VNAA to Challenge Pre-Claim, Medicare Cuts

A national, nonprofit organization that promotes, advances and supports mission-driven providers of community-based health care has revealed the specific home health and hospice legislation it will focus on and which causes it will seek to advance on Capitol Hill in the coming months.

The Visiting Nurse Association of America (VNAA), based in Arlington, Virginia, outlined two pieces of home health legislation and four pieces of hospice legislation that it intends to advocate for* in Congress in a policy call Tuesday. The organization also identified two additional home health-related policies—with no current associated bills—it intends to push in the upcoming months, which involve delaying the rollout of the pre-claim review demonstration, as well as preserving and protecting access to home-based services.

Specifically, VNAA plans to ask all Congressmen to tell the Centers for Medicare & Medicaid Services (CMS) that slashing home health payments by $180 million in 2017 will place beneficiary access to care at risk and surpass the statutory limits Congress placed on rebasing home health payment rates.


VNAA also plans to ask Congress to urge CMS to postpone the rollout of the pre-claim review demonstration in Massachusetts, Florida, Texas, and Michigan in the next three years. The pre-claim review demonstration, VNAA says, imposes additional documentation requirements on high-quality home health agencies that are already burdened. Moreover, the implementation could lead to poor care transitions, as well as confusion for seniors receiving care at home and the seniors’ doctors.

The pre-claim review demonstration has already proven plenty controversial among home health providers and U.S. Senators alike; earlier this month, two Senators from Florida called for the program to be delayed in their state, and the National Association for Home Care & Hospice (NAHC)’s Vice President for Law Bill Dombi called the rollout in Illinois a “complete mess.

Legislation-wise, the organization stands behind the Home Health Planning and Improvement Act (S. 578 / H.R. 1342), a bipartisan bill which would enable clinical nurse specialists, nurse practitioners, certified nurse midwives and physician assistants to order home health services under Medicare in accordance with state law. The legislation, according to VNAA, would improve access to critical home health care services and possibly prevent additional skilled nursing and hospital admissions.


VNAA also plans to advocate for the passage of the Home Health Documentation and Program Improvement Act of 2015 (S.1650), another piece of bipartisan legislation that, in VNAA’s view, provides “common-sense improvements to currently unworkable and administratively burdensome rules regarding Medicare home health ‘face-to-face’ documentation requirements.”

Currently, VNAA is also seeking the introduction of a similar piece of legislation in the House of Representatives.

On the hospice side, VNAA plans to advocate for the passage of the Care Planning Act of 2015 (S. 1549), which would establish Medicare reimbursement for health care professionals to provide a voluntary discussion about the treatment options and goals for patients with serious illness, resulting in a documented care plan that reflects the informed choices made by patients working with members of their health care team, family members, faith leaders and friends. Additionally, the legislation provides resources for professional and public care planning educational materials.

VNAA also plans to advocate for the passage of the Palliative Care & Hospice Education and Training Act (PCHETA) (S. 2748 / H.R. 3119), a piece of bipartisan legislation that would establish education centers and career incentive awards to improve the training of physicians, social workers, physician assistants, nurses and other health professionals in palliative care.

The Compassionate Care Act (S. 2961), bipartisan legislation that would create and implement provider and consumer education programs to increase awareness and develop skills on how to help patients and their loved ones with advance care planning and palliative care, also has VNAA’s support. The bill establishes a demonstration project to reimburse eligible entities for expenses related to the use of telemedicine services to provide advanced care planning.

The last bill VNAA plans to advocate for—Removing Barriers to Person-Centered Care Act of 2016 (S. 3096)—would test a shared savings payment model in as many as 20 “advanced care collaboratives” to deliver coordinated, person-centered care to Medicare beneficiaries with advanced illnesses. Each collaborative would receive a planning grant to perform a needs assessment; upgrade, change or buy health information technology; and support training and education on documenting and communicating beneficiary treatment goals and preferences. As part of the pilot program, the Secretary would waive specific Medicare payment regulations and rules, as well as cover two new services under the hospice benefit.

*Editor’s note: This article has been updated from a previous version, which incorrectly stated that VNAA plans to lobby Congress. In reality, VNAA plans to educate Congress and advocate on behalf of these aforementioned issues, not lobby for them.

Written by Mary Kate Nelson

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