Home Health & Hospice Week

Which locations are next on the hit list?

The feds’ extension of HHA moratoria did not come as a surprise to many observers, but what did is that CMS did not expand the restriction to more locations.

Los Angeles is often cited as the next-most-likely target for a moratorium on new home health agency enrollees in Medicare. “Providers in that area should certainly be anticipating an extension to their area,” advises Washington, D.C.-based attorney Elizabeth Hogue.

The other Strike Force cities — Baton Rouge, La., Brooklyn, N.Y., and Tampa Bay, Fla., also seem susceptible, experts agree.

Look for: Areas adjacent to current moratoria and Strike Force cities are also potential future moratoria locations, expects attorney Robert Markette Jr. with Hall Render in Indianapolis. Criminals chased out of Strike Force areas are often setting up shop in surrounding locations, Markette tells Eli.

The Centers for Medicare & Medicaid Services may have held back in imposing more moratoria locations due to data, suggests attorney Troy Brooks with Brooks Acevedo in Houston, Texas. “I’m not sure that many other locations meet the criteria CMS relied upon to impose the first two rounds of moratoria,” Brooks notes. That included stats such as agencies receiving twice the reimbursement as comparable areas (in Ft. Lauderdale) and an agency-to-beneficiary ratio 365 percent higher than in comparison counties (in Dallas) (see Eli’s HCW, Vol. XXIII, No. 6)

In addition to adding more areas, CMS may add more provider types to the moratoria list, predicts Chicago-based regulatory consultant Rebecca Friedman Zuber. Currently, an HHA moratoria exists in six metro areas and a ground ambulance moratoria exists in two.