Home Health & Hospice Week

Where’s The Data?

One thing RCD is lacking that its predecessor, the Pre-Claim Review demonstration, did not is regular reporting of affirmation rates. The Centers for Medicare & Medicaid Services published frequent affirmation rate updates under PCR, with rates topping 90 percent at the demo’s end. Neither CMS nor Palmetto is publicizing average affirmation rates under RCD.

We “would like to have real and transparent data from CMS,” says Rachel Hammon with the Texas Association for Home Care & Hospice.“However, based on Illinois and Ohio’s experience, we are not optimistic at this time we will see such transparency,” Hammon tells Eli.

“By now we should be able to see real numbers related to the impact of RCD from CMS, but thus far those numbers have not been shared with the industry,” Hammon says.

Legislative solution: For this reason, TAHC is one of more than 140 groups supporting H.R.5741, the Strengthening Innovation in Medicare and Medicaid Act. The U.S. House bill would require CMS to “monitor continuously and on a real-time basis the effect of a model … and mitigate any adverse impact, such as inappropriate reductions in care or reduced access to care,” the legislation says. The bill would also allow for hardship exceptions.

“Safeguards are a must for any reform to ensure patients care needs are protected,” Hammon insists. CMS’ Center for Medicare and Medicaid Innovation “must conduct limited-scale testing to ensure these changes don’t harm already vulnerable patients,” she says.

“It is essential for CMMI to comply with its original intent to serve as a robust research and development platform to experiment and evaluate new payment and delivery concepts,” Hammon continues.

RCD, PDGM Close Some Doors

Measuring RCD’s impact in Illinois is a little unique, because the state already underwent the PCR demo. So far in RCD’s second state, Ohio, there have been noticeable changes, Russell relates. The market was already consolidating with sales and mergers, and RCD and the Patient-Driven Groupings Model added to that trend, he believes.

But some providers simply decided to “wave the white flag” in the face of the RCD-PDGM one-two punch, Russell says. They just got “beaten down and battered and decided to close.”

The timing of RCD right before PDGM was “unfair,” since CMS postponed the RCD implemen­tation date for Texas, Florida, and North Carolina, Russell protests.

On the other hand: Ohio agencies that stayed in the game have responded well to RCD. Russell feels confident the state’s affirmation rate is above 90 percent, based on reports he’s hearing.

The fallout from PDGM is harder to assess and might be more extensive, Russell predicts. It’s still too early to tell.

It’s even earlier days for Texas HHAs under RCD, but Hammon reports that agencies that sought out education and engaged in preparation seem to be faring well. “The more prepared agencies have stated they are able to submit their PCR requests in about 30 minutes per request and have received a [Unique Tracking Number required for billing] within 24 hours,” plus “an affirmation within 48 hours,” she says.

In contrast: “The agencies that were less prepared are taking longer to submit and have not been as successful at receiving affirmations,” Hammon relays. However, those agencies in Option 1: PCR will get second chances to fix their mistakes, even if it delays cash flow.

Note: Palmetto’s RCD page is at www.palmettogba.com/palmetto/providers.nsf/Docs/Providers~JM Home Health and Hospice~Home Health Review Choice Demonstration.