by Tim Rowan | Jan 31, 2024 | Clinical, Marketing
by Tim Rowan, Editor Emeritus
Counter-intuitive but true. Over-the-top customer service, intended to delight rather than merely satisfy, creates no more customer loyalty than very good customer service.
Speaking to a crowded room at last week’s Home Care 100, Ian Goddard, of Challenger Performance Optimization, Inc., raised a lot of eyebrows when he presented findings of an extensive research project that surveyed 125,000 customers and 5,000 customer service reps across a range of unrelated industries.
- Lousy customer service discourages return customers.
- Good customer service increases customer loyalty.
- Great service leads to a high level of loyalty, but that is as high as it goes.
Over-the-top, he called it “delight service,” results in the same level of loyalty as great service.
Most people have heard the stories. Anyone who has taken a sales training class know about the Nordstrom’s employee who refunded money to a customer who was dissatisfied with a tire. She had bought the tire at that location when the building housed a tire store, before it was a Nordstrom’s.
Goddard told a similar one about a stuffed giraffe that was left behind at a Ritz-Carlton when the family left for the airport. At bedtime, the giraffe’s poor little owner was distraught. Dad called the hotel and soon began to receive photos of the giraffe “on vacation” but coming home soon. The enthusiastic employee took pictures of the giraffe sunning himself by the pool, having a drink at the cafe, and sleeping in a big comfortable bed. The little guy was at peace and slept well. The father flooded social media, singing the praises of Ritz-Carlton. “I’ll never stay anywhere else,” he proclaimed.
According to the Challenger survey, that enthusiasm does last for a while, but not forever. If that grateful dad’s next vacation is in a city without a Ritz-Carlton, or if there is another upscale hotel with a better price, loyalty takes a back seat. His social media campaign, of course, has a long-lasting ripple effect. Word of mouth today is online, not over the backyard fence.
Effortless Customer Service
The survey discovered that there is, however, one customer service experience that impacts loyalty more than any other, even more than service that delights a customer. “Your customers do not want to talk to you,” Goddard asserted. “The most important experience is the one that requires the least effort on the part of the customer. The customer service rep who acts as your advocate cuts through red tape, solves your problem, and takes steps to avoid you having to call again about the same thing. Advocacy is the characteristic of the rep who creates loyalty. Think of your own customer service experiences. If you have to work, or wait on hold, to get a problem solved or to fix something broken, you come away unhappy, meaning less loyal to the brand, even if your issue is finally resolved.
Out of eight personality types typically found in customer service positions, Goddard said, the “controller” type is the most effective. This is the agent who says, “Hold on, I’m going to take care of this for you,” and then comes back a few minutes later with, “all done, problem solved.”
Avoid the Next Service Issue
Goddard told the story of the customer with a broken vacuum cleaner belt. The service rep recognized the issue and told him, “Your replacement part is already on its way.” When he received two belts instead of one, he called back. She said, “We have learned that some customers have trouble installing the belt and they break it the first time. So, we send two, hoping they will learn what they did the first time and install it correctly with the second part.”
“Thinking forward like this vacuum cleaner company does cost a few extra cents with every replacement, but avoids a far more expensive service rep interaction in the future and cements customer satisfaction,” Goddard explained.
Effortless Service in Home Care
Ryan Iwamoto, owner of 24 Hour Home Care, interpreted this way of thinking about customer loyalty for our industry. Asking, “How do we get effortless experience into our organization?” he partnered with a company called Tethr that listens to and analyzes phone conversations. It then coaches the customer service person on ways to improve effectiveness, think like an advocate, and improve satisfaction. Realizing that his caregivers are much like customers, he uses Tethr for them as well.
From the start of the Tethr implementation to the present, advocacy on all calls increased from 26.3% to 34.1%. Difficult calls decreased from 8.3% to 7.9%. Average call length decreased from 4 minutes, 15 seconds to 3 minutes, 52 seconds. Customer Effortless Score, which was tracked at the company, region, office, and individual level, increased 39 percent. Phone calls tracked came from all customers: clients, caregivers, and referral sources.
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
by Kristin Rowan | Jan 31, 2024 | Admin, CMS, Regulatory
By 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
by Kristin Rowan | Jan 24, 2024 | Clinical, Regulatory, Vendor Watch
The Arizona Healthcare Cost Containment System (AHCCCS American Rescue Plan (ARP) Program has awarded a grant to a collaborative group of care providers, solutions providers, and educators. On January 18th, Arizona home care agency Cypress HomeCare Solutions announced they have been selected at the recipient of this program award along with solutions provider PocketRN and educator Nevvon. As a team, they will implement services that improve client and provider experiences while also creating health system savings.
