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


Home health stakeholders – and plenty of others – recently had the chance to weigh in on the way in which 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 many two groups that answered CMS’ request for information.

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

“The importance is that CMS is starting to judge the plans more closely when it comes to provider relations and approaches to health care delivery for enrollees and the way the plans can improve health care services for these beneficiaries,” Mary Carr, vp of regulatory affairs at NAHC, told Home Health Care News in an email.

Broadly, the comment period gave home health stakeholders the chance to affect potential future rulemaking on various features of the MA program. That is notable because Medicare Advantage enrollment continues to grow — having greater than doubled during the last decade.

In actual fact, Medicare Advantage has 28.4 million beneficiaries, or 45% of the Medicare population. By 2030, Medicare Advantage is anticipated to have over 52% of total Medicare enrollment, in accordance with data from the research and advocacy organization Higher Medicare Alliance.

With enrollment on the rise, it’s likely that providers will change into much 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 within the organization’s comments to CMS.

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

This comment period can be significant since it gives home health stakeholders the ground to share their standpoint. Prior to now, providers have been vocal concerning 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 of their comments.

“[Providers] proceed 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 fee of care in lots of plans. With the growing proportion of home health patients enrolled in MA, that level of reimbursement jeopardizes the power of the HHA to proceed to operate.”

Overall, NAHC addresses the questions that CMS lays out while offering recommendations. To be able to ensure that each one enrollees receive the care they need, NAHC suggests that CMS concentrate on language.

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

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

“Much of the data provided to the general public regarding MA plans is misleading when it comes to the constraints of MA plans and advantages of selecting traditional Medicare,” the organization wrote. “Plans ought to be required to make use of uniform content and display format in describing advantages and

cost inside each plan. For instance, CMS should require the plans to make use of side-by-side

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

NAHC also noted that there’s confusion amongst beneficiaries in relation to what the person MA plans offer.

“Enrollees may consider they’re required to decide on an MA plan for his or her Medicare advantages,” NAHC wrote. “All MA plan marketing ought to be subject to CMS approval for accuracy and comprehensiveness and celebrity endorsement or promotions ought to be prohibited. All MA plan marketing should include a reference regarding an choice to enroll in traditional Medicare and include information as stated within the previous response.”

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

“The scope could concentrate on certain specialties where in-home care is suitable or on specific patient populations who may profit essentially the most from in-home care equivalent to high-cost, high-need patients,” the organization wrote. “The present process for requesting an exception to network adequacy requirements should remain for those plans who’re unable to supply in-home care, or who consider it’s inappropriate for his or her 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 which have certificate of need laws,” Moving Health Home wrote. “The telehealth and the CON credits might be combined together to scale back the proportion of beneficiaries which might be inside the maximum time and distance requirements. Under this selection, CMS could replicate one or a mix of those policies to encourage MA plans to cover in-home services.”

Along with this, NAHC identified the necessary role telehealth played in home health care through the public health emergency.

“The worth of telehealth will proceed even after the PHE ends and can likely remain an important tool for HHAs that provide care in the house to vulnerable populations,” the organization wrote. “Telehealth ought to be equally available as a profit under MA Plans and traditional Medicare because it brings value to enrollees and improves access, especially for the homebound.”

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

“We also hope that beneficiaries are fully informed of the differences within the offerings between the plans and traditional Medicare,” Carr said. “Further, we hope that the plans recognize home health care as a crucial, if not mandatory, 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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