

In previous opinion pieces, I have quoted revelations in government lawsuits against MA divisions of insurance companies. These prove the program that was originally launched to extend the lifespan of the Medicare Trust Fund actually costs CMS 118 percent of what traditional Medicare costs. At the same time, insurance company reports to shareholders proudly point out that their MA division is their most profitable.

One of last week’s most read stories was the report from UnitedHealth Group on their astounding Q3 growth.

In the Long Run

Learning to cope with MA care denials and below-cost visit payments is fine for those focused on making next month’s payroll. An entirely different tactic is needed for those focused on the care needs of their elderly parents or who are approaching age 65 themselves. The question must be asked, “Why does Medicare Advantage exist?”

Medicare Advantage Lobbyists

AHIP is the insurance company lobby. It put extreme pressure on Congress in 2009 when the Affordable Care Act was being written. That pressure resulted in then-President Obama removing a core plank from his bill. Obama struck the public option healthcare insurance plan in order to win enough votes to get the bill to his desk.

More $ Makes More $

That lobbying effort continues today precisely because MA is so profitable. How does it bring in so much cash? One after another, all of the large insurance companies have been caught padding patient assessments, the very fraud Home Health is so often accused of. Their monthly checks are determined by how much care they predict their covered lives will need, and they exaggerate it. Later, when it comes time to treat these same customers, MA plans deny care that would have been covered by traditional Medicare. They book profits at both ends, and they gladly pay the minimal fines when the practice is exposed.

The Reality of Medicare Advantage Fraud

To make each covered life more profitable, MA plans have begun calling customers to offer “free” nurse visits. These are essentially re-assessments where the MA staffer is rewarded for “finding” additional illnesses. This is not theoretical. My brother was offered a $50 gift certificate to CVS if he would allow his wife’s MA plan representative to drop in and chat with her, to “make sure she was getting all the benefits she was entitled to.”

Dr. Steven Landers: Call for Advocacy

In his article and in his speeches this week, Dr. Landers made it quite clear what must be done. EVERY person whose livelihood depends on the Medicare Trust Fund must make their voice heard. Letters and phone calls to Congress, to the Senate, to CMS, and to the Secretary of Health and Human Services, telling them you do not want to happen to your community what happened in Maine. After years of negative profit margins, in a state where MA adoption is at two-thirds, Andwell Health Partners ceased business in a wide swath of the northern regions of the state. Andwell was the only Home Health provider there.

The combined advocacy strength of NAHC and NHPCO is not enough to tip the scales. Your input is crucial.

Here's How it Works:

  1. Your letter explaining the damage coming from shrinking CMS reimbursement and MA care denials will be opened by a Congressional staffer.
  2. The staffer will read only enough of your letter to see its topic and which side of that topic you are on.
  3. No need to be lengthy or eloquent
  4. Put your topic and your position in your first paragraph
  5. The staffer will add a checkmark in the pro or con side of their Home Health ledger.
  6. The Congressperson, Senator, HHS Secretary will see a one-page summary of the numbers.
  7. When the numbers are small, the summary goes into a file
  8. When the numbers are large, the elected or appointed official will pay attention
  9. In rare cases, you may even get a phone call
UnitedHealth Group Advocacy Medicare Advantage

Dr. Landers, in His Own Words

The article Dr. Landers wrote detailing all of these includes wording suggestions for your message in your letter and/or call. For convenience, I have included one paragraph below,* but I urge you to spend three minutes reading the entire inspiring and frightening piece. In person, he explained all this in an emotional appeal. He said he cannot emphasize enough the importance of universal participation in our new organization’s advocacy effort. Based on what we have learned about post-hospital nursing care in the home, your letters and phone calls are a matter of life and death.

Excerpt

*To save lives and avoid unnecessary suffering, Medicare officials must reverse their plans to cut Traditional Medicare home health payments for 2025 and ensure payments are stable after adjusting for the dramatically increased healthcare labor cost inflation experienced over the past 5 years. Additionally, Medicare officials and lawmakers must study and address the possibility of the disproportionate administrative and financial barriers to home health in Medicare Advantage.

We are fortunate to have leaders in Congress like Senator Debbie Stabenow, Senator Susan Collins, Representative Terri Sewell, and Representative Adrian Smith who are working to champion a comprehensive bi-partisan legislative fix. Our leaders in Washington must act swiftly, before the end of the year, to save lives and avoid further destabilizing home health services for Medicare beneficiaries.

# # #

Tim Rowan, Editor Emeritus

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com

An Interview with Dr. Steven Landers, Part 2

Advocacy

by | Oct 25, 2024 | Advocacy, CMS, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Medicare Advantage is Killing Us...Literally

This is part 2 of 2 in the interview with Dr. Steven Landers. You can read part 1 here.

Medicare Advantage article by Dr. Landers

Earlier this week, Dr. Landers published an article in the NAHC Report. The article cited three studies and analyses on the number of enrollees in both Medicare and Medicare Advantage who do not receive the care to which they are entitled. During our recent interview with Dr. Landers, he addressed this article.

Dr. Steven Landers: On the Record

The Rowan Report:

You wanted to address something you recently wrote. Is this the same topic you mentioned the opening session, or is this something else?

Dr. Steven Landers:

No, this is a focused piece on the emerging research that we’re seeing around when people miss out on home health. It’s a life and death issue. I want to be sure that we, as an alliance, I, as a physician, and us, as advocates, that we are conveying that these issues around home health cuts and barriers are potentially deadly. This is not a trivial matter. It’s not an administrative or technical financial issue. It’s about people’s lives.

RR:

The article mentioned a study that said that the numper of people not getting the home care that they’re entitled to is almost double with Medicare Advantage enrollees over traditional Medicare.

Steve:

That was from a study that’s referenced there from a few years ago. The Partnership for Quality Home Health Arcadia Analysis that came out this year actually showed that those trends are worsening. We know that they’re not getting the needed care in Medicare Advantage and traditional Medicare.

In both cases it’s too high, but it’s higher in Medicare Advantage. It’s more common that people don’t get the prescribed care in Medicare Advantage. And we also know that that’s going up in both traditional Medicare and Medicare Advantage. The access has gotten worse because of the Medicare home health policy and because of the way that Medicare Advantage has grown and handled these issues.

Medicare Advantage Landers
Interviewer:

I guess the big giant question is what do we do, especially when margins for both traditional Medicare and Medicare Advantage are so low?

Steve:

One, we’ve got to start improving access to home healthcare. And the way that we do that is we end this march of payment cuts that are being set forward by Medicare. I mean, right now the leaders of Medicare are in their rulemaking process and they have choices to make. They can either do things that reverse this trend and put us on a path to better access or I think continuing these cuts will hurt beneficiaries.

And the other piece is the Medicare advantage front. We need more scrutiny and evaluation and potentially oversight here to make sure Medicare Advantage beneficiaries have access to high quality home healthcare.

“The results of this study demonstrate that among MA members referred to home health after acute hospitalization, those who did not receive home health services experienced higher mortality and lower readmissions than those who received these services.”

Unfulfilled Home Health Referrals Lead to Higher Mortality Among Medicare Advantage Members

Elan Gada, MD, Paul Pangburn, MHA, Chris Sahr, MS, MBA, Chad P. Schaben, MPH, Richard Young, MS

RR:

Where does the problem lie?

Steve:

People don’t get home health when it’s prescribed and mortality rates are substantially higher. There could be [anecdotal] reasons that this is happening. I’ve tried to think of them. I can’t really come up with them when you see it in three different analyses, especially one done within the Medicare Advantage plan. They have great data. It was well thought out and this is serious business and it really should be a kitchen table discussion for families like ‘what’s going here?,’ because obviously home healthcare is a beloved service that families care deeply about.