Last week, we spoke with PocketRN CEO Jenna Morganstern-Gaines. “Nevvon and PocketRN are working with Cypress to implement [the use of] PocketRN by Cypress’s caregivers to study cost of care, experience for clients, families, and the care team, and outcomes,” explained Morganstern-Gaines. She further explained that part of the requirements of the grant is to issue quarterly reports and a final evaluation of the program after one year. They are currently through the first phase of the study, which was to onboard patients, families, and caregivers.
PocketRN is a telehealth platform that engages in “whole person clinical care.” It is a flexible, virtual nursing and clinical service application that wraps clinical care around non-medical care in the home. The use a proactive approach by assigning a virtual nurse to each patient who continues to check in with the patient and the family to provide coaching and assistance and to help coordinate care.
“There’s a real reason we use the phrase ‘nurse you back to health’ and not ‘doctor you back to health’. The person that will help follow through is the nurse and PocketRN provides you a one-to-one relationship with a nurse that will follow through with all of your care providers to ensure that you are ‘nursed’ back to health.”
CEO, PocketRN
We will be following this ongoing study and providing updates from the reports we receive.
Kristin Rowan has been working at The Rowan Report since 2008. She is the owner and Editor-in-chief of The Rowan Report, the industry’s most trusted source for care at home news .She also has a master’s degree in business administration and marketing and runs Girard Marketing Group, a multi-faceted boutique marketing firm specializing in content creation, social media management, and event marketing. Connect with Kristin directly kristin@girardmarketinggroup.com or www.girardmarketinggroup.com
©2025 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
by Tim Rowan | Jan 24, 2024 | CMS, Regulatory
by Tim Rowan, Editor Emeritus
T
he battle for stable Home Health reimbursement rates continues full speed ahead on Capitol Hill, but the advocacy organizations engaged on the front lines of that battle are losing ground. The Partnership for Quality Home Healthcare and the National Association for Home Care and Hospice have deployed weapons from educating Congressional staffers to suing CMS. Those traditional methods appear to be insufficient, as the specter of draconian rate cuts casts a larger and larger shadow.
Missing from the conflict is the only effective weapon, flooding lawmakers with messages from their constituents.
According to Joanne Cunningham, CEO of the Partnership, the time is now to bring that weapon to the front. She told over 600 attendees at this week’s Home Care 100 event in Scottsdale that she and Bill Dombi have done everything they can up to now, adding that the only way to stop $3.5 to $5 billion in Medicare cuts is for every person of voting age whose livelihood depends on Home Health care to call or write their House Member and Senators.
STEP ONE: A "Must-Pass" Bill
“Preserving Access to Home Health Act of 2023,” is a pair of bi-partisan bills introduced into the House and Senate in the summer of 2023. (S.2137/H.R. 5159) They would prevent CMS from making new cuts to the PDGM payment system, both now and in the future, by blocking annual “recalculations” that traditionally use flawed formulae.
The bills would require MedPAC to perform more comprehensive calculations before it makes recommendations to Congress. Currently, the Commission only considers revenue and profit margins from traditional Medicare. They determine that Home Health margins are too high without looking at the small-to-negative margins providers accrue from Medicare Advantage, Medicaid, the VA, and private insurance. Medicare profit margins make it possible for HHAs to care for patients with stingier payers. Reducing those margins too far, which MedPAC recommends every year, would remove access to care for millions of beneficiaries.
STEP TWO: Educating Congress
Ms. Cunningham emphasized that elected officials, as well as bureaucrats who write the regulations to implement the “will of Congress,” have yet to understand the impact in-home care has on overall healthcare spending and access to care. “We have to get bureaucrats to look at our data,” she said. “We know we save the trust fund more than we take from it, and we know that we are turning patients away because we cannot pay enough to attract clinicians in sufficient numbers. We have to educate them all.” She offered a few concrete suggestions.
-
- Data, data, data. The most effective policy argument starts with independent analysis from outside the industry.
- Tell stories. Elected officials and their staffers respond to real-life experiences of people within their districts and states. A group from Inhabit Health, for example, sat Congressional staffers down and told them about individual patients who had been kept out of hospitals and EDs, about great care they had received. They added summaries of their typical patients as well.
- Listen. Staffers will challenge your assertions and ask hard questions. They will help you identify your ‘Achilles Heels.’ See this as helpful preparation for meeting the Member or Senator.
- See them at home. Cunningham underscored the importance of making appointments and meeting with House members and Senators away from DC, for two reasons.
