Home Health Stakeholders Voice Their Concerns To CMS Over Medicare Advantage Program

Home health stakeholders – and many others – recently had the opportunity to weigh in on the way Medicare Advantage (MA) is currently administered by the U.S. Centers for Medicare & Medicaid Services (CMS).

The National Association for Home Care & Hospice (NAHC) and Moving Health Home are among the two groups that answered CMS’ request for information.

In July, CMS released that request for information seeking public comment on the MA program. Comments were to be submitted by Aug. 31, 2022.


“The significance is that CMS is beginning to evaluate the plans more closely in terms of provider relations and approaches to health care delivery for enrollees and how the plans can improve health care services for these beneficiaries,” Mary Carr, vice president of regulatory affairs at NAHC, told Home Health Care News in an email.

Broadly, the comment period gave home health stakeholders the opportunity to affect potential future rulemaking on various aspects of the MA program. This is notable because Medicare Advantage enrollment continues to grow — having more than doubled over the last decade.

In fact, Medicare Advantage has 28.4 million beneficiaries, or 45% of the Medicare population. By 2030, Medicare Advantage is expected to have over 52% of total Medicare enrollment, according to data from the research and advocacy organization Better Medicare Alliance.


With enrollment on the rise, it’s likely that providers will become even more entangled with health plans offering Medicare Advantage. And as this happens, it’s the responsibility of providers and plans to work together, NAHC President William A. Dombi wrote in the organization’s comments to CMS.

“It is imperative that the [MA] plans and the provider community work together to ensure patient-centered, high quality health care is provided to all beneficiaries,” he said.

This comment period is also significant because it gives home health stakeholders the floor to share their point of view. In the past, providers have been vocal about the challenges surrounding MA.

Specifically, providers have struggled with receiving fair rates for the services they deliver. NAHC took the time to directly address this in their comments.

“[Providers] continue to struggle with the payment structures and payment rates for care

by the MA plan,” NAHC wrote. “MA plan reimbursement for home health services is below the cost of care in many plans. With the growing proportion of home health patients enrolled in MA, that level of reimbursement jeopardizes the ability of the HHA to continue to operate.”

Overall, NAHC addresses the questions that CMS lays out while offering recommendations. In order to make sure that all enrollees receive the care they need, NAHC suggests that CMS focus on language.

“All communications with enrollees, including service/claims determinations, should be in plain language using the medium of language best understood by the specific enrollee,” NAHC wrote.

In its comments, NAHC also criticized the misinformation surrounding MA.

“Much of the information provided to the public regarding MA plans is misleading in terms of the limitations of MA plans and benefits of choosing traditional Medicare,” the organization wrote. “Plans should be required to use uniform content and display format in describing benefits and

cost within each plan. For example, CMS should require the plans to use side-by-side

comparisons for cost sharing, utilization data and how provider networks differ from traditional Medicare.”

NAHC also noted that there is confusion among beneficiaries when it comes to what the individual MA plans offer.

“Enrollees may believe they are required to choose an MA plan for their Medicare benefits,” NAHC wrote. “All MA plan marketing should be subject to CMS approval for accuracy and comprehensiveness and celebrity endorsement or promotions should be prohibited. All MA plan marketing should include a reference regarding an option to enroll in traditional Medicare and include information as stated in the previous response.”

On its end, the Washington, D.C.-based advocacy coalition Moving Health Home believes that CMS should urge MA plans to provide access to in-home care through the network adequacy standards.

“The scope could focus on certain specialties where in-home care is appropriate or on specific patient populations who may benefit the most from in-home care such as high-cost, high-need patients,” the organization wrote. “The existing process for requesting an exception to network adequacy requirements should remain for those plans who are unable to offer in-home care, or who believe it is inappropriate for their patient populations.”

Moving Health Home also suggests that CMS replicate the MA telehealth bonus.

“CMS now provides a 10-percentage point credit towards meeting time and distance standards for affected providers in states that have certificate of need laws,” Moving Health Home wrote. “The telehealth and the CON credits can be combined together to reduce the percentage of beneficiaries that are within the maximum time and distance requirements. Under this option, CMS could replicate one or a combination of these policies to encourage MA plans to cover in-home services.”

In addition to this, NAHC pointed out the important role telehealth played in home health care during the public health emergency.

“The value of telehealth will continue even after the PHE ends and will likely remain an essential tool for HHAs that provide care in the home to vulnerable populations,” the organization wrote. “Telehealth should be equally available as a benefit under MA Plans and traditional Medicare as it brings value to enrollees and improves access, especially for the homebound.”

Ultimately, NAHC hopes that CMS will ensure there is uniformity of coverage for home health services among Medicare Advantage plans and traditional Medicare.

“We also hope that beneficiaries are fully informed of the differences in the offerings between the plans and traditional Medicare,” Carr said. “Further, we hope that the plans recognize home health care as an important, if not necessary, step along the care continuum in ensuring that beneficiaries obtain their maximum level of health and avoid unnecessary health care costs.”

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