Rogers: PDGM’s 8% Cut ‘A Double Slap in the Face’ to Home Health Providers

While home health advocacy efforts are routinely focused on national policies, state-level organizations often help pave the way. Among them is the Association for Home & Hospice Care of North Carolina (AHHC-NC), led by industry veteran Tim Rogers, its president and CEO.

With the Patient-Driven Groupings Model (PDGM) and the Review Choice Demonstration (RCD) on the horizon, the first nine months of 2019 have been particularly busy for Raleigh-based AHHC-NC, according to Rogers, who also serves as chair for The Council of State Home Care & Hospice Associations.

Understandably, PDGM has largely taken priority for the AHHC-NC decisionmaker — specifically the model’s widely opposed behavioral adjustments, a “double slap in the face to home health providers” that could pose an 8% cut right off the bat.

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HHCN recently caught up with Rogers to learn more about his organization’s approach to PDGM advocacy. Apart from PDGM, Rogers also touched on the implications of a hospice carve-in under Medicare Advantage (MA) and ongoing changes to the home health rural add-on program.

Highlights from that conversation are below, edited for length and clarity.

In addition to his role at AHHC-NC, Rogers also serves in a leadership position at the South Carolina Home Care & Hospice Association, which is managed by AHHC-NC.

HHCN: You serve in a few different leadership roles. Can you tell me a little bit about AHHC-NC, SCHHA and The Council of State Home Care & Hospice Associations?

Rogers: The Association for Home & Hospice Care of North Carolina is one of the oldest and largest state home care, home health and hospice organizations in the country. We have 98% penetration of home health members in the state and 98% penetration of hospices as well.

We also represent home care, meaning Medicaid home care and private-duty. We have roughly 774 members in our association.

That really high penetration rate for home health and hospice, though, gives us a really good idea of what’s going on in the industry. It’s a really good barometer. A lot of the associations out there have a bit of a revolving door when it comes to home care [membership].

What about SCHHA and the council?

AHHC-NC manages the South Carolina Home Care & Hospice Association — it has for about 15 years. But it’s its own association bylaws, its own board of directors. SCHCHA has about an 85% penetration in home health and a 65% penetration in hospice.

The Council of State Home Care & Hospice Associations was formed in 2005. We are a 42-state organization. It’s an independent organization of state associations and executives. For lack of a better word, there’s no parent — we’re not controlled by any other groups.

We’ve grown to become a very powerful council of state associations, working in tandem with others, including the Partnership for Quality Home Healthcare (PQHH).

As a leader of these organizations, what are you top two or three near-term priorities?

For AHHC-NC, we’re in a parallel track. We’re preparing our members diligently for the Review Choice Demonstration (RCD). We don’t know if we’re next after Ohio — or whether it’s going to be Texas or Florida. But we’re preparing as if we’re next.

And everyone, including us, is frantically preparing for PDGM.

On the hospice front, we’re preparing our members to implement new change included in the new hospice rule. We’re also guiding members as to what a benefit would look like should hospice become a part of Medicare Advantage (MA). That has become somewhat of a divisive issue on the national stage.

RCD seems to sometimes fall to the backburner. How disruptive do you think that could be if it does make its way to North Carolina?

The main disruption would be the timing of implementation, if it comes around Jan. 1, 2020 with PDGM at the same time. However, North Carolina only has 208 Medicare-certified home health agencies, compared to Ohio, Texas and Florida, which has more. Ohio has around 800 while Texas and Florida have several thousand agencies.

I’m still baffled that North Carolina was even in RCD to begin with.

I co-chair the Palmetto GBA, 16-state home health and hospice coalition. I’m privy to the state data. I still question why North Carolina was included — but that train has left the station.

To prepare, we’ve brought down providers from Illinois, providers who have achieved a 100% affirmation rate. I will tell you, I do believe my 208 providers are as ready as they can be for RCD, but the problem really is the simultaneous approach with something so monumental — PDGM. It’s just so unfortunate.

There have been a lot of mixed opinions regarding the hospice carve-in. Where do you stand?

I’m speaking on behalf of my hospice members. And I’m speaking on behalf of the fact I represent 98% of hospices in North Carolina and the majority in South Carolina — one of the largest state associations in the country.

They have told me they’re very concerned about a hospice carve-in under Medicare Advantage. All they need to do is look closely at what has happened with their brethren in home health.

It has some potential advantages, but the thinking is the disadvantages could outweigh those. It’s a wait-and-see.

Home health has had a very rocky relationship with Medicare Advantage. It’s not only getting paid. It’s getting visits approved and patients seen, taken care of. That can’t happen when you’re talking about end-of-life care. Waiting on the phone to get a visit approved is not quality patient care.

You recently wrote an opinion piece in The Hill highlighting your biggest PDGM concerns. What’s specifically keeping you up at night with that overhaul?

CMS continues to apply and treat home health to a double standard compared to our friends in the skilled nursing community or acute-care settings. For them to reject payment assumptions in skilled nursing but allow them in home health — to claim they have to make them — is disingenuous. It’s almost hypocritical.

Right off the bat, we’re stuck with a potential 8% payment cut in 2020. At some point, there has to be fairness from CMS. But it really seems like time and time again that home health is not treated with that sense of fairness.

We all know that MedPAC has its axe to grind in home health. But we and other home health leaders meet with CMS repeatedly, we respond to their rulemaking with toons comments, yet this continues to seemingly fall on deaf years.

And we almost have 100 co-sponsorships in the House and about 25 in the Senate. That’s nothing to sneeze at. I’m talking about, of course, the legislation we’ve introduced to correct the wrongs CMS has done.

You mentioned that 8% cut. That’s the estimated impact of the behavioral adjustments included in the July 11 proposed payment rule — more than the 6.42% in last year’s rule.

It’s a double slap in the face to home health providers. At some point, you can’t speak out of both sides of your mouth. You can’t say home health is where it’s at, we need more home health providers out there … but then actually double down on these behavioral adjustments.

When you have an 8% cut, you’re going to put a large portion of providers out of business — especially in the rural South and in frontier areas. Is that what CMS wants on its hands?

Because rural providers are also dealing with changes to the rural add-on, right?

Exactly. I have a lot of rural providers in my state — all the way from the Outer Banks to the Islands in the southeastern portion of the state and the rural areas of Appalachia. I’ve got providers that have to drive up mountains and take ferries to get to patients.

Do you think Congress is ultimately going to listen to your concerns?

They are listening to us. Various caucuses are listening. The PDGM legislation is strong, bipartisan legislation. Look at the leaders. And they’re sending a message to CMS.

You worked in the industry. You currently help lead advocacy efforts. But you also have ongoing, personal ties to home health, correct?

Yes. I do. I am a caregiver to a wonderful 91-year-old mother who is a retired nurse. My 88-year-old father is also a caregiver. My mom recently suffered a heart attack, and she’s the recipient of both phenomenal home health care and private-duty home care.

She just finished her first two rounds of her home health plan of care. It was simply phenomenal. I’ll even tell you the agency: It was Duke Home Care. They were great. She’s recovering wonderfully.

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