We’ve seen home care become a presidential campaign issue because it’s good policy and also because the folks running, Vice President Harris, who brought it up, and former President Trump, who chimed in sort of a me too, being enthusiastic about the concept. They’ve got to know that this polls well, that the families care about this stuff.

Editor Emeritus Tim Rowan provides an analysis of the study from UnitedHealth Group here.

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

UnitedHealth Group Sees Q3 Growth

CMS

by | Oct 18, 2024 | CMS, M&A, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

UnitedHealth Group Earnings Show Strong Q3 Revenue Growth

For most of 2024, and even going back into 2023, The Rowan Report has written about UnitedHealth Group and its acquisitions, its over diagnosing patients for financial gain, its dropping of Medicare Advantage plans, and, of course the Change Healthcare cyberattack.

Despite all the negativity, UnitedHealth Group continues to grow. The company’s revenue grew more than 9% over last year’s Q3 numbers. Even after the cyberattack, Optum grew by more than $2 billion. According to UnitedHealth Group CFO John Rex, the growth is due to an increase in both the number and type of care services offered. Optum operates three subsidiaries, OPtum Health, OptumRx, and OptumInsight, with total revenue of $63.9 billion.

CyberAttack did not Impact Earnings

According to the Q3 financial statement, per share earnings of $6.51 include the cyberattack impacts. The annual adjusted net earnings outlook for 2024 is between $27.50 and $27.75, in line with earlier projections. The 2024 net earnings outlook reflects both the selling of South American properties and the impacts from the Chnage Healthcare cyberattack. Net earnings outlook is $15.50 to $15.75 per share.

UnitedHealth Group Earnings

More UnitedHealth Group Acquisitions on the Horizon

UnitedHealth Group CEO Andrew Witty said the company is using a five pillar growth strategy. They will continue to spend money acquiring companies for United Healthcare, value-based care, pharmacy businesses, financial services, and what he called “technology-ed opportunities.

Meanwhile...

While UnitedHealth Group and Optum post higher revenue and cash flow and their shareholders se an increase in per share earnings, subscribers to UnitedHealth insurance plans are losing. Monthly premiums and annual deductibles for Medicare Part B increased from 2023 to 2024. Part B standard premiums are expected to increase by almost 6% in 2025. For seniors with higher income, the adjustment amount will go up to $74 per month, making monthly premiums jump to $259. The base beneficiary premium for Part D also increased in 2024 and will again for 2025.

Keeping it in the Family

Effective September 1, 2024, UnitedHealthcare started requiring prior authorization for Medicare Advantage member to receive PT, OT, and ST services when performed outside of the home. Not surprisingly, United Health owns multiple practices that offer PT, OT, and ST at home. Those services don’t require prior authorization. UnitedHealth Group is enjoying higher revenue, higher net income, and is funneling the money from insurance premiums back into its own pocket.

Go for the Gold

This announcement came just after UHC announced a gold card program to reduce prior authorization requirements. The gold card program started October 1st and was supposed to reduce the prior authorization request volume for provider groups. Providers groups who are in-network, have a minimum number of prior authorizations for two years, and have at least a 92% approval rate qualify for gold status. 

Final Thoughts

Home health agencies are struggling to survive with lower payment rates from Medicare plans and operating in the negative under Medicare Advantage plans. Physician practices, surgery centers, urgent care, and pharmacy benefit managers are operating under UHC for even greater profits. More patients are seeing delays in care due to increased prior authorization requirements, unless the patient is seeing a caregiver owned by UHC. Shareholders are getting increased per share revenues. Perhaps there’s a solution hidden in the math there somewhere.

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Another One Bites the Dust

CMS

by | Sep 20, 2024 | CMS, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Essentia Drops Medicare Advantage

Essentia Health is an integrated health system with locations in Minnesota, North Dakota and Wisconsin. The health system offers 285 different services across more than 1,700 locations. They employ more than 2,700 doctors. Essentia also includes 14 hospitals, emergency care, same-day care for mental health crises, and multiple specialties.

This is all to say that Essentia Health is not a small player. They contract with the largest payers in the industry.

Re-Evaluation

Recently, the health system began re-evaluating its participation in some Medicare Advantage plans. According to the chief medical officer for population health at Essentia, Cathy Cantor, M.D., M.B.A., too often deny or delay care. Cantor said in a statement:

“This was not a decision we made lightly. The frequent denials and associated delays negatively impact our ability to provide the timely and appropriate care our patients deserve. This is the right thing to do for the people we are honored to serve.”

Essentia informed patients that they will no longer be an in-network provider for MA plans through UnitedHealthcare (UHC) or Humana beginning January 1, 2025. The health system claims that UHC and Humana delay and deny approval of care at more than twice the rate of other Medicare Advantage plans.  They are encouraging its patients to choose a different plan during open enrollment that is in-network with Essentia.

UHC Responds

UnitedHealthcare responded to the press release that Essentia issued. According to their statement, the two parties extended their contract just this past July. Negotiations included a number of items on which they agreed to collaborate, but Medicare Advantage was not specified among them.

“Essentia Health didn’t raise concerns regarding its participation in our Medicare Advantage network until last week. We have since met with Essentia on Sept. 9 and are committed to working with the health system to explore solutions with the goal of renewing our relationship. We hope Essentia shares our commitment toward reaching an agreement.”

Essentia Drops Medicare Advantage

Following Suit

Essentia’s departure from Medicare Advantage is just one in a recent mass exodus.

Sanford Health of South Dakota ended its Humana MA participation due to “ongoing challenges and concerns that negatively effect patients including ongoing denials of coverage and delays in accessing care.”

HealthPartners out of Minnesota announced over the summer that “UnitedHealthcare delays and denies approval of payment for MA claims at an exceptionally high rate…up to 10 times higher than other insurers….  After over a year of being unable to persuade UnitedHealthcare to change their practices, we’ve determined that we can no longer participate in the UnitedHealthcare Medicare Advantage network.”

Mercy, the official medical provider of the St. Louis Cardinals, announced its year-end departure from the Anthem Blue Cross Blue Shield network. This includes all Medicare Advantage, ACA marketplace, and managed Medicaid plans. They cited administrative tasks that create a barrier to timely, appropriate patient care. Mercy also complained that Anthem has raised its rates for patients and employers, increased its profits, and still has not raised reimbursement rates to providers. Like Essentia, Mercy is encouraging its patients to consider whether the health care plan they choose during open enrollment will list Mercy as one of its in-network providers.

Final Thoughts

CMS reimbursement rates, Medicare Advantage denials, payment delays, and other interruptions are impeding patient care. As Tim mentions in his editorial this week, we are in an election year and we urge you to research how each party might impact our industry.

If more providers and payors continue to drop Medicare Advantage from their offerings, will we see more patients returning to traditional Medicare plans with an affordable Medicare Supplement or MediGap coverage? One can only hope!

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Medicare Advantage Predatory Marketing

CMS

by | Aug 16, 2024 | CMS, Editorial, Marketing, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

Leading Associations Attempt to Curb Medicare Advantage Marketing Practices that Prey on the Unsuspecting

For some time now, we’ve been reporting on the marketing practices that Medicare Advantage uses to lure new members. And, it’s working, as more than 50% of eligible patients are now on Medicare Advantage plans. From federal lawsuits to fraud, to upcoding, Medicare Advantage has made headlines more often than almost any other topic in the industry in the last few years. A joint move last week by two national associations may bring the issue to a head once and for all.

The National PACE Association (NPA) and LeadingAge wrote to the Centers for Medicare and Medicaid Services (CMS) urging them to employ stricter oversight on Medicare Advantage marketing practices. The letter, dated July 25, 2024, cited the impact of these marketing tactics on adults served by Programs for All-Inclusive Care for the Elderly (PACE). They called the marketing “aggressive and misleading” and called upon CMS to protect PACE beneficiaries from harm.

