by Elizabeth E. Hogue, Esq. | Oct 10, 2024 | Admin, Clinical, CMS, Regulatory
This article provides updated information about a discrimination case filed against a home care agency by the EEOC. The Rowan Report published the initial press release and article last year.
by Elizabeth E. Hogue, Esq.
What to do When Patients Don't Want Caregivers of Certain Races or Nationalities
The Equal Employment Opportunity Commission (EEOC) sued ACARE HHC, Inc.; doing business as Four Seasons Licensed Home Health Care Agency in Brooklyn, New York. The EEOC claimed that the Agency removed home health aides from work assignments based on their race and national origin to accommodate clients’ preferences in violation of the Civil Rights Act of 1964 [EEOC v. ACARE HHC d/b/a/ Four Seasons Licensed Home Health Care, 23-cv-5760 (U.S. District Court for the Eastern District of New York)].
This case recently settled, and Four Seasons will pay a whopping $400,000 in monetary relief to affected home health aides! The Agency must also update its internal policies and training processes related to requirements of the Civil Rights Act, stop assigning home health aides based on clients’ racial or nationality preferences, and provide semi-annual reports to the EEOC about any reports or complaints received about discrimination.
Aides Removed from Assignments
According to the EEOC, Four Seasons routinely responded to patients’ preferences by removing African American and Latino home health aides based on clients’ preferences regarding race and national origin. Aides removed from their assignments would be transferred to new assignments, if available, or, if no other assignments were available, would lose their employment altogether. The lawsuit asked for both compensatory and punitive damages, and for an injunction to prevent future discrimination based on race and national origin. The EEOC says that “Making work assignment decisions based on an employee’s race or national origin is against the law, including when these decisions are grounded in preferences of the employer’s clients.”
As many providers know, patients’ preferences for certain types of caregivers are common. Experienced managers have been asked by patients not to provide caregivers who are, for example, “foreign.” Such requests should generally be rejected, especially when they involve discrimination based upon race, national origin, religion, or any other basis commonly used to treat groups of people differently. Legally and ethically, providers should not engage in such practices.
There is one exception to this general rule that occurs when patients ask for caregivers of the same sex as the patient based upon concerns about bodily privacy. It is then acceptable to assign only same-sex caregivers to patients who have made such requests.
In addition to concerns about discrimination, providers must also be concerned about risk management when they honor such requests. Especially in view of increasing staff shortages, limitations on available caregivers may mean that patients’ needs cannot be met by staff members who are acceptable to patients. In view of staffing shortages, the fewer caregivers who are permitted to care for certain patients, the more likely it is that patients’ needs will go unmet. Unmet patient needs are, in turn, likely to significantly enhance the risk associated with providing care to patients.
Perhaps the pressure to honor patients’ requests is at its greatest when patients receive services at home. Patients who will accept any caregiver assigned to them in institutional settings somehow feel that they have the right to decide who may provide services in their homes. On the contrary, with the exception noted above, staff assignments should be made without regard to client preferences for services rendered at home, just as assignments are made in institutional settings.
How should managers respond when patients tell them not to assign any “foreign” nurses to them? First, they should explain that the organization does not discriminate and that to avoid assignments based on cultural or racial background may constitute unlawful discrimination. Then staff should explain that if limitations on caregivers were acceptable, the provider may be unable to render services to the patient at all because they may not have enough staff. The bottom line is that staff will be assigned without regard to patient preferences in order to prevent discrimination and to help ensure quality of care.
Patients’ requests and managers’ responses must be specifically documented in patients’ charts. Documentation that says patients expressed preferences for certain caregivers or rejected certain types of caregivers is too general. Specific requests and responses of management must be documented.
After patients have expressed what may amount to prejudice against certain groups of caregivers, managers must follow up and monitor for inappropriate behavior by patients directed at caregivers who are not preferred. Managers should be alert to the potential for this problem and should follow up with patients and caregivers to help ensure that caregivers are receiving the respect they deserve. Follow-up activities and on-going monitoring should also be specifically documented.
“Employers cannot make job assignment decisions based on a client’s preference for a worker of a particular race or national origin. It is imperative for employers to have policies, training and other safeguards in place that help prevent a client’s prejudices from influencing their employment decisions.”
-EEOC Representative
Caregivers are a scarce commodity. Providers cannot afford to lose or alienate a single caregiver based upon discrimination or inappropriate behavior by patients.
Elizabeth Hogue is an attorney in private practice with extensive experience in health care. She represents clients across the U.S., including professional associations, managed care providers, hospitals, long-term care facilities, home health agencies, durable medical equipment companies, and hospices.
©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
©2024 Elizabeth E. Hogue, Esq. All rights reserved.
No portion of this material may be reproduced in any form without the advance written permission of the author.
by Rowan Report | Apr 26, 2024 | Admin, Clinical, CMS, Regulatory
by Johnathan Eaves, Senior Director of Communications, Axxess
Treating Medicare patients comes with a level of nuance that is important to understand to ensure that organizations remain compliant and patients receive appropriate care. Standards for quality care and payment can sometimes be dictated by Medicare’s payment policies and at other times be decided by the Conditions of Participation. There is an important difference between these two governing principles that providers should understand to ensure compliance.
