BREAKING NEWS – CMS Proposed Rule for 2025
CMS by Kristin Rowan, Editor CMS Proposed Rule for 2025 Citing “budget neutrality adjustments”, the Centers for Medicare & Medicaid Services (CMS) June 26 issued its proposed rule for 2025 for the home health prospective payment system. Here are the...CMMI Terminates Hospice Carve-In Demonstration
RegulatoryFrom the NAHC News Desk,
Late on Monday, March 4, the Center for Medicare and Medicaid Innovation (CMMI) announced it plans to formally end the Value-Based Insurance Design (VBID) Medicare Advantage hospice “carve-in” demonstration on December 31, 2024, and that it will not accept applications to the previously released CY 2025 Request for Applications (RFA) for the hospice component of the Model. In its announcement, CMMI stated that it made the decision to terminate the demo “after carefully considering recent feedback about the increasing operational challenges of the Hospice Benefit Component and limited and decreasing participation among MAOs that may impact a thorough evaluation”. CMMI recently solicited input on the carve-in via a public request for information (RFI).
NAHC was pleased to be able to provide detailed comments to the RFI highlighting our members’ ongoing concerns and frustrations with the demonstration and registering our deep skepticism that the model was necessary or appropriate for hospice patients and families. We are pleased to see CMMI has decided to end this particular demo, and we look forward to continuing to work with them to advance innovation in care delivery and payment models for people with serious illness.
Since the carve-in was first announced, NAHC has maintained our strong opposition to the premise that incorporating hospice into the Medicare Advantage was necessary or would lead to positive outcomes. In 2019, NAHC emphasized our “unqualified opposition” to the program when it was first unveiled, and after more details were released in the model’s first request for applications (RFA); We have continued to stress our concerns since model implementation began, working with our hospice members to solicit feedback and translate those experiences into direct advocacy with CMS, CMMI, and members of Congress. As early evaluation data and inputs highlight, the model has been extremely burdensome for both hospices and participating plans, and has had no measurable positive impact on beneficiary or family outcomes, care experiences, or Medicare spending.
In the announcement about the model’s termination at the end of 2024, CMMI stated that the decision is not a result of the demo “not meeting its goals”, and that the agency will continue its evaluations of the hospice component to assess its overall impact. Over the course of the three years of the model, it was clear to NAHC that the demo was not meeting CMMI’s stated goals to drive greater care continuity and higher quality hospice care for beneficiaries and families. We also questioned the premise that a carve-in would save the Medicare program money in the long run. Contrary to what the VBID evaluators found, the seminal 2023 NORC research demonstrated that hospice utilization in the traditional Medicare program saves billions of dollars a year while delivering high-quality care.
CMS also indicated in their notification that later this year, they will issue additional guidance to ensure that “all obligations of any impacted organization may be met in a timely and reasonable manner so that hospice beneficiaries in the Hospice Benefit Component maintain a coordinated, seamless care experience.” NAHC will be following up directly with CMMI to better understand what may be included in this guidance and when it may be released.
Increasing access to hospice care remains NAHC’s primary policy goal. We are committed to working to improve more timely connection to hospice, reducing the percentage of very short stays that make it difficult to benefit fully from the hospice model, and ensuring every provider is capable of delivering high-quality, person-and-family-centered services. We appreciate our engagement with CMMI on the carve-in over the years, and we welcome the opportunity to collaborate with them on new ways to support seriously and terminally-ill people and their families.
© 2024 NAHC This article was originally published on the NAHC website. All rights reserved.
Is There an Answer to Paying for Palliative and Private Care?
UncategorizedBy Kristin Rowan, Editor
Last month, we published an article in partnership with Bob Roth of Cypress HomeCare Solutions in Scottsdale, AZ about paying for long-term care at home. Since then, I have come across some interesting information as we continue to tackle the issue of paying for care that is not reimbursed by the current Medicare/Medicaid system.
Medicare and Medicare Advantage have set pay rates for home health and hospice care. Home Health Value-Based Purchasing (HHVBP), implemented by CMS, was designed to incentivize agencies by paying more for quality care rather than a higher number of services provided. This is similar to giving advances and pay raises based on performance rather than longevity in a job, which I’m all for. However, the HHVBP overlooked palliative care altogether and neither the fee-for-service model nor the HHVBP model includes supportive (read private duty) care at home. Since these services are not reimbursed, there is no incentive to provide them nor way to get paid for them if the patient cannot pay out-of-pocket.