 One of the selling points in the marketing of Medicare Advantage is the supplemental benefits. Medicare Advantage plans are allocated nearly $64 billion dollars to pay for dental, vision, gym memberships, and other benefits that are not available with traditional Medicare. However, the government has no idea where this money is going, who is using it, and what it’s for. Limited available data suggests that a very low number of Medicare Advantage enrollees are using these supplemental benefits. The rest of the money just sits with the payers at taxpayer expense.

The false promise of cash benefits draw even more of this population away from traditional Medicare and into Medicare Advantage plans. Cash benefits from MA plans are only available to dual eligible members. What they don’t tell you, though, is that if you are dual eligible and you switch from Medicare to Medicare Advantage, you are subject to prior authorization rules, care denials, and smaller networks, meaning you may lose your physician when you switch plans. Some of those cash benefits are restricted to use in particular stores. For example, Aetna restricts the use of cash benefits to stores owned by CVS Health. If there isn’t a CVS Health near you, the cash benefits can’t be used.  

PACE Programs

Programs of All-Inclusive Care for the Elderly (PACE) are typically traditional Medicare and Medicaid joint programs that provide medical and social services in home and community-based care settings. The programs cover prescriptions, dental care, emergency services, home care, meals services, primary care providers, nurses, social workers, and more. The program’s goal is to keep patients at home or in their communities and get the health care they need. There is no out-of-pocket costs to these programs for dual eligible members. Medicare only members have a monthly premium and prescription drug (Part D) premium. There are no additional deductibles or copayments for any service or level of care.

Bait and Switch

The marketing messages from Medicare Advantage are pulling PACE eligible members into dual MA and Medicaid plans, which significantly reduce the level of care, access to care, and continuity of care. The MA/Medicaid programs also have higher out-of-pocket costs to members, despite having no monthly premium. Research shows that Medicare Advantage is targeting healthier individuals who will use the provided benefits less often and that when Medicare Advantage patients become sicker, they switch back to traditional Medicare plans if they can.

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PACE LeadingAge MA ReformThe financial and health implications of uninformed disenrollment from PACE to conventional MA plans are significant. The needs of PACE beneficiaries, most of whom have multiple complex medical conditions, cognitive or functional impairments – or all three – are not comprehensively addressed by MA plans. The loss of PACE services is harmful and, in some cases, can be life-threatening.

Katie Smith Sloan

president and CEO, LeadingAge

Dire Need for Change

In their letter to CMS, NPA and LeadingAge called for the following changes to be made:

  • Require MA plans to explain, clearly and without embellishment, all out-of-pocket costs and network/coverage limitations. using easy to understand terms
  • When a member disenrolls from a PACE program, additional steps should be taken to ensure the disenrollment is voluntary and that the member is fully informed of the differences in coverage before leaving the PACE program.
  • Increased leniency in re-enrolling in PACE programs after leaving a Medicare Advantage program by allowing re-enrollment mid-month.
  • Require MA brokers, when providing comparative benefit information of their current coverage (e.g., PACE) to an alternate MA plan, to also inform them, in plain language, if the new plan does not cover or coordinate their Medicaid benefits; and any benefits the individual would “lose” under the new plan (e.g., transportation to groceries).

Pace LeadingAge MA ReformWe share CMS’ stated desire that people have access to accurate and complete information when they make health care choices. We have numerous examples of vulnerable seniors being induced to enroll in MA plans without being fully-informed of what they are giving up when they enroll.

Shawn Bloom

president and CEO, National PACE Association

The Rowan Report reached out to LeadingAge to see if CMS has responded to their letter.

Updates will be provided when we have them.

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Sources:

https://prospect.org/health/2024-05-30-medicare-advantage-64-billion-supplemental-benefits/

https://leadingage.org/associations-urge-tougher-enforcement-of-anti-predatory-medicare-advantage-marketing-practices/

 

NAHC NHPCO Town Hall

Advocacy

by | Aug 9, 2024 | Advocacy, CMS, Hospice, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

The Alliance

On June 18, 2024, the National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO) announced they had met in Washington D.C. to formally sign an affiliation agreement between the two organizations. After 18 months of meetings, conversations, and compromises, the two groups announced their “Alliance” would be the leading authority of the care at home community.

Bill Dombi Ken Albert Town Hall Alliance

During the opening keynote address at the NAHC Financial Management Conference in July, Bill Dombi, President of NAHC and interim President of The Alliance, and Kenneth Albert, Chair of the Transition Board of Directors overseeing the merger, spoke about the progress they have made.

Albert spoke of the thoughtful consideration the board and members of both organizations have put into this change. They are focusing on the biggest concerns of home health and hospice providers both now and in the future. The unification will create one voice as they advocate for home health and hospice in Washington D.C.

New Leadership

Albert and Dombi shared the stage at the NAHC Financial Management Conference about the ongoing search for a CEO of the new organization. According to Albert, there were some candidates who were very excited about the role, but whom the board did not feel there was a great fit. Contrarily, there were candidates the board eagerly wanted to move forward with who declined to continue the process. According to Dombi, the search has gone outside care at home as they look for the right fit from qualified candidates from multiple industries. Both agreed that they felt the search was close to over and they should have an announcement about the new CEO, and possibly the new name, sometime in August of this year.

New Resources

The conjoined organization promises more than just new leadership. Currently under construction is a new logo and website to encompass both groups. Dombi alluded to new resources for providers, training for quality care, and other tools for the industry. While the organization’s name and leadership are forthcoming, the website is projected to launch sometime in the spring of 2025. 

Operating as One

Since the announcement of the merger last year, and even before the deal was inked, NAHC and NHPCO have already been integrating. Dombi told The Rowan Report in a previous interview that the two groups have already been lobbying together, working on policy together, and integrating the management of the two associations. 

The Last NHPCO Conference and the First Alliance Conference

September, 2024 marks the final standalone event for the NHPCO. The 2024 NHPCO Annual Leadership Conference runs September 16-18, with a pre-conference September 14-15 in Denver, CO. The conference will have on-demand access until December 31, 2024. NAHC members will receive member rates to the NHPCO conference. 

The “2024 Home Care and Hospice Conference and Expo” will be the last conference held solely by NAHC, but we are seeing quite a few hospice companies on the exhibitor list and expect this to be a sneak peek at future conferences. The national conference is scheduled for October 20-24, 2024 in Tampa, Florida. This will also mark the final conference for Bill Dombi as President. Dombi announced earlier this year that he will retire at the end of 2024.

NAHC NHPCO Alliance Town Hall
NAHC NHPCO Alliance Town Hall

Town Hall

With quite a few remaining unanswered questions about the future of the two organizations, NAHC and NHPCO hosted a virtual Town Hall on July 31, 2024. With more than 250 association members from both groups in attendance, Bill Dombi and Ben Marcantonio, interim-CEO for NHPCO, along with Kenneth Albert and Melinda Gruber, Vice Chair of the Transition Board of Directors.

Naming "The Alliance"

Albert mentioned that there has been some success using the term Alliance, but it is not a long term solution. The finalization of the name is awaiting some trademark issues to be ironed out and that announcement, which they had hoped to be able to make in July, is coming soon.

CEO Search Update

Gruber thanked the search committee and recruiting firm for their work on the CEO search. Gruber reiterated that they are nearing the final selection phase and after board approval, an announcement will be made. 

Website

Ben Marcantonio, current interim CEO of NHPCO and future CIO of The Alliance confirmed that the new website will allow access to both legacy websites (the current NAHC and NHPCO websites). The new website will have a preliminary version this fall with a fully completed version next spring.