Care at home industry veteran and Axxess Senior Vice President of Clinical Services Arlene Maxim RN, HCS-C, offered insights into the differences between Medicare’s policy and its Conditions of Participation during a recent webinar.
Explaining the Difference
Maxim pointed out that the differences between policy and the conditional requirements comes down to what can be billed and what are the quality standards for the services provided.
“The Conditions of Participation are dealing primarily with quality, whereas Medicare policy is related to payment,” said Maxim. And while there is a difference, that doesn’t mean both aren’t important and must always be followed.
“If Medicare policies are not followed, you are audited and if you do not have documentation to support those policies, you’re not going to get paid,” said Maxim “Oftentimes, with PDGM, staff members are not getting past that first 30 days. They’re not understanding what they need to do to keep that patient who continues to qualify for services on for longer.”
Maxim says that the problem is often that clinicians do not understand Medicare policy. “Every piece of documentation we submit to the Medicare program for review [needs to be] as pristine as we can possibly get it,” she said.
Assessment and Documentation
Proper assessment and documentation is something Maxim feels is critical in ensuring quality care, meeting Medicare requirements, and receiving payment for services.
“Complete and detailed documentation is going to be the key for agency payment by the Medicare program,” Maxim said.
Maxim pointed out certain services covered under Medicare policy may include observation and assessment, management and evaluation of a care plan, maintenance therapy, teaching and training activities, administration of medications, wound care, ostomy care, rehab nursing, venipuncture, skilled nursing visits, and more.
She also cautioned that agencies need to be prudent with the funds they receive from Medicare, viewing them as a potential “short-term, interest-free loan” until undergoing any audit. Until their documentation is reviewed and approved, there are no guarantees.
“Medicare is an insurance and it’s not free,” said Maxim. “Medicare policy provides us with a list of covered items. If experiencing an audit, and if the documentation is not there to cover the covered service, you’re not in compliance with that Medicare policy and you will not be paid for the services.”
Communicating With Physicians
Maxim further emphasized the importance of frequent contact with physicians, adherence to care plans, and ensuring that care plans are simple with individualized plans and goals that are achievable.
“You want to make sure that you have orders that physicians are actually going to read and to determine that they make sense and they’re going to sign off on them,” said Maxim.
“Keep your plan of care simple.”
# # #
Axxess Home Health, a cloud-based home health software, streamlines operations for every department while improving patient outcomes.
© 2024 Axxess. For reprint permission, please contact The Rowan Report: kristin@therowanreport.com
by Kristin Rowan | Apr 18, 2024 | Caring for the Caregiver, Clinical, Regulatory
In October of 2023, nurse Joyce Grayson went to the home (halfway house) of a released convict. She was later found dead in the basement of the house. In addition to adding focus to home care worker safety, the immediate response to this tragic event was an increase in nurses being afraid to do their jobs. Lawmakers in Connecticut vowed to increase protection for visiting nurses to ensure health care worker safety. The nurses requested additional reporting requirements for assaults while lawmakers suggested requiring an escort for high-risk situations.
Home Care Worker Safety by Law
Connecticut Senator Saud Anwar recognizes the growing segment of people wanting to age at home. “We want people to be able to get treatment at home,” he said. However, he also recognized the need for more information about potentially dangerous homes. He said at-home health care workers should be aware of what they’re walkin into “if there’s a high-risk situation.” Conn. lawmakers introduced Senate Bill One for Session Year 2024. The bill would require agencies to provide patient information, as applicable, including:
- Medical History
- Psychiatric history
- History of violence
- History of substance abuse
- History of domestic abuse,
- Current infections and treatments
- Stability of diagnoses or symptoms over time
- Housing Information
- Other persons in the home
- Name and relationship to patient
- Psychiatric history
- History of violence or domestic violence
- Criminal records
- History of substance abuse
- Location of Service
- Crime rate
- Presence of hazardous materials
- Presence of firearms or other weapons
- Status of location’s fire alarm system
- Presence of any other safety hazards
The bill also included ongoing safety training, safety assessments, and safety checks including:
- A mobile app with patient information
- A GPS enabled wearable device that allows staff to contact law enforcement
The Bill included payment rates to offset the cost of implementing all safety items to ensure cost-neutrality.
Implications for Hospice Agencies
Barbara Pearce, interim CEO of Connecticut Hospice, raised some legitimate concerns over the bill. Pearce warns that the background screenings required are lengthy and would result in many patients not receiving hospice care at all. According to Pearce, Connecticut Hospice “had 300 people die within three days, 200 people within two days, and 100 people within one day of entering home hospice care.” None of these patients would have been cared for if the bill had been in place at the time. Pearce discussed her concerns with Conn. lawmakers, who have since changed their approach.
