Home Health & Hospice Week

Is your city next on the list?

The Centers for Medicare & Medicaid Services hasn’t named a new HHA moratorium city since early 2014 — but that may change soon.

Reminder: CMS first implemented the home health agency moratoria in July 2013 in Miami-Dade and Chicago (see Eli’s HCW, Vol. XXII, No. 27), two years after the moratorium authority was enacted. Then in February 2014, it added Ft. Lauderdale, Detroit, Dallas, and Houston (see Eli’s HCW, Vol. XXIII, No. 6). Since then it has extended the moratoria every six months for those six areas. The latest extension was announced in the July 28 Federal Register (see Eli’s HCW, Vol. XIV, No. 27).

Home care experts have expected CMS and the HHS Office of Inspector General to extend the moratoria to even more areas as utilization and the number of providers continue to climb. Predictions on new moratoria targets have included other cities that have HEAT Medicare Fraud Strike Force operating in them (as five of the six current areas do). That would be Baton Rouge, La., Brooklyn, N.Y., Los Angeles, and Tampa Bay, Fla.

Other likely targets include cities adjacent to Strike Force areas (such as the current Ft. Laudedale moratorium). That could be cities in Northern Indiana and South Texas, experts suggest.

Finally, cities whose home health agency statistics stick out like a sore thumb are also areas ripe for future moratoria. In the past, experts have cited Ohio, Las Vegas, Salt Lake City and Oklahoma City as potential moratoria areas (see Eli’s HCW, Vol. XXIII, No. 6).

Now, it looks like the Ohio prediction may come to pass. According to state government emails obtained by The Columbus Dispatch newspaper, an OIG official told an Ohio Medicaid official that “I plan to submit a memo to my supervisor requesting that the Centers for Medicare and Medicaid Services conduct statistical analysis in order to determine if a home health moratorium should be put in place for Franklin County, Ohio.”

The Columbus metro area has the highest concentration of Medicare-certified home-health agencies among the nation’s 50 largest metro areas, according to the Dispatch. The OIG official also listed a number of high Medicaid stats, including that Franklin County accounts for 27.7 percent of all Ohio Medicaid spending for HHAs but has only 10 percent of the state’s population; and Ohio Medicaid paid agencies in Franklin County 41 percent more per recipient than agencies in the rest of the state.