In The News

CMS Prods Hospitals to Improve Discharge Info for Home Health, SNFs

McKnight’s Home Care | By JAMES M. BERKLAN
 
The home care community is supporting a special memo issued this week that draws attention to hospitals’ shortcomings in providing post-acute care providers with adequate discharge information.
 
Home health and nursing home providers too often have been receiving patients with conditions they are not properly prepared for, putting both care providers and patients at risk, a Centers for Medicare & Medicaid Services official said in a note to state survey agency directors.
“CMS has identified areas of concern related to missing or inaccurate patient information when a patient is discharged from a hospital,” wrote David R. Wright, the CMS director of the Quality, Safety & Oversight Group. 
 
“[Post-acute care] providers may not be equipped or trained to care for certain conditions that apply to patients whose information they were not previously informed of by the hospital and have accepted for transfer and admission,” the memo added. “Not only can this place the patient’s health at risk, it can also put the health and safety of other residents (in the patient’s home or in a SNF), as well as provider staff, at risk. These situations can cause avoidable readmissions, complications, and other adverse events.”
 
The National Association for Home Care & Hospice said it agrees with the memo.
 
“Lack of thorough information coming from acute care facilities to home health and hospice providers is a long-standing issue. As the memo points out, thorough and accurate information is essential to patient safety and quality of care,” NAHC Director of Home Health and Hospice Regulatory Affairs Kate Wehri told McKnight’s Home Care Daily Pulse in a statement. “We believe that when it comes to serious mental illness (SMI), complex behavioral needs and/or substance use disorder (SUD) information, guidance around what should or should not be shared with the post-acute care provider may not be clear.”
 
Some specific “areas of concern” for CMS are “missing or inaccurate information” related to patients with serious mental illness, complex behavioral needs or substance abuse problems.
Underlying diagnoses related to mental illness or substance abuse sometimes have not been included, regulators found. In addition, there may be incomplete information passed along about specific treatments a hospital undertook, such as additional supervision needed during a patient’s stay…

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Making Care Primary (MCP) Model

On June 8, 2023, the Centers for Medicare & Medicaid Services (CMS) announced a new voluntary primary care model – the Making Care Primary (MCP) Model – that will be tested in eight states. Launching July 1, 2024, the 10.5-year model will improve care management and care coordination, equip primary care clinicians with tools to form partnerships with health care specialists, and leverage community-based connections to address patients’ health needs as well as their health-related social needs (HRSNs) such as housing and nutrition. CMS is working with State Medicaid Agencies in the eight states to engage in full care transformation across payers, with plans to engage private payers in the coming months. CMS will begin accepting applications for the model in late summer 2023.

Model Overview 

The Making Care Primary (MCP) Model is a 10.5-year multi-payer model with three participation tracks that build upon previous primary care models, such as the Comprehensive Primary Care (CPC), CPC+, and Primary Care First (PCF) models, as well as the Maryland Primary Care Program (MDPCP). MCP aims to improve care for beneficiaries by supporting the delivery of advanced primary care services, which are foundational for a high-performing health system. The MCP Model will provide a pathway for primary care clinicians with varying levels of experience in value-based care to gradually adopt prospective, population-based payments while building infrastructure to improve behavioral health and specialty integration and drive equitable access to care. State Medicaid agencies will commit to designing Medicaid programs to align with MCP in key areas. This model will attempt to strengthen coordination between patients’ primary care clinicians, specialists, social service providers, and behavioral health clinicians, ultimately leading to chronic disease prevention, fewer emergency room visits, and better health outcomes…

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Report: A Few Private Equity Firms in Home Health Command Large Portion of Medicare Payments

McKnight’s Home Care | By Liza Berger
 
An aging population and pressure on labor and costs makes home health an attractive target for private equity firms. Also, while private equity accounts for a relatively small proportion of ownership, a few players control a large proportion of Medicare payments. These are two key findings from a report published this week.
 
“Private equity ownership provides opportunities to maximize revenue by cutting costs, increasing control over prices by consolidating markets, and deploying financial engineering mechanisms such as fees and dividend recapitalization,” the report by the American Antitrust Institute and Americans for Financial Reform Education Fund stated. “This aligns closely with the private equity model of generating high short-term returns for investors.”
 
Small piece of home health pie
 
As of early 2023, private equity was behind 5.7%, or about 492, of 8,591 total home health providers. Moreover, a total of 37 private-equity-owned or backed “parent” companies was behind the 492 home healthcare providers. These parent companies have acquired about 330 individual, and frequently small, home healthcare companies and consolidated them into the three dozen firms.
 
The top five of the 37 are raking in a disproportionate amount of the home health private equity revenues, according to the report. They account for about 63% of total revenues and 57% of their locations. On average, they collected over $850 million in Medicare revenue and operated almost 280 locations in 2020. The largest home healthcare company, Accentcare, backed by private equity firm Advent International, collected just over twice as much as the average revenue for all five firms. The four other largest parent private equity-backed companies are Interim HealthCare, Aveanna Healthcare and Mission Healthcare.
 
Red flags for regulators
 
The report sounds alarm bells on the importance of government oversight of private equity, which has been associated with cutting costs at the expense of quality and operating under the radar of regulatory authorities.  
 