Senate Bill One "Home Care Worker Safety" Moving Forward
Connecticut lawmakers are opting to exclude hospices from the bill for now. Sen Anwar said they plan to write a hospice-tailored bill “in the future” to ensure safety of hospice workers. Anwar continued, “We will have a plan of action to see what can be done to reduce the risk for hospice care workers too because…we want to make sure they’re safe too.”
The Connecticut 2024 legislative session is scheduled to adjourn on May 8. Senate and House representatives are racing the clock to modify the bill before the session ends.
Implication for Home Health
Few, if any, states have laws for home health worker safety. Alaska and Idaho have strict penalties for violence against health care workers. Wyoming introduced a similar bill in 2013, but it was defeated. Oregon passed a law in 2007 to require hospitals and surgery centers to implement safety strategies. Washington state established a law in 1999 that requires the development and implementation of a work-place violence plan. The law includes home health, hospice, and home care agencies, but does not have the detailed measures included in Connecticut’s bill.
If Senate Bill One passes in Connecticut, it could pave the way for additional state or federal regulations for in-home care safety precautions. Violence in home health, hospice, and home care has increased and steps need to be taken to ensure the safety and well-being of caregivers. Keep an eye out for some upcoming product reviews on mobile apps and hand-held emergency devices that allow home care workers to alert the agency, law enforcement, and/or family members before, during, and after a care visit.
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
by Rowan Report | Apr 18, 2024 | Partner News
HHAeXchange Names Scott Schwartz as Chief Operating Officer, Announces New Senior Vice President of Product
New appointments highlight the company’s commitment to equipping providers, managed care organizations (MCOs), and state Medicaid agencies with solutions that enable more effective homecare
NEW YORK, Feb. 21, 2024 – HHAeXchange, a leading provider of homecare management solutions for providers, managed care organizations (MCOs), and state Medicaid agencies, today announced that Scott Schwartz, formerly Chief Revenue Officer, has been appointed to Chief Operating Officer, and Lori Harrington has joined the team as Senior Vice President of Product.
After serving as Chief Revenue Officer, Senior Vice President, and Vice President of Sales & Marketing at HHAeXchange for nearly seven years, Scott Schwartz will step into a new role as Chief Operating Officer. In his new position, Schwartz will lead implementation, revenue cycle operations, integrations, technical customer care, training, and customer education. Bringing these functions under Schwartz’s leadership will evolve operations to enable more effective services and solutions.
“Over the past seven years, Scott has been integral in establishing HHAeXchange as the leader in homecare software through helping nearly 10,000 homecare provider agencies leverage technology and spearheading our robust Partner Connect program,” said Paul Joiner, Chief Executive Officer at HHAeXchange. “As we work to expand our platform and create better solutions for homecare providers and payers, Scott’s top priority will be driving operational excellence and delivering an improved end-to-end client experience.”
In addition to the appointment of Schwartz as COO, the company has announced Lori Harrington as the new Senior Vice President of Product. With over twenty years of experience in the industry, Harrington brings an extensive healthcare product strategy and management background to the organization. In her most recent role, Harrington served as Vice President of Product Management for Teladoc, where she led product strategy for value-based care initiatives and was instrumental in developing a client innovation hub for strategic health plan clients, creating a streamlined experience for clients based on their emerging needs.
“Lori’s deep understanding of healthcare and her customer-centric approach will be crucial in advancing our product solutions to serve providers and payers better,” said Tim Brewer, Chief Technology Officer at HHAeXchange. “With her vast experience, Lori will play a pivotal role in driving product evolution and execution, improvements to our current products, and delivering solutions that meet the evolving demands of our customers and the homecare industry to ultimately provide better customer satisfaction.”
As aging populations across the country continue to increase and more members express a preference for homecare, these new appointments will advance HHAeXchange’s commitment to setting new industry standards that enable providers, caregivers, payers, and families to deliver the best care in the home.
For more information about HHAeXchange and its executive team, please visit hhaexchange.com/leadership and follow the company on Twitter, LinkedIn and Facebook.
# # #
About HHAeXchange
Founded in 2008, HHAeXchange is the leading technology platform for homecare and self-direction program management. Developed specifically for Medicaid home and community-based services (HCBS), HHAeXchange connects state agencies, managed care organizations, providers, and caregivers through its intuitive web-based platform, enabling unparalleled communication, transparency, efficiency, and compliance. To learn more information, visit hhaexchange.com or follow the company on Twitter, LinkedIn and Facebook.
by Tim Rowan | Apr 4, 2024 | Clinical, Editorial
by Tim Rowan, Editor Emeritus
For as long as I can remember, Home Health and Home Care owners and advocates, including their national and state associations, have struggled to develop concrete data to prove what we all know to be true: In-home care is a great deal for payers, both public and private. Underpaying our sector in a misguided attempt to reduce costs results in paying more in the long run. Buying more in-home care translates into lower overall cost.
This is one part of the story, and we continually search for the proof our sector so desperately needs. But there is another aspect to the Home Health, Home Care advantage that must not be overlooked as we focus on payer finances.
