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[Statement issued by the Partnership for Quality Home Healthcare]
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Washington, DC – June 8, 2016 – The Partnership for Quality Home Healthcare – a coalition of home health providers dedicated to improving the integrity, quality, and efficiency of home healthcare for our nation’s seniors – today expressed disappointment with the revised home health prior authorization demonstration, released today by the Centers for Medicare & Medicaid Services (CMS). Now called a “Pre-Claim Review” demonstration affecting seniors in five states over three years, the demonstration will impose still further documentation requirements on already burdened high quality home health agencies that could result in poor care transitions and still further confusion for seniors seeking care at home. [Details are provided about the expected detrimental results of applying the Pre-claim Review to healthcare at home seniors.]
Home health leaders have previously warned that prior authorization policies will drive up costs to the Medicare program as patients would likely be sent to more expensive in-patient facilities, or potentially experience a hospital readmission while waiting alone at home for their prescribed post-acute care to begin. The Pre-Claim Review Demonstration takes a step forward to address this outcome by allowing seniors to start home health services while the agency submits applicable documentation, but it still creates new challenges for home health agencies in providing seamless, integrative high quality skilled health care, and thus could negatively impact the patient experience overall. “We appreciate the steps CMS has taken to protect beneficiary access to care in the revised demonstration, however, much more needs to be done. We remain concerned that the demonstration does not go far enough to protect patients from potential harms inherent with pre-claim review, including confusion, delays and service interruptions in care for a vulnerable patient population” said Colin Roskey, Executive Vice President of the Partnership. “We are also concerned that CMS has not followed notice-and-comment standards for obtaining and responding to input from those immediately affected by the demonstration.” Bipartisan lawmakers have also expressed concerns that home health prior authorization could cause dangerous delays in care for vulnerable home health patients. In a letter to CMS last month, 116 bipartisan House lawmakers wrote, “This demonstration project imposes costs on patients, providers and taxpayers. Delaying patient care while waiting for CMS to approve home health services may put patient health in jeopardy and cause patients to stay in the hospital longer than necessary.” The mandatory pre-claim review demonstration paints all agencies in the affected states with a single brush. The Partnership instead recommends CMS pursue more targeted reforms that will strengthen program integrity without compromising the healthcare needs of patients. The Partnership has offered several proposals to address fraud, including targeting aberrant billing and utilization, ensuring sufficient qualifications and background checks, and identifying the isolated geographic areas which CMS data confirm are the ‘hot spots’ of fraud. “We and our colleagues throughout the home healthcare community would welcome the opportunity to collaborate with CMS on the development and implementation of appropriate and targeted program integrity measures that fall within CMS’s authority and that would effectively identify and eradicate fraud and abuse,” the Partnership wrote in its comment letter to CMS. Data compiled by Avalere Health reveal that Medicare home health beneficiaries are older, sicker, poorer and are more likely to be female, a minority, and disabled than all other beneficiaries in the Medicare program combined. Nationwide, 3.5 million homebound Medicare beneficiaries depend on the Medicare home health benefit to receive clinically advanced, cost effective and patient preferred care. This statement was released on 6/8/16 by the Partnership for Quality Home Healthcare. For more information about the Partnership, visit homehealth4america.org/mission or on Facebook at https://www.facebook.com/Homehealth4America. |
By Tim Rowan. Editor and Publisher of Home Care Technology Report
On April 8, fourteen representatives of healthcare at home software companies gathered with provider executives at the VNAA Annual Meeting in Miami to explore the challenges of creating data interoperability between acute and post-acute caregivers. What came out of the two-plus hour discussion must be described as, at best, a solid understanding of how difficult a hill this is going to be to climb. This will not be the only attempt, however, to search for answers. Home Care Technology Report editor Tim Rowan and VNAA CEO Tracey Moorhead have agreed to work together to keep the conversation alive until the best path forward appears. [The range of multi-faceted problems were outlines by 14 panelists from the industry’s leading solutions vendors, and, as Rowan notes, though definitive solutions could not be expected during a preliminary discussion between 14 people, a moderator, and an audience of providers, a range of first steps to be undertaken by national associations such as the VNAA is indicated for working toward establishing data interoperability between acute and post-acute caregivers.]
The fourteen panelists from the industry’s leading solutions vendors first outlined the multi-faceted problem:
- Willingness to cooperate on the part of hospital EMR software vendors cannot be assumed, especially the one vendor that chose not to join the Commonwell Health Alliance, a membership organization where competition is supposed to take a back seat to patient care when the creation of data sharing standards is concerned.
- Customers of these EMR vendors have not been demanding data interoperability features to be added to their applications. Much work remains to be done to teach providers how urgent this technology will be to their very survival.
- HL7 can no longer be considered an adequate solution to the problem of HIPAA-compliant data transparency.
- Healthcare at Home providers and their vendors should not be hoping that complete patient records will be shared in the near future but should be satisfied with minimal data sets, such as the one established for the Continuity of Care Document.
- The entire Healthcare at Home industry must continue the uphill battle to be included in high-level discussions rather than disregarded as an afterthought, merely informed when others finally establish standards.
While definitive solutions could not be expected during a preliminary discussion between 14 people, a moderator, and an audience of providers, some good ideas came to the forefront before the afternoon ended.
- National associations such as the VNAA have a responsibility to include interoperability in their educational offerings.
- Healthcare at Home executives need to take responsibility to negotiate partnerships with hospitals and ACOs, not leave it up to their sales and marketing staff.
- Early steps can be taken to transmit simple patient data sets from home health to hospice to long term care and rehab hospitals while waiting for the large hospital software companies to decide on standards. Among those might be Direct Secure Messaging, a protocol available to all software developers that could be used to exchange patient data without the need for interoperability standards.
As mentioned above, this conversation will continue. The VNAA is taking it seriously and so do we. The door is open to every concerned healthcare at home industry participant to join us.
©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com
