LeadingAge’s Home Health Member Network met on April 5, 2022, to discuss the Medicare Home Infusion Therapy benefit and health equity issues in home health as well as updates on national legislation and regulation policy.

Medicare Home Infusion Therapy Benefit

LeadingAge was approached by contractors for the Centers for Medicare and Medicaid Services (CMS) regarding the Home Infusion Therapy benefit in Medicare. Home health members discussed barriers to become a provider of this benefit including the limited reimbursement for staff time, the difficulty in accessing drugs for infusion without a pharmacy partnership, and the limitations of comprehensive care for patients. Many members shared that they currently work with home infusion companies through contractual relationships and those are often better collaborations than the home infusion benefit. Members also shared that more education on the benefit was needed for providers including how Part B billing factors in and how assessments like OASIS are utilized.

Health Equity

CMS and the Center for Medicare and Medicaid Innovation (CMMI) are increasing their focus on health equity across the continumm. Recent proposed rules in hospice identified specific quality measurement development activities and similar efforts will most likely be including in the home health proposed rule this summer. Providers discussed the unique health equity issues faced by beneficiaries accessing home health. A critical health equity issue identified were individuals who did not have family caregivers to support them at home. Overall, providers felt home health staff were well trained on cultural differences in their respective communities and found that families were often a big help in building trust with patients. A major issue that was echoed by many providers was the inconsistency between Medicare Advantage plans authorization of home health services. Many felt that patient care was the most important consideration, and they would take on patients prior to authorizations to make sure they received necessary care. Many others shared delays in prior authorization processes at plans meant patients went without needed wound or infusion care sometimes leading to unnecessary hospitalizations.

Policy Update

LeadingAge Leadership Summit: At the LeadingAge Leadership Summit in March, members of CMMI’s Home Health Value Based Purchasing team provided a presentation on the program’s expansion. Data collection will start in January 2023 that will impact CY 2025 payment adjustments. After the meeting, CMMI updated their FAQ’s to reflect information shared during the presentation.

Choose Home Care Act: During the Leadership Summit, Alex Graf, the Democratic Staff Director of the Senate Finance Committee’s Subcommittee on Health Care, shared that they are pursuing a Congressional Budget Office (CBO) score for the Choose Home Care Act. If CBO determines the bill will save money, it has a higher likelihood of moving forward in Congress. Additionally, advocates are working hard to get more co-sponsors for the legislation.

Home and Community-Based Services Funding: While the original Build Back Better legislation stalled earlier this year, there is continued interest in moving a legislative package which includes additional funding for Medicaid home and community-based services. These funds would include money for the direct care workforce. Work on this package will begin after the April holidays.

Mental Health Legislation: The coordinated effort in both houses of Congress to create comprehensive mental health legislation has continued including several committee hearings on key mental health issues like suicide. There is a specific effort on workforce mental health and the Senate Finance Committee is looking for information from the provider community on solutions.

COVID Relief: More COVID relief is under negotiation. The current package is $10 billion in additional aid including therapeutics, testing, and vaccines.

Notice of Admissions Update: Notice of Admissions (NOA) which replaced the Request for Anticipated Payments (RAPs) launched in January 2022 with mixed success. Last month, CMS issued a change order to the Medicare Benefit Policy Manual to clarify the NOA process, establish the requirements for NOA submission, and clarify the definition of allowed practitioners. An MLN article was also issued to review the changes and expectations for the new NOA process. The process will be fully implemented by May 26, 2022.

CMS Home Health, Hospice, and DME Open Door Forum: CMS will host an Open Door Forum on Thursday, April 20 from 2:00 – 3:00 PM ET for Home Health, Hospice and Durable Medical Equipment (DME) providers. To participate by phone: Dial: 1-888-455-1397 & Reference Conference Passcode: 5109694.