Patient care and safety
One need look no further than our post-acute care neighbor, Skilled Nursing Facilities, to understand how much better off elderly citizens are when in-home caregivers and clinicians enabled them to stay in their own homes and avoid institutionalized care. A new, peer-reviewed study titles “Profits Over Patients” was published in the online collective The Conversation. If unfamiliar, think of it as The Huffington Post for scholars and researchers.
In the exposé, investigators Sean Campbell and Charlene Harrington reveal that for-profit organizations have been infiltrated by Wall Street investors and other venture capitalists, seeking quick turnarounds and handsome profits. Founders and other SNF owners gladly accept generous offers to be acquired or partner with investors who immediately begin to impose cost-cutting measures and maximize profits. The probe, which paired an academic expert with an investigative reporter, discovered a number of startling findings:
“The investigation revealed an industry that places a premium on cost cutting and big profits, with low staffing and poor quality, often to the detriment of patient well-being. Operating under weak and poorly enforced regulations with financially insignificant penalties, the for-profit sector fosters an environment where corners are frequently cut, compromising the quality of care and endangering patient health.”
Campbell and Harrington also looked at the ineffectiveness of state inspectors, who have limited ability to impose meaningful fines for violations. One startling example in the report is that of a Louisville SNF. The care was found to be “abysmal” when Kentucky inspectors filed their survey report.
“Residents wandered the halls in a facility that can house up to 250 people, yelling at each other and stealing blankets. One resident beat a roommate with a stick, causing bruising and skin tears. Another was found in bed with a broken finger and a bloody forehead gash. That person was allowed to roam and enter the beds of other residents. In another ase, there was sexual touching in the dayroom between residents, according to the [surveyor’s] report.
“Meals were served from filthy meal carts on plastic foam trays, and residents struggled to cut their food with dull plastic cutlery. Broken tiles lined showers, and a mysterious black gunk marred the floors.
“Overall, there was a critical lack of training, lack of staff, and lack of supervision.”
The report said state inspectors found 29 deficiencies, including six that put residents in immediate jeopardy of serious harm and three where actual harm was found. The fine imposed was $319,000 — more than 29 times the average for a nursing home. Payments from Medicare and Medicaid were suspended. The investors and owners chalked the fine up to a normal cost of doing business and, five months later, inspectors found six additional deficiencies “of immediate jeopardy,” the highest level.
The parent company of the Kentucky SNF, Infinity Healthcare Management, owns 58 facilities across five states. Since 2021, Infinity has been hit with nearly $10 million in fines, more than 4.5 times the national average.
Cut staff, save money, hide money
The investigation revealed an industry that places a premium on cost cutting and big profits, with low staffing and poor quality, endangering patient health. “Meanwhile,” the authors assert, “owners make the facilities look less profitable by siphoning money from the homes through byzantine networks of interconnected corporation
s. Federal regulators have neglected the problem as each year likely billions of dollars are funneled out of nursing homes through related parties and into owners’ pockets.”
The report points out that problems of this magnitude are found far less often in small, single-location facilities and in national chains and franchises. The sweet sport for abuse seems to be in the mid-range, for-profit organizations that have been taken over by far-away investors. Sadly, 72 percent of the SNF’s in this category are for-profit. “While such chains account for about 39 percent of all facilities, they operate 11 of the 15 most-fined facilities.
Relevance
A frequent message at Home Healthcare conferences in recent years has been the renewed interest in our sector from big money investors. While quick profits and the enticement of early retirement might bring Home Health and Home Care owners to the negotiating table, this exposé may be a reason to take a breath and think it through. Most of you who nurtured your company from startup to attractive acquisition target did so as much out of compassion as entrepreneurship. Would you not wonder, from your perch on the sun deck of a cruise ship, whether your legacy is being dragged in the mud and your patients and employees reduced to a Wall Street cost column?
Read the entire report here.
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 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
by Rowan Report | Mar 28, 2024 | Partner News
Key Findings Include:
- Average 2023 hourly rate for home health aide increased 5.2%
- Hourly per visit nurse rate decreased 1.6% with facility prices mixed
- Washington and New Hampshire most expensive states for home health aides
illumifin’s comprehensive study provides insight which empowers consumers, insurers, and providers by benchmarking the prices of senior care.
WOODBURY, Minn., March 27, 2024 /PRNewswire/ — illumifin, the leading insurance administration and claims solution provider for long term care (LTC) insurance, has just released its 2023 Cost of Care study and comprehensive analysis. Now in its tenth year, this longitudinal study includes national, state and regional costs of various care services, spanning skilled nursing, adult day care, home health care and assisted living facilities.
illumifin’s Cost of Care study gathers tens of thousands of data points from care providers nationwide, with results normalized by the company’s in-house actuarial and data science teams. Insurers and financial services providers rely on this data for both forecasting and stakeholder education as well as informing customers and agents about national and regional cost variations. In addition, care providers benefit from understanding the market rates for services in their area. These insights are also accessible via illumifin’s What Care Costs website, which offers interactive maps and projection tools to sort, rank and evaluate average costs of LTC services across the US.
illumifin’s study found that the average hourly rate for a home health aide in 2023 was $30.62, an increase of 5.2 percent over the prior year. Meanwhile, the average per-visit rate for a registered nurse in 2023 was $147.72, a decrease of 1.6 percent over the prior year, potentially reflecting rates beginning to normalize post pandemic.
