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
by Tim Rowan | Nov 15, 2023 | CMS, Editorial, Regulatory
Dear Friends,
I have some news that may be upsetting. Frankly, that is my intention, to frighten you into action.
In August, a Home Health provider in New York paid an $$866,339.25 fine for violating the “Civil Monetary Penalties Law.”* The Chinese-American Planning Council Home Attendant Program had employed an individual, in connection with the New York State Consumer Directed Personal Assistance Program (CDPAP), who was excluded from participation in the New York Medicaid program and was not eligible to furnish services under the CDPAP.
Georgia provider Agape Hospice Care paid $250,993.97 in penalties, the specific amount it had paid in salary and benefits to two unlicensed nurses.
If this law is unfamiliar to you, it is the requirement that you may not employ any individuals who are not eligible to work within the Medicare system.*
This is only one example of a new OIG crackdown!
- Bridges MN, a non-profit with services to the disabled, was fined $150,171.96 for employing a single excluded individual.
- Vicki Roy Home Health Service paid a $38,000 fine for employing one excluded caregiver.
- Providence Health System-Southern California, doing business as Providence Little Company of Mary Medical Centers, which includes two hospitals, agreed to pay $141,562 in connection with the employment of an excluded emergency services technician from Aug. 8, 2016, to June 5, 2019. (Note that this person was employed for nearly three years without the health system knowing, as they are required to know, that he or she was excluded.)
- Joseph Health Personal Care Services, doing business as Nurse Next Door, agreed to pay $32,244 in connection with the employment of an excluded constant care attendant from Nov. 2, 2017, to Aug. 8, 2019.
My friends, the list goes on and on, and these are just the Home Health agencies:
- Serenity Home Healthcare Services Agreed to Pay $146,000
- Professional Home Health Care 2: $77,000
- Chinese-American Planning Council Home Attendant Program: $866,000
- Visiting Angels of Rhode Island: $158,000
I learned of at least 25 other healthcare providers that were fined under this law. Clearly, the HHS OIG is on the warpath. This is not a regulation you are wise to ignore.
That is why I write you today. I have found an affordable service that performs monthly OIG exclusion screening for you. Doing it yourself would require a dedicated FTE and hours of painstaking work.
I would be honored if you would accept my introduction to the company that provides this service. If the fines I listed above grabbed your attention, you can see that a service of this type is like an insurance policy that costs a fraction of the disaster it can prevent.
The company is called Carosh Compliance Services. The monthly service is called “OIG Express.” I know and trust the founding CEO, Roger Shindell. To contact Roger and learn more about this necessary service, use this link: https://oig.hhs.gov/faqs/exclusions-faq/
Sincerely,
Tim Rowan
Editor Emeritus
The Rowan Report
Tim@RowanResources.com
by Tim Rowan | Nov 15, 2023 | Vendor Watch
by Tim Rowan, Editor Emeritus
In September, we posted the announcement from HHAeXchange about their inking a deal to provide EMR and EVV software to Gentiva Personal Home Care. We had some questions about the partnership and both HHAeXchange president Stephen Vacarro and Gentiva president Richard Bruner took the time to speak with us.
Background and Context
Gentiva Health Services is a provider of Home Health and Hospice services. Headquartered in Atlanta, the company became an independent business unit of Kindred Healthcare in October, 2014. At the time of the acquisition, it had been a Fortune 100 company with over $1.7 billion in annual revenue.
Today, Gentiva provides in-home care to over half a million patients annually through over 420 locations in 40 states.
The Rowan Report: Can you provide an update about Gentiva and your role?
Bruner: Gentiva Health Services is a network of compassionate caregivers, clinicians, support personnel, and information technology teams who provide superior outcomes for patients across the post-acute continuum. Originally part of Olsten Corporation, Gentiva officially became an independent company on Aug. 6, 1999. Our services include personal care, palliative care, and hospice care. Through our personal care offerings, we deliver services to patients across Texas, Arkansas, Arizona, California, North Carolina and Missouri.
Through my role as Gentiva’s personal home care president, I oversee strategic planning for the company’s personal care programs, establish protocols and quality standards, drive key initiatives, build sustainable growth, and am responsible for day-to-day administrative operations.
RR: How did the partnership with HHAeXchange and Gentiva come about?
Bruner: Gentiva connected with HHAeXchange years ago through mutual industry contacts and kept up with the company’s progress. Later, when we began to evaluate our Texas agencies’ need for a new solution, we spent 18 months investigating and vetting major vendors in the homecare management software space.