- “A lot of people approach a Member on the way out of a church they both attend. What they don’t realize is that they are one of ten who will do the same thing between the church door and his car, from ten different industries. You just become ‘part of the clutter’ and are quickly forgotten.”
- Back home advocacy is the most important thing you can do; it is even better than going to DC. Their main interest is re-election and they respond to messages from constituents. The purpose of advocacy is to cut through the noise. At home, you can say, “Hey, I know you; you’re my neighbor; listen to me!”
- Repetition is key. When you write a letter, it goes on a list. Staffers count up how many constituents have written about each issue. The best strategy is to make them feel pressure from back home. Marshall all the political pressure you can, but fill it with data.
Ms. Cunningham told about leading a group of Home Health providers from Oregon to meet with Senator Ron Wyden in his home office. To make their case for Home Health reimbursement support, they showed him their books, which proved that MedPAC is wrong about Home Health profit margins. They changed his mind. She said that meeting was so powerful and successful, it has become a model for working with other states.
STEP THREE: Expose Medicare Advantage
The Partnership’s goal is to ensure alignment of the MA home health benefit with traditional Medicare – as all Medicare beneficiaries are all entitled to the same home health benefit, regardless of the payor.
“MedPAC met during the first week of January to discuss Medicare Advantage. The meeting, which included a focus on the methodology of payments, was contentious at times.” Cunningham said. “In its January 12 report to Congress, The Medicare Advantage Program: Status Report, MedPAC forecast that CMS will overpay MA plans as much as $88 billion in 2024, based on prior year behavior.”
Higher coding organizations have a competitive advantage because they receive larger payments for enrolling the same beneficiaries as other organizations, and they can offer more extra benefits and attract new enrollees simply because of their coding efforts
Principal Policy Analyst, MedPAC
MA’s focus on extras such as Silver Sneakers, vision care, and basic dental care, along with low or zero premiums added to the Medicare Part B premium that all beneficiaries pay, are what MA plans emphasize in their annual barrage of TV commercials. Never mentioned on TV or in direct mail brochures are two practices that impact many times more dollars than gym memberships and low premiums. The undeserved $88 billion mentioned in the MedPAC report comes from exaggerating initial assessments of plan enrollees. Payments from Medicare to a plan hinge on patient acuity. When improperly padded, acuity robs the trust fund and pads insurance company profits.
The second downplayed practice is on the care side of the equation. The largest MA plans have often been found to deny procedures that traditional Medicare standards would have covered. When they do pay for care, especially Home Healthcare, they pay rates below traditional Medicare rates, often lower than provider costs. Cunningham concluded her comments with a description of the Partnership’s efforts to bring pressure from MedPAC and the HHS OIG to force MA plans to comply with regulatory requirements. “We are all of one mind regarding MA. I think we are going to see practices change.”
The Partnership for Quality Home Healthcare was established in 2010 to work in partnership with government officials to ensure access to quality home healthcare services for all Americans. Representing community- and hospital-based home healthcare agencies nationwide, the Partnership is dedicated to developing innovative reforms to improve the program integrity, quality, and efficiency of home healthcare for our nation’s seniors.
pqhh.org
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
by Tim Rowan | Jan 24, 2024 | Regulatory
Untitled Document
Analysis by Tim Rowan, Editor Emeritus
P
erennial Home Health enemy MedPAC angered a different group last week by releasing a status report on insurance companies participating in the Medicare Advantage program.1
The report details the way in which giant, for-profit, health insurance companies improperly increase per-customer payments by upcoding their health assessment at enrollment, and then slash costs by denying coverage for healthcare services that traditional Medicare would have honored. MedPAC was also critical of the practice of requiring prior authorizations, backed up by utilization review algorithms that are supposedly intended to “minimize furnishing unnecessary services” but which effectively increase denials for necessary care.
According to the report, MedPAC expects CMS to pay MA plans $88 billion in 2024.
On January 12, a meeting to discuss the report ended in what one reporter politely described as “a kerfuffle.” Other witnesses to the meeting chose to describe it as a shouting match.
“One member, Brian Miller, MD, MPH, of Johns Hopkins University in Baltimore, accused panel leadership of issuing a negative status report on MA plans’ market dominance, saying it had been ‘hijacked for partisan political aims to justify a rate cut to Medicare Advantage plans.’