The research also shows facility prices were mixed. The average assisted living facility rates increased between 0.6 and 3.8 percent in 2023 depending on room type, reversing course from the pandemic where assisted living facility rates had been trending downward. However, skilled nursing facility rates experienced a small decrease in 2023 between 0.4 and 1.0 percent.
The most expensive states for home health aides were Washington and New Hampshire, whereas Mississippi and Louisiana were the least expensive. Meanwhile, the most expensive assisted living rates were found in New Hampshire and New Jersey, while the lowest assisted living prices were found in Alabama and Oklahoma.
“We are proud to leverage our 30 years of experience in senior care to provide actionable data for insurers, consumers, providers and financial institutions,” said Peter Goldstein, illumifin’s President and CEO. “Our focus remains on customer centric initiatives which assist in managing risk and planning for the future. Our Cost of Care survey has proven valuable to not only to our business partners but providing valuable knowledge to consumers and their families as they navigate the maze of service types when making care decisions.”
The study, interactive tool and data are available for use by insurers, providers and financial services firms. For more information regarding illumifin’s Cost of Care Study, please contact Jennifer Frost via email at jenniferfrost@illumifin.com.
About illumifin
illumifin provides third party administration and technology services to individual and group insurers. The company, launched in 2021, blends insurance industry knowledge, technology leadership and operational execution to prepare insurers for the digital future. illumifin is a diverse, passionate and empowered team of insurance specialists committed to the growth and success of its customers. With illumifin, there’s a brighter future. Visit www.illumifin.com.
Contact: Chris Tofalli
Chris Tofalli Public Relations, LLC
914-834-4334
SOURCE illumifin
by Rowan Report | Mar 28, 2024 | Admin, Clinical, Partner News, Telehealth
CONTACT: Shannon Bishop-Green, SBishopGreen@MessagePartnersPR.com, (860) 305-3197
NEW REPORT FINDS THAT DIGITAL DIABETES MANAGEMENT TOOLS FAIL TO DELIVER MEANINGFUL HEALTH BENEFITS TO PATIENTS WHILE INCREASING SPENDING
Independent evaluation from Peterson Health Technology Institute recommends new directions for digital diabetes solutions
NEW YORK — Peterson Health Technology Institute (PHTI), an independent organization that evaluates healthcare technologies to improve health and lower costs, today released
a new evaluation of digital diabetes management tools. These solutions are used by millions of Americans and have been funded by $58 billion of investment and mergers and acquisitions, yet the evidence shows that the technologies do not deliver meaningful clinical benefits, and result in increased healthcare spending.
The analysis, conducted by a team of health technology assessment experts and informed by clinical advisors, evaluated eight widely used digital tools that people with Type 2 diabetes use to track and manage blood glucose using a noncontinuous glucometer.
The report found that people who use these tools achieve only small reductions in hemoglobin A1c (HbA1c) compared to those who do not, and these reductions are not sufficient or sustained enough to change the trajectory of their health, care, or long-term prognosis, including cardiovascular risks. The solutions also result in increased overall healthcare costs. One promising solution, Virta, supports nutritional ketosis to achieve diabetes remission in patients who follow the rigorous diet modifications.
“When these digital diabetes management tools launched more than a decade ago, they promised to improve health outcomes for people with diabetes and deliver savings to payers. Based on the scientific evidence, these solutions have fallen short, and it is time to move toward the next generation of innovation,” said Caroline Pearson, executive director of PHTI. “Patients with diabetes invest time, energy, and resources in these tools, and they deserve to experience meaningful, positive benefits for their health. The healthcare sector as a whole needs transparent, accurate information about the clinical and economic impact of these digital tools that are taking up precious healthcare dollars.”
PHTI’s rigorous analysis incorporated an evidence-based assessment framework and review of more than 1,100 articles, including 120 submitted to PHTI by companies evaluated in the report. PHTI’s ratings are at the category level, including remote patient monitoring solutions that support providers, and behavior and lifestyle modification solutions that engage users to improve their diet, exercise, and self-management.
HbA1c is the standard form of measurement of glycemic control in diabetics. The studies show that these digital tools deliver small reductions in HbA1c of 0.23 to 0.60 percentage points compared to usual care. These results are generally below industry standards for Minimal Clinically Important Difference (MCID) of 0.50 percentage points. Further, the evidence indicates that this small improvement is not durable because the reduction is not sustained over time.
Additionally, PHTI’s analysis did not find evidence to demonstrate that digital diabetes management tools improve other health factors, including weight loss, body mass index, blood pressure, cholesterol, or other common conditions impacting people with diabetes. The analysis also concluded that, despite the disproportionate impact of diabetes on low-income and racially and ethnically diverse communities, these tools are not currently being deployed in ways that improve health equity.