Members of either organization will have full access to the preliminary version of the website this fall. Currently, members can only access information from their own organization, but Marcantonio stressed that if there is information you need, they can help you access it.

Integration

There are eleven committees working together to integrate the two associations. advocacy, programs, education, and HR are a few of these workgroups that each have two to three high priority goals that will most effectively bring about the integration of the two groups. Work plans are now in place to create significant integration by the end of the calendar year. 

Policy and Advocacy

Bill Dombi presented an updated on the joint policy and advocacy issues The Alliance is undertaking. “What stands out for the immediate term has been how the resources have been employed of the two legacy organizations under the banner of The Alliance, focusing on hospice and palliative care,” Dombi said, “In a matter of weeks we saw significant regulatory and legislative action taking place.”

Hospice

The Hospice Final Rule 2025 has undergone an intense review and indepth analysis by members of both teams. The rule will have “tremendous impact” under the Medicare hospice program.

According to Dombi, the two organizations have come together to jointly fund a research project for the Special Focus Program to understand the impact and targeting. Dombi is hopeful that U.S. Representative Earl Blumenauer’s (D-OR) discussion draft will serve as a stepping stone for Hospice reform.

Home Health

The ongoing battle in Congress against CMS is gaining momentum. Dombi said there is a “tremendous amount of support” in Congress to role back the authority of CMS to institute rate changes and rate cuts under the Patient Driven Groupings Model (PDGM). “We have gained a seat at the table, which really helps,” Dombi said. We are continuing with litigation challenging Medicare’s validity of the regulation which has set all these rate cuts in motion.

Medicaid Home and Community-Based Services

The Final Rule modified in a positive way the 80/20 requirement. “We agree with the intentions of improving the status of direct care workers who positively impact so many lives. But in the absence of additional funding, it’s very very difficult to support this rule,” Dombi said. The modification stepped back from the more “draconian” interpretation, but The Alliance is not yet satisfied with the result. There is talk of a joint lawsuit challenging the validity of that rule.

Private Duty

The Private Duty Home Care world, one of the less regulated in the industry, is gaining a lot of attention from Fair Labor Standards as well as Non-Compete Laws. There is currently a joining of forces around solutions that will help Private Duty in the workforce arena, more specifically the Credit for Caring Act, which is gaining some traction, and would offer some financial support for family members who are paying for home care services directly.

The Alliance Needs You

Bill Dombi’s final statement in the Town Hall meeting centered on advocacy. He called for everyone who was in attendance and every member of both legacy organizations to join the fight. Everyone needs to part of that team of advocacy.

Final Thoughts

There is much more news to come out of these to associations as we near the end of 2024, and still more through the first quarter of 2025. The Rowan Report expects additional announcements to be made at both the NHPCO and NAHC annual conferences and we will be there to update everyone on the progress and statements coming out of those two meetings. 

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

MA Past, Present, and Possible Future: Nothing Good to Report

CMS

by | Jul 26, 2024 | CMS, Editorial, Medicare Advantage, Regulatory

by Tim Rowan, Editor Emeritus

Past

For at least the last five years, every Home Health conference this reporter has attended has featured at least one keynote speaker or expert panelist complaining about sparse and shrinking payments from Medicare Advantage plans. As thousands of seasonal TV ads convince more and more Medicare beneficiaries to enroll in what insurance company executive-turned-whistleblower Wendell Potter called “neither Medicare nor an advantage,” the calls from Home Health executives to turn away MA members, following the lead of many hospitals, have grown louder and more frequent.

Originally designed to extend the lifespan of the Medicare Trust Fund by bringing managed care practices to the federal healthcare program for seniors and disabled, Medicare Advantage has failed to do so. As long ago as 2021, an exposé by Fred Schulte in Kaiser Family Foundation Health News found that MA costs to taxpayers began to explode in 2018 and today equal 119 percent of what traditional Medicare should cost. We looked at more recent studies and found similar reports.

From the Experts

Referencing a study by Richard Kronick, a former federal health policy researcher and a professor at the University of California-San Diego, Schulte said, “his analysis of newly released Medicare Advantage billing data estimates that Medicare overpaid the private health plans by more than $106 billion from 2010 through 2019 because of the way the private plans charge for sicker patients. A third of that overpayment occurred in 2018 and 2019.”

Since Kronick’s 2021 report, more beneficiaries have opted in to Medicare Advantage. So far, just over half have switched from straight Medicare, with or without a supplement, and that number may reach 100 percent if those who profit most from the option have their way.

Present

In recent months, we have investigated and reported on the insurance industry’s practice of exaggerating MA member health conditions and denying care that traditional Medicare would have covered, collecting from both ends of the CMS trough. We have also mentioned several federal and state lawsuits piling up against insurance companies for both of those practices. One of our sources, The Center for Economic and Policy Research, said this in the Executive Summary of its detailed, September 2023 study:

Profiting at the Expense of Seniors: The Financialization of Home Health Care

“The nonpartisan Medicare Payment Advisory Commission (MedPAC) estimates that upcoding by MA plans that make enrollees appear to be sicker than they are costs CMS 106 percent of what traditional Medicare costs; adding in the quality bonus payments brings it to 108 percent. MA plans also enroll healthier Medicare beneficiaries, increasing their operating surplus by another 11 percent, making the payments to MA plans 19 percent higher than the payments to traditional Medicare. 

CMS’s announced goal for traditional Medicare beneficiaries is to move all of them to Accountable Care Organizations, which use the valued-based payment model, or other similar care arrangements, by 2030. CMS’s leading model to accomplish this shift is ACO REACH — a gentler, kinder version of the Trump administration’s backdoor enrollment of traditional Medicare beneficiaries in a capitated payment model.”

The Center for Economic Policy Research

Future

Past Present Future Medicare Advantage

Depending on results in the unpredictable world of politics later this year, CMS may or may not see its shift to value-based ACO models come to fruition. Kaiser News‘ Schulte examined the Heritage Foundation’s “Project 2025,” the conservative think tank’s blueprint for any possible future Republican administration, and found an entire section on the Department of Health and Human Services.

Within its “Mandate for Leadership,” the authors identify Medicare and Medicaid as “the principal drivers of our $31 trillion national debt.” While admitting that Medicare and Medicaid “help many,” the authors assert that the programs “operate as runaway entitlements that stifle medical innovation, encourage fraud, and impede cost containment, in addition to which their fiscal future is in peril.”

Rebuttal

Commenting on the Heritage Foundation’s claim, researcher Sonali Kolhatkar, writing for “OtherWords.org,” counters that this opinion is often used to justify ending social programs, but actual CMS data indicates that per person Medicare spending has plateaued for more than a decade and represents one of the greatest reductions to the federal debt. Even with 10,000 to 11,000 Boomers reaching Medicare eligibility every day, total per beneficiary expenditures have stopped climbing, hovering around $12,000 per year since 2010. Before reaching that 2010 plateau, per beneficiary spending had steadily risen from $2,000 at the program’s 1965 inception.

Medicare Advantage for All

Project 2025 proposes making Medicare Advantage the default enrollment option rather than a choice beneficiaries can opt into. With 100 percent of seniors on MA plans, already historic insurance profits will skyrocket further. But will Medicare beneficiaries benefit as well?

The Center for Economic and Policy Research cites multiple lawsuits that have proven eight of the ten largest MA plans routinely add chronic conditions – some non-existent – to patient assessments at enrollment…or later. We reported recently that UnitedHealth Group, operator of the largest MA plan, recently began sending nurses into homes to search for additional health conditions that would raise company payments from the trust fund. The report we quoted included evidence that these home visit upcodes do not lead to any treatments. The Center added that MA’s “heavily restricted networks damage one’s choice of provider along with introducing dangerous delays and denials of necessary care.”

