National Association of ACOs Calls for Wider Use of Home Health, Looser Requirements

The National Association of Accountable Care Organizations (NAACOS) is calling on the Center for Medicare & Medicaid Services (CMS) to loosen home health requirements for new Medicare alternative payment models. In doing so, ACOs will be able to better deliver care and save money, the association argued in a letter to CMS’s Innovation Center.

“More freedom to use skilled home care services could help patients receive care in a setting they choose while aiding [direct contracting entities] (DCEs) in controlling costs,” NAACOS wrote.

The letter came in response to a request for input from CMS’s Innovation Center, following the release of its direct contracting model — participants of whom will be known as DCEs.


The direct contracting model is essentially another name for the ACO model, which consists of a collaborative group of health care providers and may include home health organizations. For both models, the goal is to improve patient outcomes and cut costs.

The direct contracting model outlines three voluntary risk-sharing payment options for DCEs to do that. In turn, CMS will tie a meaningful percentage of the targets to performance on quality of care for participants.

Among other changes, NAACOS recommended CMS make it easier for patients in the model to receive home health treatment.


“Increased use of care management home visits, in conjunction with broad use of post-discharge home visits, would provide important tools to manage ongoing needs of high-risk beneficiaries in transitions of care,” NAACOS wrote.

Specifically, NAACOS recommended CMS loosen homebound and certification requirements.

“Beneficiaries should be not be denied the acute need for skilled home care services at a level consistent with current home health standards simply because they are able to leave the home,” NAACOS wrote. “There are many examples of patients forced into acute care stays, prolonged SNF stays and other inpatient alternatives simply because they did not qualify as ‘homebound.’ We urge the Innovation Center to remove the homebound-status requirement and allow DCEs to more broadly use home health.”

Additionally, the association advocated for non-physician certification of home health services.

Home health industry stakeholders have also targeted the homebound requirement in recently introduced legislation, both in the House and Senate.

Additionally, lawmakers introduced the Care Planning Improvement Act of 2019 in April. If passed, the legislation would allow physician assistants, nurse practitioners and other advanced practice nurses to certify home health care services moving forward.

“Recognizing the shift of care management to advanced practitioners, the home health benefit enhancement should allow advanced practitioners to certify the need for home health both with and without homebound status as long as the practitioner is part of the participant or preferred provider list,” NAACOS wrote.

The application period for the direct contracting model opens later this year and will be available starting in 2020 for an alignment year. Performance periods will begin January 2021 and last five years.

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