PHTI’s evaluation further determined that these tools increase net healthcare spending. This is due to the fact that price for the solutions exceeds the associated healthcare cost savings, because the minimal clinical benefit does not enable the patient to avoid other care or treatments. For patients using tools in the remote patient monitoring category, annual spending is projected to increase by $2,002 for commercial insurance patients, by $1,011 for Medicare patients, and by $723 for Medicaid patients, as a result of higher provider payments. For patients using tools in the behavior and lifestyle modification category, annual spending is estimated to increase by $484 for commercial insurance patients, by $513 for Medicare patients, and by $574 for Medicaid patients. For all payers, the increased spending associated with virtual diabetes solutions has a significant impact on total spending given how many people are eligible to use the solutions, including 4.3% of those with commercial insurance, 17.0% of those with Medicare, and 4.8% of those with Medicaid.
In addition to its scientific literature review, PHTI proactively engaged the companies included in the report and provided an opportunity for them to share data and product information. Companies in PHTI’s evaluation include DarioHealth, Glooko, Omada, Perry Health, Teladoc (Livongo), Verily (Onduo), Vida, and Virta. The evaluation considered evidence about which populations stand to benefit the most from using the technology, as well as the durability of clinical impacts given the importance of sustained glucose control to achieve health benefits. The economic analysis modeled expected healthcare savings resulting from improved glycemic control for patients using digital diabetes management solutions who are enrolled in Medicare, Medicaid, and commercial insurance.
PHTI identified two potential bright spots for digital diabetes management tools. Initial data showed that Virta users are much more likely to achieve clinically meaningful benefits in glycemic control, including diabetes remission and the ability to reduce or eliminate their diabetes medications, if they can maintain the rigorous dietary requirements of the intervention. The other area of greater potential is among patients with higher starting HbA1c levels who are newly starting insulin. By engaging these patients at an early critical transition point in their care, digital solutions could have more impact by helping establish good self-management habits among these higher-risk patients.
Category-level ratings are available
here.
In the United States, about one in seven adults—more than 38 million living in the U.S.—has Type 2 diabetes, which is the eighth leading cause of death. At over $400 billion of total healthcare spending annually, diabetes is the most expensive chronic condition to treat and manage. Given the critical role of patient self-management, investment in digital health tools has surged in recent years.
Throughout the assessment process, PHTI worked with a range of independent evaluation partners, clinical advisors, patients with Type 2 diabetes, and other stakeholders. Report contributors and reviewers included:
- Curta: assessed the clinical and economic impact of these technologies using the published ICER-PHTI Assessment Framework for Digital Health Technologies, including the systematic literature review and budget impact assessment
- Charm Economics: identified what technologies cost to deliver, how they work, and their impact on patients and purchasers
- Institute for Clinical and Economic Review (ICER): co-developed the ICER-PHTI Assessment Framework for Digital Health Technologies, and was consulted to review its implementation in this report
- Ami Bhatt, MD, chief innovation officer of the American College of Cardiology
- Richard Milani, MD, chief clinical innovation officer, Sutter Health; former innovation lead at Ochner Health System
- Karen Rheuban, MD, co-founder and director of the University of Virginia Center for Telehealth
“Managing diabetes is complex and essential to future cardiovascular health. Patients will gain agency and drive better clinical benefit if they direct their time and effort towards effective interventions rather than tools that provide marginal or no benefit,” said report contributor Ami Bhatt, MD, chief innovation officer of the American College of Cardiology.
“New diabetes technologies need to be easier to use, by the people who need them most, at lower cost than standard care, and provide real health benefits,” said report contributor Richard Milani, MD, chief clinical innovation officer at Sutter Health. “This evaluation suggests there is room for new innovations that deliver for patients and address worrying increases in healthcare spending.”
The PHTI report provides recommendations and best practices for innovators, providers, and payers. The next generation of diabetes management solutions should aim for clinically meaningful improvements in glycemic control, potentially integrating continuous glucose monitors and new GLP-1 obesity medications. Solutions should also generate sufficient evidence to support broader adoption, and they should prioritize access for populations who need them most. Providers of diabetes care should have clarity about the performance of these digital solutions when recommending them to their patients. Payers, including health plans and employers, should adapt their contracting approach to require transparency about the solution’s usage and benefits within their covered population and to include financial performance guarantees tied to clinical outcomes.
“PHTI is filling an important role in delivering actionable and market-facing information to digital health purchasers about what solutions will make a meaningful impact on health outcomes for members, making them worth investment,” said Peter Long, PhD, executive vice president, Strategy and Health Solutions at Blue Shield of California and a PHTI Advisory Board member. “Having an organization like PHTI cut through the noise of digital health options helps payers make faster and more effective decisions for members so that we can focus on the big work of transforming the healthcare system.”
PHTI has announced that future assessment areas include virtual physical therapy, blood pressure monitoring, and mental health tools.