As we have mentioned before, Medicare Advantage is neither Medicare nor an Advantage.

Medicaid also Attacked

Project 2025 also proposes restrictions on Medicaid eligibility by imposing work requirements. The blueprint sees the program for low-income Americans as a  “cumbersome, complicated, and unaffordable burden on nearly every state.” Their plan includes bringing private insurance companies in to “manage” care.

A June, 2024 report by the Center on Budget and Policy Priorities concluded that the ACA’s expansion of Medicaid helped millions of Americans who would otherwise be uninsured, and that its enabling and encouragement of preventive care actually saved money in state budgets. Last month’s report asserted “the people who gained coverage have grown healthier and more financially secure, while long-standing racial inequities in health outcomes, coverage, and access to care have shrunk.”

Project 2025 authors make no mention of a KFF News report from April 2023 that said most Medicaid-eligible people are already working. Nor does it take into account a Government Accountability Office report to Congress October 2020 and again in 2023 that determined that hourly wages in many large companies are low enough to keep even full-time workers eligible for Medicaid and SNAP. Walmart and McDonalds, to name two, land in the top five in almost every state for having Medicaid-eligible workers.

EVEN THE WALL STREET JOURNAL IS CRITICAL

Under the front page Headline “Medicare paid $50 billion to insurers for untreated ills,” a detailed WSJ investigation highlighted a number of findings, including:

  • “The questionable diagnoses included some for potentially deadly illnesses, such as AIDS, for which patients received no subsequent care, and for conditions people couldn’t possibly have, the analysis showed. Often, neither the patients nor their doctors had any idea.”
  • “Instead of saving taxpayers money, Medicare Advantage has added tens of billions of dollars in costs, researchers and some government officials have said.”
  • “Medicare Advantage has cost the government an extra $591 billion over the past 18 years, compared with what Medicare would have cost without the help of the private plans, according to a March report of the Medicare Payment Advisory Commission, or MedPAC, a nonpartisan agency that advises Congress. Adjusted for inflation, that amounts to $4,300 per U.S. tax filer.”
  • “The Journal reviewed the Medicare data under an agreement with the federal government. The data doesn’t include patients’ names, but covers details of doctor visits, hospital stays, prescriptions and other care.”
People voting

Now it is in the Hands of Voters

Home Health, Hospice, and Home Care owners, management, and workers will be voting in November. Consideration of what four years under a Project 2025-friendly administration will mean to businesses dependent on Medicare and Medicare will weigh heavily on their minds as they enter their polling booths.

# # #

Tim Rowan, Editor Emeritus

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com

BREAKING NEWS: Warren, Cassidy React to Supreme Court Ruling

CMS

by | Jul 26, 2024 | CMS, Medicare Advantage, Regulatory

by Kristin Rowan, Editor

The Background

Senators Warren and Cassidy react to the landmark decision by the Supreme Court in Loper Bright Enterprises v. Raimondo. That decision effectively overturned the Chevron Doctrine, which gave deference to federal agency decisions in interpreting ambiguous statutes. Eliminating the Chevron Deference puts more responsibility on federal agencies to show reason behind their interpretations. Likewise, it requires Congress to be less ambiguous in its wording of statutes. This decision would impact CMS’s ability to create their own definitions of terms when calculating reimbursement rates, implementing rules.

Senator Elizabeth Warren Reacts

Warren Chevron Bill

Senator Elizabeth Warren (D-MA)

Less than one month after the U.S. Supreme Court decided the case that overturned Chevron Deference, Senator Elizabeth Warren (D-MA) introduced a bill in the Senate that would override the Supreme Court’s decision and establish Chevron Deference as law.

“Giant corporations are using far-right, unelected judges to hijack our government and undermine the will of Congress,” Warren said. According to Warren, the pending legislation, “The Stop Corporate Capture Act”, will stop corporate interest groups from using their own interpretations of statutes over the judgment of Congress or expert agencies.

Senator Cory Booker (D-NJ) called the Supreme Court decision “an egregious power grab from the US Supreme Court.”

Warren asserts that the overturning of Chevron Deference would put more power in the hands of industry-backed lobbyists who already have more negotiating power than the general public. This assertion is contrary to the majority opinion from Chief Justice John Roberts, who wrote, “Courts must exercise their independent judgment in deciding whether an agency has acted within its statutory authority.”

Increasing Congressional Authority

In addition to making Chevron Deference law, the Stop Corporate Capture Act would also:

Modernize and Reform the Regulatory Process

    • Streamline the White House’s review period for regulations, creating a 120-day time limit for review.
    • Authorize agencies to reinstate rules that are rescinded by Congress through the Congressional Review Act.
    • Reform agencies’ cost-benefit analysis to emphasize public benefits of a rule, including non-quantifiable benefits like promoting human dignity, securing child safety, and preventing discrimination.

Empower and Expand Public Participation in Rulemaking

    • Create an Office of the Public Advocate to help members of the public participate more effectively in regulatory proceedings.
    • Strengthen agency procedures for notifying the public about pending rulemakings.
    • Provide the public with greater authority to hold agencies accountable for unreasonable delays in completing rules. 
    • Require agencies to respond to citizen petitions for rulemaking that contain 100,000 or more signatures.

Increase Transparency and Protect Independent Expertise in Rulemaking

    • Require all rulemaking participants to disclose industry-funded research or other related conflicts of interest.
    • Require any submitted scientific or other technical research that raises a specified corporate conflict of interest be made available for independent public review. 
    • Bring transparency to the White House regulatory review process by requiring disclosure of changes to draft rules during that process and the source of those changes.
    • Require agency officials to provide justification when the regulatory review process ends with a rule being withdrawn.  
    • Establish financial penalties for corporate special interests that knowingly submit false information during the rulemaking process. 

Senator Bill Cassidy Responds

At the same time that Warren introduced her bill overriding Loper v. Raimondo, Senator Bill Cassidy (R-LA) introduced the “Upholding Standards of Accountability (USA) Act of 2024.” Cassidy’s bill takes the removal of the Chevron Deference further than simply overturning the previous ruling. According to the description, the USA Act imposes additional accountability in agency rulemaking. 

Senator Cassidy is the ranking member of the Senate Health, Education, Labor, and Pensions (HELP) Committee. He stated, “For decades, the executive branch has exploited Chevron deference to increase its power beyond what Congress intended, all while skirting congressional oversight. Now, with Chevron deference overturned, Congress must work to rein in the executive branch and hold it accountable to the people and their elected representatives.”

Cassidy Chevron Bill

Senator Bill Cassidy (R-LA)

Decreasing Agency Authority

The direct impact of the Supreme Court decision is that federal agencies do not get preferential treatment when interpreting a statute. Cassidy’s bill requires the head of any federal agency signing a major rule to testify before the committee of jurisdiction within 30 days of the rule’s publication.

Additionally, the bill would:

    • Require each person nominated to a Senate-confirmed position to testify before the committee of jurisdiction prior to Senate confirmation; 
    • Improve cost-benefit analyses by requiring federal agencies to conduct retrospective reviews of such analyses for major rulemakings within five years of each rule’s effective date; 
    • Clarify that federal agencies are permitted to communicate with Congress at all times regarding proposed rules; and  
    • Require timely, substantive responses to congressional oversight from federal agencies. 

Cassidy Challenges Existing Rules

Immediately after the Loper v Raimondo decision, Sen. Cassidy sent a letter to the U.S. Secretary of Education Miguel Cardona asserting that the Education Department has established rules outside of the authority given to it by Congress. He specifically alluded to the new Title IX rule. Cassidy asked Cardona, “How will the department change its current practice to enforce the laws as Congress writes them, and not to improperly legislate via agency action?”