Seeking a third-party, EVV-agnostic, cloud-based system, we narrowed the pool to two vendors who could meet our company’s needs while enhancing caregivers’ mobile experiences through simplified scheduling and coordination options. However, cost effectiveness and EVV prowess factored heavily into the final decision, which led to our selection of HHAeXchange.
RR: The Texas market is notoriously difficult. How does HHAeXchange differ from previous providers that gave up and left the state?
Vacarro: Texas is a large state with hundreds of thousands of patients receiving homecare on a regular basis from an incredibly broad roster of agencies and providers. While no two situations are alike and no two agencies do things exactly the same way, there is a commonality: the services they provide are incredibly valuable.
Because HHAeXchange understands the complex needs of homecare recipients and the critical work agency staffers are tasked with, we put considerable thought into the development of our EVV platform, its implementation, and its continued usage across Texas. We intend to differentiate ourselves and surpass standards set by our predecessors through our commitment to functionality.
We can’t custom-make solutions based on agencies’ and patients’ individual needs, but we can provide a platform with features versatile enough to be convenient and helpful to any user, no matter their agency size, location, workload, technological expertise or experience.
The HHAeXchange team also understands the importance of laying a solid foundation on which to build a new partnership and preparing for key transitions. So, for months ahead of our launch in Texas, our team spent a considerable amount of time hosting informational sessions for caregivers and agency owners and leading road shows throughout the state, demonstrating the EVV platform, answering questions, and getting more acquainted with the market.
I should add that, as part of our partnership with the Texas Health and Human Services Commission (HHSC), our Portal is available at no cost to program providers, financial management services agencies, and Consumer Directed Services (CDS) employers. We’ve taken steps to offer simple and convenient access, enabling homecare providers to easily meet Texas state requirements while offering a streamlined experience for both back-office staff and service providers.
RR: Is HHAeXchange compatible with EVV aggregators in all of the states where Gentiva operates?
Vacarro: Yes, HHAeXchange seamlessly connects payers and providers across the homecare ecosystem. Our platform allows for the accurate capture and transmission of all visit data, regardless of which aggregator a state selects and which EVV vendor and tools a provider uses.
We regularly partner with Medicaid agencies and MCOs in open and closed model states, where our platform is utilized to submit agencies’ data to another aggregator. This is how we work in Pennsylvania, North Carolina and now in Texas, for example.
RR: Thank you, gentlemen. For background on the HHAeXchange-Gentiva partnership, see our September posting of their joint news release at:
by Elizabeth E. Hogue, Esq. | Nov 8, 2023 | Clinical
Untitled Document
by Elizabeth E. Hogue, Esq.
Joyce Grayson, a home health nurse for Elara Caring, was murdered on October 28, 2023, in the home of a patient where she was providing services. Ms. Grayson was reported missing by a family member to the local police department. The family member was also able to track her last location to the home of a patient she was scheduled to visit at 8:00 a.m. on the day of her death. The patient resided at a halfway house for convicted sex offenders. Police have not yet formally identified a suspect in Ms. Grayson’s death.
This horrible news reminds of steps that staff members and providers can take to protect their staff members:
- Staff members should be sure of the locations of patients’ homes and have accurate directions. · Employees should contact their supervisors in the event of threatening circumstances.
- During visits, employees should remain alert and watch for signs of possible violence; such as verbal expressions of anger and frustration, threatening gestures, signs of drug or alcohol use, or the presence of weapons.
- When employees are verbally abused in patients’ homes, they should ask the speaker(s) to stop. If verbal abuse continues, caregivers should leave patients’ homes and notify their supervisors that they have done so. · If possible, caregivers should identify more than one exit from patients’ homes and keep a clear path to at least one of them.
- All employees should read or reread The Gift of Fear by Gavin de Becker and take action when their instincts tell them that they should be fearful. · Management should develop a written policy of “zero tolerance” for all incidents of violence, regardless of source. The policy should include animals! The policy must require employees and contractors to report and document all incidents of violence, no matter how minor. Emphasis should be placed on both reporting and documenting. Employees must provide as much detail as possible. The policy should also include “zero tolerance” for visible weapons when caregivers are present in patients’ homes. Caregivers must be required to report the presence of visible weapons.
- Agencies should develop quality indicators that improve efforts to protect staff. Indicators in quality and safety standards should include patient assault and other instances of violence or threatened violence. The results of these indicators should result in violence prevention plans and training programs in de-escalation of violence.