# # #
About the Peterson Health Technology Institute
The Peterson Health Technology Institute (PHTI) provides independent evaluations of innovative healthcare technologies to improve health and lower costs. Through its rigorous, evidence-based research, PHTI analyzes the clinical benefits and economic impact of digital health solutions, as well as their effects on health equity, privacy, and security. These evaluations inform decisions for providers, patients, payers, and investors, accelerating the adoption of high-value technology in healthcare. PHTI was founded in 2023 by the Peterson Center on Healthcare. For more information, please visit PHTI.com.
by Elizabeth E. Hogue, Esq. | Mar 28, 2024 | Clinical, Regulatory
by Elizabeth E. Hogue, Esq.,
Primary caregivers – often patients’ family members – are crucial players in home care. Without them, it can be impossible to provide home care services and to keep patients in their homes. If patients cannot care for themselves, reliable caregivers are an essential prerequisite for the provision of all types of home care.
Caregivers have a very “hard row to hoe” because caregiving is physically, emotionally, intellectually, and spiritually demanding. Is it possible that enhanced assistance for caregivers can positively impact quality of care? Intuitively, the answer to this question seems to be “yes.” What additional assistance may be helpful and can providers offer it?
Here are some initial ideas for helpful assistance:
- Caregiver support groups
- More intensive education about patients’ clinical conditions, with an emphasis on signs and symptoms of changes in patients’ conditions and what to do about them
- Assistance from volunteers, especially for patients who are chronically ill
The next question is whether providers can offer additional assistance, such as the activities described above. This issue has been addressed by the Office of Inspector General (OIG) of the U.S. Department of Health and Human Services, the primary enforcer of fraud and abuse prohibitions. The OIG has clearly stated that providers may not give patients or potential patients free items or services that cost more than $15.00 at a time or more than $75.00 in aggregate per calendar year.
In Advisory Opinion No. 18-05; issued on June 18, 2018; the OIG also addressed the circumstances under which providers can establish “caregiver centers” that provide or arrange for free or reduced-cost support services to caregivers in local communities. The provider that requested this Advisory Opinion recognized the difficulties faced by primary caregivers and, consequently, established a caregiver Center.
The Center is staffed primarily by volunteers. Private donations fund the Center and none of its costs are shifted to any federal health care program.
The Center either directly or, in collaboration with local nonprofit organizations, provides free and fee-based services to caregivers. Free services include, but are not limited to, access to a resource library, various educational sessions, a short-term equipment lending program, and free on-site respite care during events sponsored by the Center and attended by caregivers. The Center offers or partners with other providers in the community to offer stress reduction workshops, low-cost ride-share programs, and additional respite care.
The provider does not specifically market the Center’s services, but information is available on its website, social media pages, and in brochures. These sources make it clear that every caregiver is eligible to use the Center’s services, regardless of healthcare provider or payor.
Center staff members do not market, promote, or make referrals for any medical items or services that are reimbursable by federal care programs and do not provide any items or services that are reimbursable by federal health care programs. Referrals for services include a comprehensive list of local service providers offering requested services, without recommending any provider over another.
In response to this request, the OIG first stated that the key question is whether these services are likely to influence caregivers to select the provider or items or services reimbursable by the Medicare or State health care programs in the future. The OIG then acknowledged that the services provided have intangible, psychological value to caregivers. Some of the services relieve caregivers of expenses they might otherwise have incurred. The OIG also noted that many of the support services take place on the provider’s premises, which might encourage selection of the provider for future services. The OIG also acknowledged that this arrangement does not fit into any safe harbor or exception under the federal anti-kickback statute.
Nonetheless, the OIG said that it would not impose sanctions on the provider because:
- The services offered at the Center primarily benefit caregivers, not patients.
- The Center’s services are available to all caregivers.
- The provider does not actively market the Center and its services.
- The Center is unlikely to increase costs to federal health care programs.
Caregivers have a tough job and need the support of home care providers. Based on this Advisory Opinion, the OIG has provided guidance about how home care providers of all types can expand their support for caregivers.
©2024 Elizabeth E. Hogue, Esq. All rights reserved.
No portion of this material may be reproduced in any form without the advance written permission of the author.
by Kristin Rowan | Mar 28, 2024 | CMS, Regulatory, Uncategorized
By Kristin Rowan, Editor
Illumifin, an insurance administration and claims solution provider for long term care (LTC) insurance, has released its 2023 Cost of Care study. The longitudinal study is now in its tenth year and includes national, state, and regional costs of services across skilled nursing, adult day care, home health care, and assisted living facilities.
The study found that the average rate for a home health aide in 2023 was $30.62 per hour, a 5.2% increase over 2022. The average per-rate visit for a registered nurse was $147.72, a 1.6% decrease over the prior year. Assisted living facility rates are up .6 – 3.8% nationwide, while skilled nursing facility rates decreased .4 – 1.0%.
The full press release from Illumifin is here.
To access the full study, contact Jennifer Frost by email at jenniferfrost@illumifin.com.