“Miller said the analysis … ‘appears to be slanted to arrive at a foregone conclusion in order to set up and provide political cover’ just before the Centers for Medicare & Medicaid Services prepares its annual rate notice for MA plans, expected in coming weeks. ‘The chapter reads like attack journalism as opposed to balanced and thoughtful policy research.'”2
Report authors fired back, citing numerous ways MA plans generate higher revenue, including enrolling people who are relatively healthy, known as favorable selection. They then vigorously scan patients’ medical histories and charts to code for health factors that generate higher per-capita payments, known as coding intensity, often spending less on services. Coding intensity is also the difference between a risk score that a beneficiary would receive in an MA plan versus in fee-for-service. Though MA plans skew toward healthier enrollees, MedPAC found that MA risk scores are about 20.1% higher than scores would be for the same beneficiaries had they enrolled in Fee For Service Medicare.
Namath, Walker, Shatner and Brokers
Criticism of MA plan behavior did not only come from MedPAC commissioners and report authors. For example, Lynn Barr, MPH, founder of Caravan Health, which was acquired by CVS Health through its acquisition of Signify Health, exposed what the annual TV ads do not make clear, that their 800 numbers go to brokers, not to any one plan.
“This is not the big, lovely, glowing success that everybody says it is. And we continue to create policies that drive people into these plans. Medicare allows money paid to MA plans to be used for broker commissions as high as “$600 to recruit them, plus $300 a year every year that they stay in the MA plan.
“We have allowed MA to buy the market, and that is why MA is growing. It’s not because the quality’s so great. People don’t love the prior auth, people are leaving their plans a lot. Aside from Medicaid, Medicare is the least profitable payer for doctors. And at the same time, we give all this money to the plans. It’s unconscionable.”
Adding to the “kerfuffle” with a powerful anecdote, Stacie Dusetzina, PhD, of Vanderbilt University Medical Center in Nashville, Tennessee, noted that even cancer patients often have trouble getting necessary care because of the plans’ limited networks. She referenced a January 7 NPR story3 about an MA enrollee who could not get the cancer care he needed from his MA plan, and could not get out of the plan without facing 20% in expensive copays. In all but four states, supplemental plans that could pick up the difference can reject patients with costly conditions.
“When you are 65 and aging into the program,” Dr. Dusetzina summarized, “you are healthy at that time and may not be thinking about your long-term needs. [If you did], it would push you to think harder about the specialty networks that you may or may not have access to when the MA plan is making your healthcare decisions.”
1 A 30-page slide presentation is available to the public at medpac.gov/wp-content/uploads/2023/10/MedPAC-MA-status-report-Jan-2024.pdf. The complete report is available only to MedPAC commissioners. The charts on slides 26 and 27 show how MA plans learned to pad profits in 2018 and increased the practices exponentially since then.
2 Cheryl Clark, MedPage Today January 16, 2024 medpagetoday.com/special-reports/features/108275
3 npr.org/2024/01/07/1223353604/older-americans-say-they-feel-trapped-in-medicare-advantage-plans
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. 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
by Kristin Rowan | Jan 17, 2024 | Admin, Clinical
with Bob Roth, Managing Partner at Cypress HomeCare Solutions
Saving for Long-term Care Starts in High School
What is the primary focus for an 18-year-old? Graduating high school, getting into the college or career training program of their choice, their first apartment, perhaps their first car, and their first adult job are things that come to mind. As the parent of a 20-year-old and a 16-year-old, I can attest to most of these and have encouraged both my kids to plan for them. Of course, the 18-year-olds might tell you they are focusing on spending time with friends, travelling, having fun, “finding” themselves, discovering their passion, and learning how to adult. These are all important as well. I’m sure there are other items you would add to these lists. But, how many of you would put long-term care on that list? How many of you were planning for private pay personal care services when you were 18? I’d guess not many of you.
Bob Roth, Managing Partner at Cypress HomeCare Solutions knows all too well that so many families are ill-prepared for long-term care needs for themselves and their families. In his recent article, “The aging dilemma: Long-term care”, which originally appeared in Jewish News, Roth says we should start planning for long-term care when we graduate high school. Not knowing how to provide and, especially, afford this kind of care is something Bob has seen countless times in his more than 20 years in the industry.
Long-term care can be a critical part of the health care spectrum as we age and long-term care insurance alone in the United States is inadequate. According to Roth, this stark reality prompts a crucial conversation on the state of continuing care here and around the globe. The costs of long-term care are up, the need for quality care threatens economic fallout, and the current models are unsustainable.