Given Cassidy’s position in the Senate HELP Committee and his previous statements on medical debt, the multitude of bills he introduced on transparency, accountability, and decreasing authority, this is likely not Cassidy’s last attempt to challenge agency rules.

Likely Outcomes

Senator Warren's Bill

There are ten co-sponsors of Warren’s bill and a long list of endorsing organizations. Despite that, experts say the bill has only a slim chance of passing in an election year in the Senate, where Democrats currently have a narrow majority control. The bill is even less likely to pass in the Republican controlled House of Representatives. 

Senator Cassidy's Bill

Similar to Warren’s bill, Cassidy’s bill has a low likelihood of passing. The Democrat majority in the Senate may dismiss the bill before it ever reaches the house. In 2023, the 118th Congress passed only 34 bills, the lowest number in decades. With only a few months remaining for the Congress, and the focus turning to a new Democratic nominee, passing this, or any other, bill seems improbable.

Final Thoughts

Regardless of your political affiliation, the overturning of the Chevron Deference is good news for home health, hospice, and palliative care. This ruling puts more pressure on CMS to justify its reasoning for certain decisions it has made. Senator Warren’s bill threatens the advantage given to the home health industry related to NAHC’s senate and house bills and pending lawsuits. Senator Cassidy’s bill ensures federal agency oversight and requires CMS to rationalize their decisions and prove budget-neutrality.

We will continue following these and other Chevron Deference related stories.

# # #

Kristin Rowan, Editor
Kristin Rowan, Editor

Kristin Rowan has been working at Healthcare at Home: The Rowan Report since 2008. She has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in event planning, sales, and marketing strategy. She has recently taken on the role of Editor of The Rowan Report and will add her voice to current Home Care topics as well as marketing tips for home care agencies. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Payer or Competitor?

Admin

by | Jul 19, 2024 | Admin, Editorial, Medicare Advantage

by Tim Rowan, Editor Emeritus

UnitedHealth Making Home Health Visits

Payer or Competitor…that is the question. According to a report in the Wall Street Journal, and questioned by the insurance industry’s lobbying arm, AHIP, UnitedHealth Group has increased its revenue from the Medicare Trust Fund by $50 billion by “finding” additional health issues during home visits to its MA customers.

In a July 16 investor call, CEO Andrew Witty said UnitedHealth clinicians made more than 2.5 million home health visits to UnitedHealthcare MA members in 2023. Following these visits to more than 500,000 seniors, UnitedHealth upgraded over 300,000 of them to higher payment levels by uncovering health conditions the individual seniors did not know they had.

The WSJ investigation found that between 2018 and 2021, insurers received $50 billion for diagnoses they added to members’ charts. Many of these diagnoses were “questionable,” according to that investigation.

Questionable Visits

Uncover versus Discover United Health

Though a UnitedHealth spokesperson called the analysis “inaccurate and biased,” former UnitedHealth employees told the Journal home visits are often used to add diagnoses. Clinicians say they use software during visits that offer suggestions as to what illnesses a patient might have.

CEO Witty maintained in the investor call that the practice is good for seniors. “UnitedHealth clinicians discovered more than 3 million gaps in care through home visits in 2023,” he reported, “and 75% of patients receive follow-up care in a clinic within 90 days of a home visit.” 

He added that the United home visit program “helps patients live healthier lives and saves taxpayers money,” concluding. “…Medicare Advantage makes programs and results like this possible.” 

The Journal concluded with the finding that few of these upgraded seniors are ever seen by a physician for their newly discovered health conditions. 

# # #

Tim Rowan, Editor Emeritus

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

Poor Joe is Out of A Job

CMS

by | Jun 27, 2024 | CMS, Medicare Advantage

by Tim Rowan, Editor Emeritus

We have been keeping an eye on the Medicare Advantage business as the number of beneficiaries who switch exceeds fifty percent. In past reports, we have described the federal lawsuits that accuse MA insurance companies of illicitly padding revenues while illegally denying treatments that straight Medicare would have covered. (See MedPAC Exposes More Medicare Advantage Crimes – 3/20/24)

Until now, we haven’t gone into detail about those independent brokers with the continuous TV commercials every November. It turns out, they may be even more dishonest than the insurance companies themselves.

Poor Joe

Perhaps the most famous of these brokers is the one that put Broadway Joe Namath in our living rooms a hundred times a day. The company started life as Health Insurance Innovations, owned by Chicago-based private equity firm Madison Dearborn Partners. After accusations of fraud, the company folded and re-emerged as Benefytt. When the same accusations returned, the owners shut that company down and came back as Blue Lantern Health.

According to Healthcare Uncovered, the firm filed for a state-level bankruptcy equivalent in Delaware last April, called “assignment for the benefit of creditors.” Blue Lantern’s website is down, as are MedicareCoverageHelpline.com and HealthInsurance.com, their signature assets. Nobody answers the 800 number Namath hocked for years.

A History of Fraud

The bankruptcy litigation revealed a database of 7 million seniors who had been bombarded by 17 million phone calls. The bankruptcy was apparently precipitated by the Federal Trade Commission, which forced Benefytt to pay $100 million to the people it had scammed by selling sham Obamacare plans, with checks distributed to victims in March. The Securities and Exchange Commission forced Health Insurance Innovations and the company’s co-founder Gavin Southwell to pay a $12 million settlement. Another close associate of the company, Steven Dorfman, was convicted of wire fraud in February.

Deceptive Practices

Tolerance for the firm’s deceptive advertising scheme ended with changes to the Medicare Advantage rule in 2023 that took effect in 2024. Blue Lantern stated after the fines were imposed that the new rule was critical to the company’s downfall,

Previously, former HHS Security Alex Azar characterized the Namath ads as “real savings, real options” in Medicare Advantage, ignoring the studies showing that the MA program costs the Trust Fund not less but $140 billion more than original Medicare.

Healthcare Uncovered concluded with this observation, “Further rules imposed since then by the Biden administration are putting even more pressure on Medicare Advantage lead generators, also called ‘third-party marketing organizations.’ (TPMOs) Beginning October 1 of this year, CMS will require that TPMOs get express consent from individuals before selling contact information to other marketers and brokers — a key loophole that enabled the growth of Blue Lantern and its predecessors.”

 

Don’t worry about Joe Namath’s retirement income though.
He has already landed a gig hawking hearing aids.

Joe Namath TV ad

# # #

Tim Rowan, Editor Emeritus

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

The Wrong Way to Use AI in Healthcare

Admin

by | May 16, 2024 | Admin, Artificial Intelligence, CMS, Medicare Advantage, Regulatory

by Tim Rowan, Editor Emeritus

Lawsuits are beginning to pile up against insurance companies participating in the Medicare Advantage program. The complaint? The wrong way to use AI in healthcare is with faulty algorithms to approve or deny claims. While AI can be extremely helpful in streamlining administrative tasks — comparing physician notes with Home Health assessments and nursing notes or reading hospital discharge documents — it seems not to be any good at deciding whether to approve or deny care.

The Wrong Way to Use AI in Healthcare Example 1

The Minnesota case, November, 2023, UnitedHealth Group:

    • An elderly couple’s doctor deemed extended care medically necessary
    • UnitedHealth’s MA arm denied that care
    • Following their deaths, the couple’s family sued UnitedHealth, alleging:
      • Straight Medicare would have approved the extended care
      • United uses an AI model developed by NaviHealth called nH Predict to make coverage decisions
      • UnitedHealth Group acquired NaviHealth in 2020 and assigned it to its Optum division
      • nH Predict is known to be so inaccurate, 90% of its denials are overturned when appealed to the ALJ level
      • UnitedHealth Group announced in October, 2023 that its division that deploys nH Predict will longer use the NaviHealth brand name but will refer to that Optum division as “Home & Community Care.”