- Data systems should be strengthened to monitor the exposure of staff members to aggression. More resources should be invested in measuring aggressive events and specific factors that resulted in exposure, such as patient type.
- Ongoing education should be provided to protect staff. Education should focus on intentional actions that staff members must take to recognize, document, and counter threatened or actual violence.
The Connecticut General Assembly recently passed a law to increase protection for healthcare workers that does not include home care providers. Now lawmakers are calling for extension of the legislation to include home healthcare staff. Martin Looney, President Pro Tempore of the Connecticut State Senate told the CT Mirror: “More and more care is going to be provided in a home setting, which is generally a good thing. But if that is true, we need to make sure that the people who are providing that care are safe.”
Amen to that, Mr. Looney! Let’s get to it!
©2023 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 | Nov 8, 2023 | CMS, Regulatory
By Kristin Rowan, Editor
On November 1, CMS issued its Home Health Final Rule for CY 2024. As expected, the final rule includes drastic pay cuts to Medicare home health services payments. The original proposed rule issued earlier this year included a 5.653% rate reduction, the remainder of the 7.85% reduction from 2020-2021 and an additional 1.636% for 2022, for a total rate reduction of 9.36% overall from the start of PDGM. In a surprising turn, CMS has not implemented the full 5.779% rate cut from the initial proposal, opting instead to introduce the rate cuts over two years. The 2024 rate cut will be 2.890%, half of the full adjustment CMS alleges is still needed. The CMS final rule does not attempt to collect any of the alleged overpayments from 2020-2022, totaling $3,439,284,729.00.
NAHC President Bill Dombi offered this response:
“We continue to strenuously disagree with CMS’s rate setting actions, including the budget neutrality methodology that CMS employed to arrive at the rate adjustments. We recognize that CMS has reduced the proposed 2024 rate cut. However, overall spending on Medicare home health is down, 500,000 fewer patients are receiving care annually since 2018, patient referrals are being rejected more than 50% of the time because providers cannot afford to provide the care needed within the payment rates, and providers have closed their doors or restricted service territory to reduce care costs. If the payment rate was truly excessive, we would not see these actions occurring. The fatally flawed payment methodology that CMS continues to insist on applying is having a direct and permanent effect on access to care. When you add in the impact of shortchanging home health agencies on an accurate cost inflation update of 5.2% over the last two years, the loss of care access is natural and foreseeable.
We now implore Congress to correct what CMS has done and prevent the impending harm to the millions of highly vulnerable home health patients that depend and will depend in the future on this essential Medicare benefit. Fortunately, longstanding advocates for home health care, Senator Debbie Stabenow (D-MI) and Senator Susan Collins (R-ME) have introduced S. 2137 to eliminate the rate cuts. We urge the Congress to support this legislation and enact it into law before the end of the year. The 2024 rate cuts must not take effect.”
The final rule includes the following:
- A net 3.0% inflation update
- A 2.890% Budget Neutrality permanent adjustment
- A $3,489,523,364 alleged overpayment in 2020-2022. CMS has not scheduled a collection of the alleged overpayment in 2024 or any other year yet.
- Recalibration of the 432 case mix weights with a separate budget neutrality adjustment in the payment rates of +1.0124%
- CMS estimates an increase in CY2024 Medicare spending of $140 million ($525 million inflation increase minus the $455 million rate adjustment plus a $70 million outlier FDL change)
HHAs that fail to provide required quality data will have these rates reduced by two percent.
Non-payment-related changes
In addition to the inflation increase and payment adjustments, the CMS Final Rule includes a number of other changes. These changes include amendments for the payment of Disposable Negative Pressure Wound Therapy, removing and replacing OASIS measures in HHVBP, new coverages and payments in IVIG services, the adoption of two new measures and the removal of one existing measure in HHQRP, coverage for lymphedema therapy items under a new Medicare Part B benefit, and revisions to Medicare provider enrollment requirements.
Hospice Provisions
Hospice Special Focus Program (SFP)
CMS is pushing forward with the Hospice SFP. Despite the commonsense suggested changes requested by NAHC and multiple others, CMS is using a flawed algorithm in the structure and implementation of SFP. This flawed algorithm will fail to identify hospices most appropriate for additional oversight and support. This creates the risk of reducing access to higher quality care and directing patients and families to hospices that perform most poorly relative to health and safety requirements. The official stance from NAHC is strong support of the SFPs goal to improve poor performing hospices, but are emphatically against the method in which SFP is being implemented and will continue to advocate for changes to the structure of the program.