According to a recent study from the Joint Center for Housing Studies of Harvard University, most older adults are unable to afford in-home or assisted living care. The number of older adults continues to rise, as does the number of cost-burdened older adults. Cost-burdened older adults pay 30 percent or more of their total household income for housing. When you add in the costs for food, transportation, medicine, etc., there is nothing left for in-home care.1
Neither Bob nor I have answers or solutions to this problem. For many years, we’ve talked about the continuity of care across hospitals, doctors, home health, and home care. (Read our article this week on the patient data exchange network.) Perhaps a trusted exchange framework that includes personal care might one day lead to insurance coverage. In the meantime, we are looking for alternative solutions to the widening gap between people who need in-home care and people who can afford it.
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
Bob Roth is Managing Partner of Cypress HomeCare Solutions. Bob assisted in creating Cypress HomeCare Solutions with his family in 1994. With nearly 36 years of consumer products, health care and technology experience, Bob has successfully brought the depth and breadth of his experience to the home care trade and in doing so, Cypress HomeCare Solutions has been honored to receive a number of awards over the years.
He is a well-respected and knowledgeable member of our community.
1. Harvard (2023) Housing America’s Older Adults Key Facts chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.jchs.harvard.edu/sites/default/files/interactive-item/files/Harvard_JCHS_Housing_Americas_Older_Adults_2023_Key_Facts.pdf
by Rowan Report | Dec 13, 2023 | CMS, Regulatory
From the NAHC Newsroom
Public comments due January 5, 2024
CMS Policy Changes to Medicare C & D. On November 5, 2023, the Centers for Medicare & Medicaid Services (CMS) issued the Contract Year 2025 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications.
Key provisions in the CMS policy changes that are of interest to home health and hospice providers are detailed below.
Behavior Health
CMS aims to improve access to behavioral health care by adding certain behavioral health provider specialties to the MA network adequacy standards as a new facility-specialty type. The new facility-specialty type, ‘‘Outpatient Behavioral Health,’’ can include Marriage and Family Therapists (MFTs), Mental Health Counselors (MHCs), Opioid Treatment Program (OTP) providers, Community Mental Health Centers or other behavioral health and addiction medicine specialists and facilities.
Special Supplemental Benefits for the Chronically Ill (SSBCI)
CMS is proposing regulatory changes that would help ensure that SSBCI items and services offered are appropriate and improve or maintain the health or overall function of chronically ill enrollees. The MA organization must be able to demonstrate through relevant acceptable evidence that an item or service offered as SSBCI has a reasonable expectation of improving or to maintain the health or overall function of a chronically ill. The MA plan must follow its written policies based on objective criteria for determining an enrollee’s eligibility for an SSBCI when making such eligibility determinations. CMS is proposing to require that the MA plan document its denials of SSBCI eligibility rather than its approvals.
CMS will also modify and strengthen the current requirements for the SSBCI disclaimer that MA organizations offering SSBCI must use whenever SSBCI are mentioned. Additionally, CMS proposes to require MA plans to notify enrollees mid-year of the unused supplemental benefits available to them. The notice would list any supplemental benefits not utilized by the beneficiary during the first 6 months of the year.
Guardrails for Agent and Broker Compensation
CMS is proposing to generally prohibit contract terms between MA organizations and agents, brokers or other third party marketing organizations (TPMOs) that may interfere with the agent’s or broker’s ability to objectively assess and recommend the plan that best fits a beneficiary’s health care needs, CMS proposes to set a single compensation rate for all plans; revise the scope of items and services included within agent and broker compensation; and eliminate the regulatory framework which currently allows for separate payment to agents and brokers for administrative services. CMS also intends to make similar changes to the Part D agent broker compensation rules.
Health Equity and Utilization Management (UM)
CMS proposes to require that a member of the UM committee have expertise in health equity and that t the UM committee conduct an annual health equity analysis of the use of prior authorization. The analysis would examine the impact of prior authorization on enrollees with one or more of the following social risk factors (SRFs): receipt of the lowincome subsidy or being dually eligible for Medicare and Medicaid (LIS/DE); or having a disability.
Right To Appeal an MA Plan’s Decision To Terminate Coverage for Non-Hospital Provider Services
Beneficiaries enrolled in Traditional Medicare and MA plans have the right to a fast-track appeal by an Independent Review Entity (IRE) when their covered skilled nursing facility (SNF), home health, or comprehensive outpatient rehabilitation facility (CORF) services are being terminated. Currently, Quality Improvement Organizations (QIO) act as the IRE and conduct these reviews. Under current regulations, MA enrollees do not have the same access to QIO review of a fast-track appeal as Traditional Medicare beneficiaries. CMS proposes to (1) require the QIO, instead of the MA plan, to review untimely fast-track appeals of an MA plan’s decision to terminate services in an HHA, CORF, or SNF; and (2) fully eliminate a provision that requires the forfeiture of an enrollee’s right to appeal a termination of services decision when they leave the facility. These proposals would bring MA regulations in line with the parallel reviews available to beneficiaries in Traditional Medicare and expand the rights of MA beneficiaries to access the fast-track appeals process.