This causes two problems:
1. Home Health and Hospice Agencies are reluctant to provide unreimbursed care, with good reason, so the overall patient experience is less than ideal, rehospitalization rates increase, star-ratings and scores decrease, bonuses go away, and the agencies make less money than before.
2. Patients can’t get the care they need and want. Palliative care patients may receive Hospice care too early, or they may not receive care at all because they fall between home health and hospice. Patients who need supportive care at home can’t afford it so they either go without, causing increased complications or they rely on friends and family members who burn out under the stress of being a full-time caregiver.
Innovative care strategies can overcome the obstacles faced by agencies and patients alike. There may not yet be a perfect solution, but there are some innovative ideas out there and something has to disrupt the current pay model.
Palliative Care Partners
Medicare Advantage organizations and primary physician groups receive a “cost of care” analysis for the duration of the patient care. The organization takes on the risk of that patient costing more than what the MA plan will pay, but can make more money if patient care costs less than anticipated. Palliative care at home costs less. David Causby, President and CEO of Gentiva, a Hospice organization that operates in 35 states across the U.S. and has an average daily census of 26,000, has implemented a plan of care in cooperation with these organizations in what he calls Advanced Illness Management (AIM) Model for Risk-Based Partnerships. Designed for palliative care, Gentiva creates a plan of care that includes visit frequency and care needs and employs nurse practitioners, care managers, after hours RNs and social workers. The hospital pays Gentiva on a PMPM model with shared savings. The hospital still gets paid the full amount from MA but uses fewer resources, has lower costs, and sees reduced rehospitalizations, saving more than what they pay out. According to Gentiva, this partnership “provides value to contracted organizations by decreasing the overall end-of-life spend on this high-risk patient population.”
Supportive Care at Home Innovations
Supportive Care at Home (Private Duty Home Care, Private Pay, Non-medical home care) is not covered by Medicare, Medicare Advantage, or most health insurance plans. Limited Medicaid grants, VA plans, and long-term health insurance pay for some supportive care at home. Without one of these plans, patients and family members pay out-of-pocket for supportive care at home, averaging $22-$27 per hour with a 4-hour minimum. In some states it can cost up to $50 per hour. At $80 per day, that’s around $20,000 per year.
One software company we recently spoke with is upending the home care model with fee-for-service model that charges by the minute, rather than by the hour, making care more affordable for more people. You can see our product review of Caring on Demand here. By reducing the cost for customers and reducing the time for caregivers, agencies can onboard more customers without hiring more caregivers. The system is being used in facilities where these services are not provided, which allows a caregiver to visit several people in one stop. The agency and the caregiver can see the same income in the same time, spread out across multiple private payers.
Combining Innovation for a Win-Win-Win
I heard about Caring on Demand and spoke with its founder in August of 2023. I spoke with one Home Care agency owner who recently started working with Caring on Demand. “Times have changed,” the agency owner said. With fewer caregivers joining the workforce, increased levels of burnout since 2020, and CMS changes that overlook palliative and non-medical care, maybe there’s another way…
- Partnerships with organizations and physician groups that have Medicare, MA, and traditional health insurance patients, non-medical home care agencies, and palliative care providers.
- Localized groups of patients in limited areas like retirement villages, planned communities, neighborhoods, or small towns.
- Cost sharing and care coordination that includes in-home palliative care visits, supportive care, communication with primary care providers and specialists
- Preventative intercessions to avoid unnecessary ER visits and hospitalizations
- Shorter visits per caregiver with multiple visits to a community each day
- Cost sharing among patients splitting a 4-hour minimum visit among 4-8 patients
- Shared savings from reduced hospital stays, shorter durations of hospice care, and nursing visits that are supplemented by supportive care
Gentiva has experienced some success already in using shared savings as a payment model. Can costs be decreased even more by adding supportive home care to this plan? Is there enough shared savings for three payees instead of two? I don’t have the answers to these questions, but I do believe providers of supportive care and palliative care have been in the background, overlooked by CMS and MedPAC for long enough. If they aren’t going to recognize the positive impact and cost savings of home care and palliative care and include them in the reimbursement model, we may have to do it for them.
We’d love to hear your feedback on this and other innovative ways to combat the crisis of paying for care at home.
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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.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com
NAHC Fights for Advocacy on Capitol Hill
ClinicalBy Kristin Rowan, Editor
The National Association for Home Care and Hospice joined other advocacy groups this month on Capitol Hill to fight against the looming pay cuts from CMS. Some members of Congress joined the fight for “common sense policies” to expand access to care in the home for Americans.
