Home Health & Hospice Week

Meanwhile, industry pursues PCR eradication.

The home health industry continues to try to return the unwanted present Medicare has left under its Christmas tree.

Now that the Centers for Medicare & Medicaid Services is rolling forward with Pre-Claim Review implementation again, industry representatives are redoubling their efforts to combat the demonstration program.

“We are still vehemently opposed to the Pre-Claim Review Demonstration,” vows Joy Cameron with the Visiting Nurse Associations of America.

The National Association for Home Care & Hospice “and the state home care associations have been aggressively pursuing remedies for the problems caused by the project since its original unveiling in February of 2016,” NAHC says in its member newsletter.

Many agencies are pinning hopes on the incoming Trump administration, including Health and Human Services Secretary nominee Tom Price (R-Ga.), to roll back the program. Price has previously introduced legislation to halt the program (see Eli’s HCW, Vol. XXV, No. 43). “We hope that HHS Secretary designee will rescind or scale back PCR consistent with his legislative proposal,” says William Dombi, NAHC’s VP for law.

HHAs “hope that the new administration folks will pull the plug on this nightmare,” agrees Chicago-based regulatory consultant Rebecca Friedman Zuber, who works with the Illinois Homecare & Hospice Council.

Whether Price can be confirmed and effect such a change in time to help Florida agencies is an open question.

Last resort: NAHC is still considering development of a lawsuit over PCR, it says.

Alternative: NAHC hopes to persuade “CMS to scale back the application of pre-claim reviews to target only high risk providers and that rely on random sampling methodologies for pre-claim reviews overall in order to reduce unnecessary administrative burdens,” the trade group adds.

While agencies can hope for success with these elimination or abatement methods, they should still prepare for the worst, advises attorney Robert Markette Jr. with Hall Render in Indianapolis. That’s especially true for agencies in the three remaining demo states — Texas, Michigan and Massachusetts.

“I would not assume it’s not going to happen,” Markette says.

The worst-case scenario is that you improve your documentation and better prepare yourself for future audits, Markette tells Eli.