- Dual eligible Special Needs Plans (D-SNP)
- CMS proposes to increase the percentage of dually eligible managed care enrollees who receive Medicare and Medicaid services from the same organization.
- CMS is also proposing to limit out-of-network cost sharing for D–SNP preferred provider organizations (PPOs) for specific services.
Further, CMS is proposing to lower the D–SNP look-alike threshold from 80 percent to 70 percent for plan year 2025 and 60 percent for plan year 2026. This proposal would help address the continued proliferation of MA plans that are serving high percentages of dually eligible individuals without meeting the requirements to be a D–SNP.
The National Association for Home Care and Hospice will continue to analyze the proposed rule, but supports CMS’ aim to protect Medicare beneficiaries by modifying policies and procedures that will improve programs under Part C and Part D.
Public comments are due January 5, 2024.
This article originally appeared at https://nahc.org/cms-proposes-policy-changes-to-medicare-part-c-and-part-d/. All rights reserved.
by Kristin Rowan | Dec 13, 2023 | CMS, Regulatory
by Kristin Rowan, Editor
Last week, MedPAC met for their December meeting to discuss “Assessing payment adequacy and updating payments.” Hospice services and Home health care services were each presented separately to Congress and commissioners are set to review the key indicators and discuss updates to Medicare payment rates for 2024.
The findings presented to Congress gave me whiplash.
Hospice Services
- There is ‘mixed evidence’ on whether hospice reduces Medicare expenditures, but is has important benefits for beneficiaries
- 2021 saw a 6% increase in hospices, mostly in for-profit agencies
- Hospice use rates are down overall, but MedPAC blames the effects of the pandemic on death rates and patterns of care
- Hospice use continues to shift from SNFs to in-home care
- In 2020, 18.6% of hospices exceeded the payment cap
- MedPAC recommends the cap be wage adjusted and reduced by 20%
See the full Hospice Services presentation to Congress here.
Opinion
Of the 18.6% of hospices that exceeded the payment cap in 2020, 17.2% of those were also in the highest bracket of hospice providers with stays longer than 180 days. The payment cap is not enough to cover patients who need hospice care for longer time periods, even though the requirement for hospice care is expected death within 6 months. If hospice is intended to care for a patient for 180 days, shouldn’t the payment cap be equal to 180 days of care? If a hospice provider is caring for a patient for longer, shouldn’t they get paid more?
MedPAC is convinced that lowering the cap would only impact those hospice providers who have the longest stays. However, if those hospices can no longer provide care because the payment cap has been reached, it will fall to other providers to continue care, stretching the already overworked hospice nurses even thinner.
Home Health Care Services
- The Bipartisan Budget Act (BBA) of 2018 prompted CMS to implement PDGM and required MedPAC to review PDGM in its first year of operation
- BBA 2018 changes must be budget neutral
- CMS issued a $2 billion one-time reduction for overages and a 3.925 percent permanent reduction
- The decline in the number of Home Health Agencies continues
- The number of FFS beneficiaries declined, but the per capita use of HHS increased
- The median Medicare margin (profit) for efficient providers is 28.4 percent, but only 14% of HHAs met cost and quality criteria
- The median Medicare margin indicates Medicare payments are too high
Opinion
This makes about as much sense as the new phenomenon “dog math.” 14% of all Home Health Care agencies are considered efficient. On average, those who are efficient have a 28% Medicare profit margin. Among 133 industries reporting gross profit margins across the U.S., a 28% profit margin puts Home Care Agencies at number 104 out of 133, much lower than the average or median profit margins of every other industry.1 The all-payer margin is about 12%, making them the second least profitable industry in the U.S., coming in only slightly higher than auto manufacturers. The smallest HHAs have a profit margin just under 6%. MedPAC’s stance seems to be that if an HHA is making enough money to barely survive, they are making too much money.
See the full Home Health Care Agency presentation to Congress here.
©2023 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Home Care Technology: The Rowan Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com
by Tim Rowan | Dec 6, 2023 | CMS, Regulatory
by Tim Rowan, Editor Emeritus
MA Plans Continue to Exaggerate Patient Conditions for Profit
As we reported in October (More MA Plans Caught Inflating Patient Assessments, 10/11/23), insurance companies operating Medicare Advantage plans routinely pad the patient assessments that set their monthly revenue from the Medicare Trust Fund. Worse, CMS bowed to industry pressure earlier this year and agreed not to extrapolate the amount of the fraudulent payments, as it does with Home Health and Hospice overpayments (Government Lets Health Plans That Ripped Off Medicare Keep the Money, 2/22/23).