The family’s complaint stated, “The elderly are prematurely kicked out of care facilities nationwide or forced to deplete family savings to continue receiving necessary medical care, all because [UnitedHealth’s] AI model ‘disagrees’ with their real live doctors’ determinations.”

The Wrong Way to Use AI in Healthcare Example 2

The Class-Action case, December 2023, Humana:

    • A lawsuit was filed on December 12, 2023 in the U.S, District Court for the Western District of Kentucky
    • It was filed by the same Los Angeles law firm that filed the Minnesota case the previous month, Clarkson
    • The suit notes that Louisville-based Humana also uses nH Predict from NaviHealth
    • The plaintiffs claim, “Humana knows that the nH Predict AI Model predictions are highly inaccurate and are not based on patients’ medical needs but continues to use this system to deny patients’ coverage.”
    • The suit says Medicare Advantage patients who are hospitalized for three days usually are eligible to spend as many as 100 days getting follow-up care in a nursing home, but that Humana customers are rarely allowed to stay as long as 14 days.
    • A Humana representative said Humana their own employed physicians see AI recommendations but make final coverage decisions.

What Makes This Possible

According to experts we speak with, there are many ways to use data analytics. The insurance companies named in the lawsuits use predictive decision making. This way of analyzing data compares a patient to millions of others and deduces what treatment plan might be suitable for one patient, based on what was effective for most previous patients. Opponents of this method have called it “data supported guessing.”

A superior analysis method experts are coming to understand  is prescriptive decision making. This is taking all of the available historical and current data surrounding a patient and making a clinical decision specifically designed to that patient’s age, gender, co-morbidities, doctor recommendations, and treatment records.The Power of AI with SmartCare

Until recently, predictive analysis was the preferred method because of its resource efficiency. Examining the data of every individual patient used to be prohibitively labor-intensive, requiring hours of reading hospital records, physician notes, and claims. Today, however, AI tools are able to do that work in seconds, making prescriptive analytics and customized plans of care possible.

Fix May Be in the Works

In a February 6, 2024 memo to all Medicare Advantage Organizations and Medicare-Medicaid Plans, CMS explained the difference between predictive and prescriptive analytics. The memo said these plans may not make coverage determinations based on aggregated data but must look at each individual:

“For Medicare basic benefits, MA organizations must make medical necessity determinations in accordance with all medical necessity determination requirements, outlined at § 422.101(c)1 ; based on the circumstances of each specific individual, including the patient’s medical history, physician recommendations, and clinical notes; and in line with all fully established Traditional Medicare coverage criteria.”

In response to a request for clarification, the CMS memo laid out its rule in specific language:Wrong AI in Healthcare Prescriptive Analytics

An algorithm or software tool can be used to assist MA plans in making coverage determinations, but it is the responsibility of the MA organization to ensure that the algorithm or artificial intelligence complies with all applicable rules for how coverage determinations by MA organizations are made. For example, compliance is required with all of the rules at § 422.101(c) for making a determination of medical necessity, including that the MA organization base the decision on the individual patient’s circumstances, so an algorithm that determines coverage based on a larger data set instead of the individual patient’s medical history, the physician’s recommendations, or clinical notes would not be compliant with § 422.101(c).
(emphasis added)

“Therefore, the algorithm or software tool should only be used to ensure fidelity with the posted internal coverage criteria which has been made public under § 422.101(b)(6)(ii).”

In further responses to questions in the same memo, CMS made it clear MA plans must make the same coverage decision original Medicare would make. The only allowable exception is that plans may use their own criteria when Medicare Parts A and B coverage criteria “are not fully established.”

Knowledge of this CMS directive may give Home Health agencies one more arrow in their quiver when going to battle with powerful, profit-oriented insurance companies over harmful, illogical AI algorithm decisions.

For information on the right way to use AI in healthcare, see our complimentary article in this week’s issue.

 

Tim Rowan, Editor EmeritusTim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

 ©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com

HOPE is on the Way: Part 3

CMS

by | Apr 26, 2024 | CMS, Medicare Advantage, Regulatory

By Beth Noyce, RN, BSJMC, BCHH-C, COQS
CHAP-certified home health & hospice consultant

This is part 3 of the 3 in the series, outlining the discussions and implications in adopting new outcome and process measures for Hospice care. The final segment addresses future process and outcome measures that the board discussed, but did not yet implement. Read Part 1 on Outcome Measures and Part 2 on Process Measures.

The TEP discussed potential future process and outcome measure concepts that Abt Associates presented to the panel as well.

The process measures included:

  • Education for Medication Management
  • Wound Management Addressed in Plan of Care
  • Transfer of Health Information to Subsequent Provider
  • Transfer of Health Information to Patient/Family Caregiver

Hope-based outcome measures were:

  • Patient Preferences Followed throughout Hospice Stay
  • Hospitalization of Persons with Do-Not-Hospitalize Order

Developing education for medication management as a process measure was a popular concept, and the top priority of the recommended measures with the TEP as they “broadly agreed that CMS should develop this measure,” the report says, citing “a significant need for training in medication management for patients and their caregivers.” They recommended that the measure weigh more heavily when care is provided in a home setting than in a facility setting because hospices are unable to control facility training and hiring practices. One panelist commented that including the phrase “during today’s visit” in the measure is important.

Whether CMS should further develop the process measure addressing wound management in the plan of care was less straight-forward, as panelists provided varied feedback. They generally agreed that this measure is important, as having a record of wound management addressed in the plan of care can hold the staff accountable for treating the wounds. But some members recommended measuring wound management with outcome measures rather than process measures. One panelist cited potential problems from patients’ deterioration over time and another noted that the time frame of this measure is important, and encouraged recording the process of getting care in place once a wound is identified.  The panel agreed CMS should carefully define the measure’s specifications.

Because standard practice for most agencies is, when a patient is discharged live, to transfer health information to the subsequent provider and to the patient and family or caregiver, TEP members expressed that the two measures were likely to “top out,” meaning they would almost always be marked “Yes,” making them of no value in differentiating between hospice providers. The group generally discouraged developing these process measures.

The group strongly rejected any merit in developing two outcome measures concerning Patient Preferences Followed Throughout Hospice Stay and Hospitalization of Persons with Do-Not-

Hospitalize Order. The report says “Multiple TEP members described situations in which patients who had preferred not to be hospitalized changed their minds when a crisis occurred. Patients’ preferences and unexpected crises are usually out of the hospice’s control. Although it is still important for hospices to ask patients about their preferences as part of patient-centered care, the TEP did not believe these two items would be practical measures of a hospice’s care quality.”

Dr. McNally expects that Abt. Associates will apply the HQEP TEP’s suggestions to the HOPE tool.

“Oh yeah, they did it,” he says. “Abt would come to a specific meeting with information, data, suggestions, and specific information about how these things would be measured. We’d give feedback. Then they’d come back to the next meeting having incorporated our suggestions,” he explains. “All of us felt very much heard and responded to. It didn’t feel in the least bit perfunctory.”

Whatever specific measures are eventually included in the HOPE tool, Lund Person sees value in its implementation. “Hospice providers have had a woeful lack of outcome measures for hospice patients, which has made the evaluation of quality hospice care based only on process measures and the family’s evaluation of hospice care in the CAHPS® Hospice Survey, she explains. “Implementing HOPE will begin to identify outcome measures that can be compared between providers.”

Lund Person warns of potential challenges as well. “The selection of risk adjustment and stratification must be carefully done to minimize bias and maximize effectiveness of measures,” she says. “In addition, hospice providers have been awaiting the release of the HOPE tool with significant anxiety about content and administrative burden.”