Rep. Adrian Smith (R-NE-3), who spoke at the event, decried moves against home health, saying “there are cuts looming that are not based on reality” and “we want to make sure reimbursement policies are reflective of the actual realities.” Smith is also the representative who introduce the “Homecare for Seniors Act,” H.R. 1795, which would allow the use of Health Savings Accounts (HSAs) to be used for home care.
Rep. Terri Sewell (D-AL-7) has a personal connection to home care and spoke about how her mother cared for her father through a series of strokes he suffered. She expressed strong opinions about payment reductions that could see home health lose as much as $20 billion dollars over the next ten years. Sewell called the idea “frightening” and said, “I am a big fan of making sure that my constituents have access to quality, affordable health care.”
The Medicare program has admitted that home health is not just a bringing of great care and not just a more cost effective way to provide care, but is a service that provides dynamic value. Care in the home has decreased overall costs by $3.2 billion dollars just in the small segment of value-based payment model test cases. Patients who receive care in the home are re-admitted to the hospital 37% less frequently than those who do not and are 43% less likely to die than patients who do not receive care at home. Still, CMS is looking at additional pay cuts which bring the total payment reduction down 13.72% since 2019. The costs of everything else have increased in that time. According to the U.S. Bureau of Labor and Statistics, the average cost of living has increased 22% since 2019. NAHC President Bill Dombi said, “Where we’re headed in 2024 is that half of all home health agencies will be operating in the red with the cuts facing them in the Medicare program. It’s not a recipe for continued access to care.”
Dombi, along with many others, is predicting that 50 percent of agencies will be operating in the red after the next round of payment reductions and that without a reversal of these pay cuts we could see the end of care at home altogether with a collapse of the home health payment system.
The advocacy event on Capitol Hill helped raise awareness of the plight of care at home among some policymakers, but more help and advocacy is needed. Please, take a few minutes to click the link below and tell your members of Congress to support the Preserving Access to Home Health Act of 2023.
# # #

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
- Please GO HERE to tell your members of Congress to support the Preserving Access to Home Health Act of 2023
NAHC Fights for Home Health on Capitol Hill
AdminBy Kristin Rowan, Editor
The National Association for Home Care and Hospice joined other advocacy groups this month on Capitol Hill to fight against the looming pay cuts from CMS. Some members of Congress joined the fight for “common sense policies” to expand access to care in the home for Americans.
Rep. Adrian Smith (R-NE-3), who spoke at the event, decried moves against home health, saying “there are cuts looming that are not based on reality” and “we want to make sure reimbursement policies are reflective of the actual realities.” Smith is also the representative who introduce the “Homecare for Seniors Act,” H.R. 1795, which would allow the use of Health Savings Accounts (HSAs) to be used for home care.
Rep. Terri Sewell (D-AL-7) has a personal connection to home care and spoke about how her mother cared for her father through a series of strokes he suffered. She expressed strong opinions about payment reductions that could see home health lose as much as $20 billion dollars over the next ten years. Sewell called the idea “frightening” and said, “I am a big fan of making sure that my constituents have access to quality, affordable health care.”
The Medicare program has admitted that home health is not just a bringing of great care and not just a more cost effective way to provide care, but is a service that provides dynamic value. Care in the home has decreased overall costs by $3.2 billion dollars just in the small segment of value-based payment model test cases. Patients who receive care in the home are re-admitted to the hospital 37% less frequently than those who do not and are 43% less likely to die than patients who do not receive care at home. Still, CMS is looking at additional pay cuts which bring the total payment reduction down 13.72% since 2019. The costs of everything else have increased in that time. According to the U.S. Bureau of Labor and Statistics, the average cost of living has increased 22% since 2019. NAHC President Bill Dombi said, “Where we’re headed in 2024 is that half of all home health agencies will be operating in the red with the cuts facing them in the Medicare program. It’s not a recipe for continued access to care.”
Dombi, along with many others, is predicting that 50 percent of agencies will be operating in the red after the next round of payment reductions and that without a reversal of these pay cuts we could see the end of care at home altogether with a collapse of the home health payment system.
The advocacy event on Capitol Hill helped raise awareness of the plight of care at home among some policymakers, but more help and advocacy is needed. Please, take a few minutes to click the link below and tell your members of Congress to support the Preserving Access to Home Health Act of 2023.
# # #

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.homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com
Please GO HERE to tell your members of Congress to support the Preserving Access to Home Health Act of 2023