Now, we hear that the HHS OIG has totaled its 2023 audits and announced it found over $213 million in padded Medicare Advantage overpayments so far this year. In its latest semiannual report, covering fraudulent patient assessments between April and September, the OIG said it recovered $82.7 million. Total recoveries would have been higher except for that CMS ruling that prevents the agency from extrapolating payments before contract year 2018.
Will SEC Allow Cigna/Humana Marriage?
Early last month, Bloomberg broke the news that Cigna was in talks to sell its Medicare Advantage business to Health Care Service Corporation, the parent company of BCBS in Illinois, Texas, New Mexico, Montana and Oklahoma. Should that sale be approved, it would remove an obstacle to Cigna’s rumored desire to merge with Humana.
Though approval is uncertain — the SEC has squashed more than one similar attempt under both the current and former Presidents — it would create what Axios called “another Titan” that would rival UnitedHealth Group and CVS Health in size. CVS acquired Aetna in 2018. It would also combine two Pharmacy Benefit Managers, giving the new entity control of a third of the market, which would be equal to the market share owned today by CVS.
In 2017, a proposed merger between Cigna and Elevance Health, formerly Anthem, was struck down in court. A proposed merger between Humana and Aetna was also canceled in a federal court the same year. Large, powerful insurers, and the PBMs they own, have come under increased scrutiny from federal regulators.
The Biden administration has already launched a warning shot, indicating it will be scrutinizing private equity acquisitions in health care. In September, the Federal Trade Commission sued private equity firm Welsh, Carson, Anderson & Stowe after it bought up nearly all of the anesthesiology practices in Texas and then, with competition removed, began to jack up prices. FTC chair Lina Khan made it clear the suit was intended to send a message to all consolidation attempts that might harm patients.
United to Change Prior Authorization Policy
According to a November 27 policy update from UnitedHealthcare (UHC), the payer is updating its Home Health prior authorization and concurrent review process for services that are delegated to Home & Community Care, the payer’s home care division.
The updated policy, which are set to take effect January 1, will affect United’s Medicare Advantage and Dual Special Needs plans in 37 states, a UnitedHealthcare news release stated.
In Summary
- Start of care visits still do not require prior authorization.
- Providers must notify Home & Community Care of the initiation of home care services. UHC encourages providing notice within five days after the start of a care visit to help avoid potential payment delays.
- Before the 30th day, providers must request prior authorization for days 30 to 60, by discipline, and provide documentation to Home & Community Care.
- For each subsequent 60-day period, providers must request prior authorization, by discipline, and provide documentation to Home & Community Care during the 56- to 60-day recertification window.
UHC says it will respond to questions about the prior authorization approval process at HHinfo@optum.com
In related news, in its annual investor conference call, the company projected “revenues of $400 billion to $403 billion, net earnings of $26.20 to $26.70 per share and adjusted net earnings of $27.50 to $28.00 per share” for 2024. Cash flows from operations are expected to range from $30 billion to $31 billion.
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 Healthcare at Home: The Rowan Report. homecaretechreport.com One copy may be printed for personal use: further reproduction by permission only. editor@homecaretechreport.com
by Rowan Report | Dec 6, 2023 | Admin, Marketing
By Mary E. Maloney
What can you learn about brands and branding from an iconic company like the Mayo Clinic?
We daresay a lot
In this blog, we are going to first explore the “Mayo magic”—some key ideas about why Mayo Clinic has been named, again in 2023 as it has been so many times before, “among the best of the best” hospitals by U.S. News and World Report and listed as one of the “most trusted healthcare brands” by Beckers Hospital Review.
Then we will discuss the benefits of having a solid corporate brand like Mayo’s.
Finally, we will relate the branding principles established by this iconic corporate brand to why it is worthwhile to have a solid personal brand.
Successful Brands Are Built on Trust
Perhaps the most important lesson to take away from Mayo Clinic is that the best brands are built on trust.
A February 2023 Business Insider article titled, Mayo Clinic CEO: Here’s Why We’ve Been The Leading Brand in Medicine for 100 Years, asks Mayo CEO Dr. John Noseworthy how the clinic built its reputation and manages to stay at the top.’
