Home Health & Hospice Week

Plus: Some agencies are poised for whiplash — and maybe closure — from major wage index swings.

What can Medicare do to help home health agencies survive the brutal slog through the COVID-19 Public Health Emergency, which doesn’t look to be ending any time soon?

Commenters on the 2022 home health proposed rule released in June were full of suggestions, including:

• Telehealth. The Centers for Medicare & Medicaid Services is proposing to permit telehealth service delivery as a home health benefit beyond the PHE, cheer execs Margaret VanOosten, Jenn Ofelt, and Cathy Simmons with Iowa health system UnityPoint Health in the system’s comment letter. Telehealth has many benefits, VanOosten, Ofelt and Simmons relay. “As an example, during a significant COVID-19 surge in a rural part of Iowa, the hospital was overwhelmed by patient volume. Our HHA was able to increase census capacity via the use of remote patient monitoring,” they cite. “During the pandemic, remote monitoring was also crucial to our strategy to conserve Personal Protective Equipment (PPE),” they add.

But “this proposal stops short of authorizing reim­bursement and/or allowing for an audiovisual connection to count toward visit frequency, which improves the ability of HHAs to serve more patients, especially in rural areas,” VanOosten, Ofelt, and Simmons chastise. “We urge CMS to expand this proposal. As CMS considers [a] potential reimbursement framework for HHA telecommunication encounters, we would recommend reimbursement be tied to those encounters identified within the Home Health plan of care and that the rate be commensurate with the various eval­uation and management visit codes as set forth in the Medicare physician fee schedule,” they advise.

• Wage index. The volatile wage index system has never been popular with HHAs, and that’s only increased as CMS has adopted new Office of Management and Budget (OMB) geographic delineations.

Reminder: CMS capped wage index decreases for the new OMB designations at 5 percent this year. Next year, the rest of the wage index change will hit with no cap. So, if the wage index for an area dropped 30 percent due to the OMB change, agencies will see a 25 percent decrease starting Jan. 1.

Doing a full switch with no cap is “so adverse that without further mitigation, we will be forced to curtail services and limit access to populations in need,” stresses Christopher Rinn with Visiting Nurse Association Health Group in New Jersey.

“The wage index in every area that we serve will be reduced for the upcoming year,” relates Lisa Harvey- McPherson with Northern Light Health, parent of Northern Light Home Care and Hospice in Maine. “This is completely antithetical to the wage situation all of our healthcare partners are facing as we continue to navigate the COVID-19 pandemic, as well as other upward wage pressures,” Harvey- McPherson says in the system’s comment letter. “Our ability to care for patients in their home is limited only by our ability to compete to hire and retain staff. A reduction in wage index further threatens this notion,” she stresses.

“We respectfully request that CMS reverse the proposed rule and reinstate the 5 percent cap for 2022 for home health providers,” Rinn urges.

Commenters also decry the longstanding problem of neighboring areas having very different wage index levels, and of hospitals that get to reclassify into higher wage index levels while HHAs can’t. Current and potential home health staff “could travel a very short distance to the New York Metro CBSA, with its 25 percent higher wage index,” leaving VNA Health Group scrambling in an already tight labor market, Rinn notes.

• Rural add-on: “Patients living in remote or rural areas of the country face a variety of obstacles when it comes to accessing the health care system,” reports Rachel Hammon with the Texas Association for Home Care and Hospice in the trade group’s comment letter. “In order to serve rural patients, home health agencies are confronted with significantly higher costs due to the additional travel time needed to reach patients, and the higher transportation expenses of home health medical professionals having to travel longer distances to reach a patient. Rural home health agencies operate differently than urban agencies, and have fixed costs that are often spread out over a smaller patient population and fewer visits.”

Reminder: CMS is currently phasing out the rural add-on based on a legislative mandate. In 2022, only agencies in low population density counties will see an add-on, and it will be reduced to 1 percent. In 2023, all rural add-ons will go away.

“We urge CMS to work with Congress to maintain the rural add-on payment at 3 percent in order to protect Medicare beneficiaries’ access to home health in rural communities,” TAHC tells CMS. ey advise.