“The incursion of private equity into healthcare, and home healthcare in particular, raises pressing questions,” the report said. “For example, are the economic incentives and strategies typical of private equity compatible with ensuring affordability, access and quality in healthcare? What do aggressive acquisition strategies, roll-up strategies and rapid market exits mean for market concentration and the stability of healthcare markets? Is private equity targeting or driving higher concentration in healthcare markets?”
 
Of particular concern is private equity firms are present in about half, or around 190, of highly concentrated home health markets. More concentrated markets feature fewer competitors and are associated with higher prices following “harmful” mergers and lower quality of care, according to the report. Large players also are operating in markets with and without private equity, the report points out…

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2024 Proposed Hospice Payment Update Will Significantly Impact Hospice Providers

The Health Group

Under the proposed hospice payment rule, payments to hospices for the year beginning October 1, 2023, will increase by only 2.8%.  This increase in base rates, adjusted by geography, is not close to the overall increase in the cost of services being experienced by hospice providers across the country.  The comment period relating to the proposed rule has ended.

Even though the 2.8% will be revised later this year to be more reflective of more current data, if available, hospices are experiencing substantially greater cost increases than 2.8%.

A substantial portion of the cost increases being experienced are related to labor costs.  Hospices, and much of the healthcare industry as a whole, have experienced an inability to secure staffing to support healthcare delivery needs.  This shortage, which originated prior to the COVID-19 PHE, has increased because of the public health emergency.  Healthcare professionals can, and are demanding, higher levels of compensation because of this shortage.  Hospices have no alternative but to increase compensation to compete with other healthcare providers for these personnel.  Hospices are also experiencing cost increases related to supplies, drugs and other necessary items to appropriately provide care to terminally ill populations.

Other cost increases are influenced by the ever-increasing regulatory environment, which has only been compounded by the removal of flexibility provided during the COVID-19 PHE.  Simultaneously, there are significant efforts underway to improve program integrity, many of which can be more efficiently addressed than expected to be proposed.

The increase in hospice payment rates, over the past several years, has been less than the actual cost increases incurred and the same will occur in FY 2024 (October 1, 2023, through September 30, 2024).

While we recognize the national efforts to decrease government expenditures generally, we believe there are many areas where healthcare expenditures could be reduced or better managed, rather than simply reducing payments generally compared to the costs being incurred to provide patient services.

Sequestration May Never End – Hospices, like other healthcare providers, are being penalized at the rate of two percent (2%) of Medicare payments due to the inability of Congress to reduce government spending by $1.5 trillion over ten (10) years in 2011.  Congress passed legislation in 2011, signed by President Obama, as part of a debt ceiling compromise which established a Joint Select Committee on Deficit Reduction, consisting of Republicans and Democrats, to reach a compromise on the reduction of expenditures by $10.5 trillion.  If the Committee had done so, sequestration could have been averted.  The Committee took the easy way out and just let the two percent (2%) reduction become law.  Of course, healthcare providers are not the only ones impacted by the sequester; however, it has now been ten (10) years, excluding the COVID-19 PHE period, that hospices, and other healthcare providers, have had their payments confiscated.  The sequestration was originally scheduled to end in 2021 but is currently extended to 2032.  The extension of sequestration continues to be an easy means for Congress to reduce expenditures with little, if any political consequence.

It is becoming increasingly important that hospices, and other healthcare providers, take these issues to their elected officials, especially as elections loom in the future.  CMS cannot address sequestration and has limited ability, on their own, to address the increase in upcoming payment rates.

The Health Group continues to do whatever it can to pursue appropriate reimbursement for hospices, and other healthcare providers, on your behalf.

 

In Case You Missed It – Webinar Recording Available Now

Experts Share Tips on Properly Documenting the Physician Certification of Terminal Illness in New Webinar

CGS, your Medicare Administrative Contractor (MAC), has launched a new webinar that covers everything you need to know about completing the physician certification of terminal illness (CTI) for hospice services.

What does the training discuss?

In this interactive webinar, you will learn what a CTI is, when it is needed, and the documentation Medicare requires to avoid claim denials. Expert speakers Kristi Spruell, RN, and Neil Sandler, MD, also present examples of proper CTI documentation and answer questions from the audience.

For whom is this training?

This webinar is for staff involved in documenting the CTI (i.e., physicians [MDs and DOs], nurse practitioners/other advanced practice registered nurses).

What’s the cost?

This activity is available at no cost.

To access the recording, you must register and create a profile. From there, you can view all recorded sessions by going to Schedule at the top of the page and selecting On Demand in the drop-down menu.

Access the Recording Here: https://web.cvent.com/event/a64b8e73-c925-4e3f-a190-8d61ecdd86f8/websitePage:41a33394-6c97-4314-96b9-385402ce20d2

Have you seen our new video on additional documentation requests (ADRs)? This quick video [r20.rs6.net] shows you the fundamentals, including ways to check for ADRs and tips for responding on time. 

You’re receiving this message from CGS, a MAC. Contact us by email, or visit our website [r20.rs6.net] for more information on hospice certification requirements.

 
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