“I think it all comes down to our core value, which is that the needs of the patient come first,”; Noseworthy says in the piece, “I know that might sound kind of trite in today’s world, but our staff is extraordinarily committed. If you spent a day here, and you grab(bed) anybody at the Mayo Clinic and ask(ed) them, ‘what’s the purpose of your work?’; they would say, ‘to meet the needs of our patients.'”
In other words, patients come to Mayo because they can—and do—trust their needs will be served.
The Best Brands Are Consistent
Based on the Mayo example, the best brands are consistent. In the Business Insider article, Noseworthy explains how the Mayo brand is expressed the same way across the organization.
“In my role, what I hear every day from patients and family members is that the minute they step onto a Mayo campus, whether it’s in Rochester, Minnesota; Scottsdale, Arizona; Florida; or in our large integrated health system, they immediately sense that there’s something different,” he says. “They feel it right from the first person they speak with, and it’s the physicians, it’s the science, it’s the engineers and technologists. It’s that patient focus and a relentless focus on quality. This goes all the way from the heart surgeons down to the cleaning staff.
Iconic Brands Stand for Something Significant
A few years back, a woman I know took her young daughter to Mayo Clinic’s Rochester, Minnesota, location for treatment for epilepsy. Ask her what words came to mind when she thinks about Mayo today, and she’ll say: “research, specialists, world-renowned.”
Top brands know what they stand for—and then they deliver on it. For Mayo, this is serving people first, and especially people experiencing special health concerns.
“Founded more than a century ago by two brothers in the rural Midwest, the Mayo Clinic has built a world-renowned reputation as an exemplary network of clinics and hospitals that has become the preferred destination of patients with difficult-to-treat conditions,” reads the intro to a 2018 Q&A article published in Knowledge at Wharton, a business journal from the Wharton School of the University of Pennsylvania.
“As people live longer and have multiple different chronic diseases, the need for … advanced services will be ever greater,” says Larry Jameson, EVP of the University of Pennsylvania Health System, in the article.
The Benefits of a Strong Niche Brand
Being as famous and respected as Mayo would certainly be nice for any brand. But what are the deeper business benefits of having a strong brand in the home health/home care industry?
Qualtrics suggests that strong brands can capture greater market share, accelerate new patient acquisition through online rates and word-of-mouth marketing, and increase loyalty amongst a highly competitive set.
Here are some specific examples:
- Having a strong brand can help an organization appeal to underserved or growing segments.
- Having a strong brand that truly resonates with consumers can translate to patients promoting your organization through online reviews and social media mentions.
- Having a strong brand can boost communication and help to create moments that matter with those the organization serves.
- Having a strong brand creates “stickiness” and can mitigate employee turnover and improve retention rates. When employees feel like they are connected to an organization that is on-purpose, they are more likely to stay and to influence a healthy work culture.
Applying the Key Principles of Iconic Brands to Personal Branding
So how do these ideas we’ve garnered from an iconic brand translate into your personal brand?
As we have seen, consistently delivering on a brand promise helps people decide to do business with a brand. They trust that brand to deliver for them. At the end of the day, people do business with people if they have a choice.
Personal branding can help you excavate your very own brand manifesto and develop ways to tell others about it consistently and authentically. Being mindful of personal branding will help you answer mission-critical questions as: “What is my brand promise?” and “How consistently am I delivering on it?”‘
Personal branding can not only help you as a leader clarify what you stand for but also affirm it until you feel it with conviction. And it can help you to effectively deliver the same message about it in any situation—whether that’s the proverbial elevator, in an all-staff meeting, or in the field.
Imagine what your business would be like when everyone, whether it’s in the first 90 days or tenured staff, “owns” what they stand for and it aligns fully with your company core values.
You as a leader can
Knowing your “why” will also give you peace of mind to pursue your next act if you are in transition (on deck). Having a brand manifesto as your true north guide will enable you to more rapidly achieve your next career milestone and build your best exit strategy.
Once you get clarity, conviction and the ability to talk about your personal brand, maybe you’ll find yourself ranking on the Home Care Pulse 2023 Best of Home Care Awards or as part of the Modern Healthcare Hall of Fame.
Finally, a heartfelt thanks to all the healthcare leaders out there who are leading with purpose, no matter how tough it gets. It speaks volumes about your personal brand. You inspire us.
# # #
An executive advisor, educator, speaker and author, Mary E. Maloney is the founder of Revealing Genius and the expert that accomplished leaders trust for positioning, messaging and brand strategy. A former CEO and CMO, Maloney guides healthcare C-suite leaders, founders and physicians to powerfully and strategically message their expertise and “why” so they lead with conviction and achieve their most coveted career goals.
©2023 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@homecaretechreport.com