Hospice Informal Dispute Resolution (IDR)
The IDR process for hospice is for condition-level survey findings which may trigger an enforcement action. The finalized IDR process allows hospice programs an opportunity to resolve disputes during recertification or reaccreditation for continued participation in Medicare. this allows for settlement agreement prior to a formal hearing, which will save time and money for the hospice agency. NAHC has additional recommendations for the Hospice IDR process that have not been implemented in the final rule.
Hospice 36-month rule
CMS is extending the “36-month” rule that currently applies to home health agencies and hospices, which is designed to prevent the flipping of Medicare certifications to non-vetted hospice owners. There are several exceptions to the rule for hospices. Even if a hospice undergoes a CIMO, a new owner must enroll as a new hospice and undergo a survey or accreditation unless:
- The hospice submitted 2 consecutive years of full cost reports since initial enrollment or the last CIMO, whichever is later.
- A hospice’s parent company is undergoing an internal corporate restructuring, such as a merger or consolidation.
- The owners of an existing HHA are changing the hospice’s existing business structure (for example, from a corporation to a partnership (general or limited)), and the owners remain the same.
- An individual owner of an hospice dies
New hospice owners will immediately be placed into the “high-risk” category for screening requirements and will have to submit fingerprints for a national background check from all owners with a 5% or greater direct or indirect ownership interest.
CMS Final Rule Synopsis and NAHC Response
We reached out to NAHC President Bill Dombi after the release of the Final Rule for CY2024. He provided us with a full breakdown of each provision in the final rule and the NAHC stance on each topic.
You can read all of these changes and how NAHC will continue to advocate for changes to the final rule here.
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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 started writing for 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
©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 Kristin Rowan | Oct 25, 2023 | Admin, Regulatory
by Kristin Rowan, Editor
Marking a significant victory for the HCAOA Connecticut Chapter and the home care industry, in the legislative session that ended last week, lawmakers unanimously passed a bill to reverse the policy guidance issued by the Department of Consumer Protection in January that banned use of the word “care” by home care agencies. In response to the guidance that directly harmed the industry, the Chapter and its members engaged in a strong lobbying effort to reverse it.
The guidance had caused significant concern and confusion for agencies, caregivers, consumers and lawmakers. Indeed, the Department had recently begun enforcing the ban against HCAs, requiring them to remove the word “care” from websites and other advertising.
On June 2, the state Senate gave final legislative approval to House Bill 5781, which allows HCAs to use the word “care” in their business names and advertising and advertise having employees trained to provide services to individuals experiencing memory difficulties as long as the agency prominently advertises that it solely provides nonmedical care, and doesn’t use any words, such as those related to medical or health care licensure or services, to describe services beyond the scope of those a HCA is authorized to provide. Also, HCAs must give consumers written notice that the agency provides nonmedical care and obtain the consumer’s signature on the notice before providing services. The Governor is expected to sign Public Act 23-48 shortly.
Chapter leaders and many members testified in support of the legislation, contacted the Governor and met with lawmakers and other officials, engaged in grass roots support, and advocated for the change. “It was a significant effort by the Chapter but our strategy and the work of members paid off,” said Marlene Chickerella, Chapter Chair and owner of B&M Homemaking Services in West Haven. “We are very grateful to lawmakers for changing the policy and appreciate all the support and assistance of our member-home care agency owners. They stepped up and clearly made a difference.”
Additionally, House Bill 5781, which originally arose out of the Homemaker-Companion Task Force recommendations:
• Requires the Office of Policy and Management to develop a plan and proposed timeline to transfer oversight of HCAs from Consumer Protection to the Department of Public Health; the plan will include recommendations on training standards and appropriate use of the term “care” to describe home care services.
• Adds failure to give a consumer written notice that the agency provides nonmedical care to a list of violations for which DCP may revoke, suspend, or refuse to issue or renew a HCA’s registration; requires DCP to revoke a HCA’s registration if the agency is found to have violated any revokable provisions three times in a calendar year.
• Requires HCAs to develop in consultation with the consumer a service plan or contract that includes (1) a person-centered plan of care, (2) anticipated oversight by the agency of the caregiver assigned to the consumer, and (3) how often the person who oversees the agency’s caregiver and consumer will meet.
• Requires DCP to post on its website a guide detailing the process for consumers to file complaints against a HCA; and requires agencies to give consumers a printed copy of this guide with their contract or service plan.
• Requires HCAs to create a brochure and maintain a website detailing the services it provides.
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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 at kristin@girardmarketinggroup.com or www.girardmarketinggroup.com
