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TAHC&H Goes to Washington

By Becky Campbell posted Sep 17,2018 11:46 AM

  

TAHC&H Executive Director, Rachel Hammon, TAHC&H Board President Jon Scepanski, TAHC&H Treasurer Dana Madison and members Luke James (Encompass) and Marcylle Combs (Accent Care) headed to Washington DC to advocate for issues of importance to Home Health and Hospice this week.  Dana, Rachel and Luke started the week at the Home Care Council’s Policy Summit where many speakers from CMS, the Medicare Administrative Contractors, Bill Dombi and other industry leaders discussed issues such as the current political landscape, home health market trends, value based purchasing, PDGM, TPE and RCD. 

One of the liveliest discussions was around PDGM and RCD.  Key CMS staff announced the start of RCD would be delayed until December 2018.  Despite the delay, summit attendees were able to express their concerns over the re-start of this demonstration and the unnecessary burden it presents for home care agencies.  The primary points of discussion around PDGM were concerns related to the behavioral adjustments, payment changes that go beyond the legislation and the timing of the rule to which CMS responded that the legislation required a start date of 2020 and the implementation of the behavioral adjustments.  Members of the audience quickly reminded CMS that the law does allow flexibility with the start date, stating the payment change should occur “on or after 2020” and that the behavioral adjustments should be based on actual behavior rather than assumed behavior in a budget neutral fashion. 

On Wednesday, TAHC&H started the day very early in Baltimore Maryland at a meeting directly with CMS at their headquarters to discuss the proposed rule (PDGM), RCD and the phase down of the rural add – on.   The CMS meeting attendees included key personnel from the Chronic Care Policy Group (CCPG) and Center for Program Integrity (CPI).  CCPG is the department in charge of developing the rule and reviewing all of the comments, while CPI is in charge of the demonstration project.  While CMS is not allowed to discuss how they intend to address the rule or comments, the directors in each area gave us a full hour of discussion.  They listened to industry concerns, asked detailed questions in order to better understand our concerns and how the rule as written would impact Texas agencies.  They listened to our suggestions and committed to review all of the industry comments (over 5000 on PDGM and 500 on RCD).  We were invited back to continue to work with them after the rule was finalized in case additional clarifications might be needed.  This is a significant change from the CMS of the past 8 years.  We appreciate the open door and opportunity to give helpful feedback as they work through the rule making and future implementation process. 

After the meeting the TAHC&H President and Treasurer accompanied the TAHC&H ED back to DC for legislative visits the rest of Wednesday and on Thursday.  We had many fruitful meetings with key committee and legislative staff advocating that they weigh in with CMS on congressional intent related to the PDGM, look for legislative solutions to fix the Rural add on phase down and stop RCD.   We left DC with some good follow up with legislative offices to advance these priorities.   Thank you to your board leaders and member colleagues for utilizing their own resources to go to DC and speak on behalf of the industry, we appreciate your time and dedication.  We will keep you updated on the progress of these issues as they unfold so keep an eye on future Perspectives

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