As costs continue to rise, CMS will need to adjust its proposed per-episode base pay cut for FY 2025. We continue to report on the proposed cuts from CMS and MedPAC, who argue home health agencies are being overpaid, even as costs of supplies and hourly pay go up.
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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. www.therowanreport.com One copy may be printed for personal use: further reproduction by permission only. editor@therowanreport.com
by Kristin Rowan | Mar 20, 2024 | CMS, Regulatory
By Kristin Rowan, Editor
In December, 2023, The Medicare Payment Advisory Committee (MedPAC) recommended a 22% payment reduction for hospice providers. This week, they’ve recommended additional cuts once again.
MedPAC has just released the March, 2024 Medicare Payment Policy Report, issued to Congress. The initial statement from MedPAC recognized the long-lasting impact of the COVID-19 pandemic on healthcare providers and the record inflation rates. The commission admits that the pandemic has caused burnout and personal risk to clinicians and other health care workers. The commission also admits that the effects of COVID-19, PHE-related policy changes, and emergency funding made it difficult to interpret the indicators of adequacy in Medicare’s payment rates.
The commission openly states that the fundamental problem with FFS Medicare payments is that providers are paid more when they deliver more services, whether or not those services provide value. The call for additional payment reforms to force providers to coordinate care over time and across care settings and to eliminate what may be necessary services that MedPAC doesn’t deem valuable.
Home Health Agencies
The commission reports the Medicare margins for HHAs at 22.2 percent in 2022. The commission calculates these margins excluding some fixed costs. The margins, according to the commission, indicate that FFS Medicare payments exceed the costs of care. This should incentivize HHAs to take on additional beneficiaries, as the margins are calculating using only costs that diminish by volume.
The commission notes a drop in HHA use in 2022 and lists possible causes including:
- The number of FFS Medicare beneficiaries is lower due to the increased enrollment in Medicare Advantage
- Lower use of inpatient hospital care among FFS beneficiaries
- Hospitalized FFS beneficiaries were less likely to be discharged to home health care (no reason for this was given)
- More FFA beneficiaries are using SNFs after hospitalization (no reason for this was given)
- The staffing shortages reported by HHAs limit the volume of services they can provide
The commission implies that the staffing shortages are not a factor in the decline in HHA usage. The Department of Commerce’s employment data indicates staffing levels that are currently higher than pre-pandemic levels. Even though the data includes HHAs, hospice, private duty, pediatric agencies, and other home care providers, the commission still contends that Medicare HHAs comprise a significant enough share of this group to conclude there is no staffing shortage nationwide.
The commission also reports that the decrease in the number of HHAs nationwide is not a factor in the decline of HHA usage, because most beneficiaries still live in an area with at least on HHA. The commission recognizes that the number of employees and contract laborers is not used to calculate access to care, even though it is a factor. They also admit that an HHA does not need to serve an entire area to be counted as serving the area, and that the capacity to serve additional beneficiaries is not considered.
The report recognizes that preventable readmissions to hospitals is lower among for-profit and free-standing HHAs than for hospital-based care. However, the commission dismisses this data in favor of the all-cause measure of hospitalization, which is much higher for HHAs. This measure covers 60 days and includes all hospitalizations for any cause and includes community-admitted and home health admitted patients. Essentially, MedPAC is assigning a 14.2 percent hospitalization rate to all home health patients, regardless of the cause of hospitalization, whether or not it is deemed preventable, and whether or not it is in any way related to the initial 30-day-period of post acute care.
The average cost of a 30-day period increased by 4 percent in 2022, due to a higher cost per visit. The HHAs are combatting this by reducing the number of in-person visits per 30-day period. Since MedPAC did not track telehealth visits, there is no data on the overall cost per visit, regardless of whether it was in person or remote. HHAs are working within the PDGM model for reimbursement by lowering their overall costs per 30-day period through telehealth visits, remote patient monitoring, and other technologies implemented to increase efficiency in HHAs. MedPAC wants to penalize this by reducing payment rates. This will only serve to push HHAs to further decrease the number of visits, which will impact quality of care, satisfactions rates, and rehospitalization rates.
The commission concludes that because the payments exceed the costs, the benefits of home health care are devalued as a substitute for more costly care options. MedPAC argues that the overpayment since 2000 creates higher expenditures for beneficiaries, but fails to provide data to this effect.
As noted by NAHC, there are flaws in MedPACs calculations as well as in the foundation of their position:
- Exclusions such as taxes, telehealth, and marketing in cost calculations incorrectly inflate the margins
- MedPAC relies heavily on the CMS calculations for budget-neutrality, which NAHC has already refuted as incorrect, bordering illegal formulas
- The data used in these calculations omitted all HHAs that are hospital-based.
NAHC, along with other agencies, will continue to advocate on behalf of HHAs, hospice providers, and other home-based care agencies in front of Congress to ensure these disastrous cuts will not become permanent inclusions in Medicare policy. We will continue to bring you updates as this issue continues to unfold.
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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