Dr. McNally is confident the HOPE tool will be a healthy change for hospices.

“A lot of my role as a medical director and hospice physician is supporting our nurses,” he says. “They do 95% of the work. I really would like to see this not be burdensome for our hospice nurses. I’m looking forward to seeing what the [HOPE tool] beta testing translates to in our own hospice world.” He added “What I would hope to see is that the tool feels user-friendly to the hospice team, the people who have to use it, and that it also provides useful information to patients and families.”

NAHC’s Wehri says that standardizing processes through the HOPE tool is the key foundational element for the hospice industry. “High quality care is driven by reducing variance through standardized processes, Wehri writes. “Also, CMS will have a better idea of how the type of population a hospice serves impacts some of the clinical care.” This small glimpse into hospice variances that CMS does not currently have could be very helpful in future policy and payment decisions, according to Wehri. “What CMS finds in terms of differences between hospices and their care for patients may be a bit of a surprise to CMS,” she says.  “I hope they are pleasantly surprised with the overall quality of care that is revealed.”

# # #

Beth Noyce provides education, consulting, mentoring, compliance assessments and auditing services to home health and hospice agencies and their clinicians in several states. She also now provides patient and family guidance concerning hospice and home health services. Beth loves teaching and helping others succeed. She also makes available recordings of much of her education for her clients’ convenience.

©2024 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in Healthcare at Home: The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com

CMS News

CMS

by | Oct 11, 2023 | CMS, Medicare Advantage, Regulatory

NOW AVAILABLE IN iQIES – Preview Reports and Star Rating Preview Reports for the January 2024 Refresh

CMS just published updated measure for Home Health Outcome Information Set (Oasis) and all HH QRP claims-based measures. These updated measures are no based on the standard number of quarter.

For additional information, please see the HH Quality Reporting Training webpage and the Home Health Data Submission Deadlines webpage. 

 

©2023 by Rowan Consulting Associates, Inc., Colorado Springs, CO. This article originally appeared in Home Care Technology: The Rowan Report. Click here to subscribe. It may be freely reproduced provided this copyright statement remains intact. editor@homecaretechreport.com

CMS News: New Rule Cracks Down on Medicare Advantage Upcoding

CMS

by | Feb 1, 2023 | CMS, Medicare Advantage, Regulatory

by Tim Rowan, Editor

CMS Rule to Protect Medicare

The U.S. Department of Health and Human Services, through the Centers for Medicare & Medicaid Services, finalized the policies for the Medicare Advantage “Risk Adjustment Data Validation” program, which is CMS’s primary audit and oversight tool of MA program payments.

Under this program, CMS identifies improper risk adjustment payments made to Medicare Advantage Organizations in instances where medical diagnoses submitted for payment were not supported in the beneficiary’s medical record. The commonsense policies finalized in the RADV final rule (CMS-4185-F) will help CMS ensure that people with Medicare are able to access the benefits and services they need, including in Medicare Advantage, while responsibly protecting the fiscal sustainability of Medicare and aligning CMS’s oversight of both Traditional Medicare and MA programs.

In Other Words, Fraud

As required by law, CMS’s payments to MAOs are adjusted based on the health status of enrollees, as determined through medical diagnoses reported by MAOs. Studies and audits done separately by CMS and the HHS Office of Inspector General have shown that Medicare Advantage enrollees’ medical records do not always support the diagnoses reported by MAOs, which leads to billions of dollars in overpayments to plans and increased costs to the Medicare program as well as taxpayers.

No Overpayments Collected Since 2007

“Protecting Medicare is one of my highest responsibilities as Secretary, and this commonsense rule is a critical accountability measure that strengthens the Medicare Advantage program. CMS has a responsibility to recover overpayments across all of its programs, and improper payments made to Medicare Advantage plans are no exception. For years, federal watchdogs and outside experts have identified the Medicare Advantage program as one of the top management and performance challenges facing HHS, and today we are taking long overdue steps to conduct audits and recoup funds. These steps will make Medicare and the Medicare Advantage program stronger.”

Xavier Becerra

Secretary, Department of Health and Human Services

“CMS is committed to protecting people with Medicare and being a responsible steward of taxpayer dollars,” said CMS Administrator Chiquita Brooks-LaSure. “By establishing our approach to RADV audits through this regulation, we are protecting access to Medicare both now and for future generations. We have considered significant stakeholder feedback and developed a balanced approach to ensure appropriate oversight of the Medicare Advantage program that aligns with our oversight of Traditional Medicare.”

The RADV final rule reflects CMS’s consideration of extensive public comments and robust stakeholder engagement after the release of the 2018 Notice of Proposed Rulemaking. The finalized policies will also allow CMS to continue to focus its audits on those MAOs identified as being at the highest risk for improper payments. The RADV final rule can be accessed at the Federal Register.

Pre-Implementation Performance Report

The January 2023 Pre-Implementation Performance Report is now available to download from the Internet Quality Improvement Evaluation System (iQIES).

Instructions on how to access the PIPR are available below and on the Expanded HHVBP Model webpage under “Model Reports.”

Background

To support home health agencies during this first performance year, CMS issued PIPRs in November 2022 and January 2023 to all active HHAs. The PIPR provides HHAs with data on their quality measure performance used in the expanded HHVBP Model, in comparison to HHAs nationally within peer cohorts, in advance of the first Interim Performance Reports (IPRs) in July 2023. The PIPRs do not contain calendar year (CY) 2023 data. The January 2023 PIPR includes a new tab containing preliminary achievement thresholds and benchmarks by volume-based cohort.

Need Help Understanding Your PIPR?

To assist HHAs in understanding the purpose, content, and use of the PIPRs, the HHVBP Technical Assistance Team created an on-demand video and downloadable resource, “Introduction to the Pre-Implementation Performance Report,” available on the Expanded HHVBP Model webpage. The video is also available on the Expanded HHVBP Model YouTube channel.

Additionally, the December 2022 edition of the “Expanded HHVBP Model Frequently Asked Questions” includes questions regarding the PIPR. If you do not see an answer to your specific question, please email the HHVBP Model Help Desk at HHVBPquestions@lewin.com.

If you experience an issue with accessing resources on the Expanded HHVBP Model webpage, first try refreshing the webpage. If that does not work, please try closing and reopening the browser. If you continue to experience issues, please try clearing the cache/cookies—links to instructions are below.

Locating the PIPR in iQIES

  1. Log into iQIES at iqies.cms.gov.
  2. Select the My Reports option from the Reports
  3. From the My Reports page, select the HHA Provider Preview Reports
  4. Select the HHVBP file to view the desired report. To quickly locate the most recently published report, select the down arrow adjacent to the Created Date label at the top of the table. This will order the reports in the folder from newest to oldest.
  5. Select the file name link and the contents of the file will display.

Help Desk Information

Should you experience difficulty locating the HHVBP file or with downloading, please contact the iQIES Help desk staff by email at iQIES@cms.hhs.gov or by phone at (800) 339-9313.

For questions about the content of the expanded HHVBP Model reports, please contact the HHVBP Help Desk staff by email at HHVBPquestions@lewin.com.

*Please include your name, agency name, and the CCN when contacting the help desks.

# # #

Tim Rowan The Rowan Report
Tim Rowan The Rowan Report

Tim Rowan is a 30-year home care technology consultant who co-founded and served as Editor and principal writer of this publication for 25 years. He continues to occasionally contribute news and analysis articles under The Rowan Report’s new ownership. He also continues to work part-time as a Home Care recruiting and retention consultant. More information: RowanResources.com
Tim@RowanResources.com

©2023 by The Rowan Report, Peoria, AZ. All rights reserved. This article originally appeared in The Rowan Report. One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com