Excellent point!

 

 

Good morning. I agree with all these comments. The only thing I would add is something about rural health clinics only having and MD 1x week in some locations and NP’s are the primary providers in many of these instances and the MD’s are not readily available to sign orders, collaborate with, etc.

Thanks

Kay

 

 

Good Morning – Thanks Vickie - see comments below! 

 

 

Karen-

 

Here are some of the talking points off the top of my head, but I haven’t really had time to think about more. If I come up with any more items, I’ll send your wayJ

 

• First of all, are we asking CMS to allow NPP’s (non physician practitioners- CNP, CNS, PA) to sign orders OR certify home health, or both? Of course, the preference would be both J I agree – we need NPP to do both!
• NP’s, but not PA’s, are allowed to practice independently in our state (and others). If a beneficiary has an NP as their primary provider, the home health agency needs to work with the clinic and the patient to identify a physician for that patient. Often times, this process leads to a delay in providing care, and in some instances, a patient cannot receive home care if the physician refuses to be the attending physician. Also, when a physician does agree to be the certifying physician for the patient, but they are not as familiar with the patient as the CNP is, the continuity of care  for that patient is disrupted while the patient is receiving home care services because the CNP is not directing the cares. Truth!
• In many other health care settings, a nurse practitioner and PA can be the attending provider- including hospice.  Also very true! We need consistency with the rest of the American health systems. Very common to have a PA or NP as the PCP. CMS should encourage licensed professionals to work at the top of his/her license.
• It is more cost effective to have nurse practitioners, rather than physicians, certify and write orders for home care patients. Yes
• NP’s can perform a F2F assessment, but a physician has to certify that it took place. That is an illogical requirement and it can delay reimbursement to the home health agency. In some cases, this can also delay care to a patient. Also agree, and also may lead to denial of claim if the physician won’t certify that the F2F took place – pretty sure this has happened once or twice around here.

 

 

 

 

Hi Workgroup Members  –

 

MHCA will submit a comment to CMS on our support of allowing APRNs and PAs to write home care orders.  Kathy has asked that I coordinate with you, as representatives of the Medicare/CMS/NGS Workgroup, to write a draft comment letter, to make sure we hit all the salient points.  I’d like to get the draft done by Friday January 3 so Kathy has time to review it, and then we are potentially going to ask some additional associations to sign on with us. It’s all due to CMS by 1/17.

 

Could you each send me a list of the key talking points that we would want to include, and I will massage them into a letter? I’ll send it back to you before giving it to Kathy …. So I guess I need your comments by end of day on the 2^nd so I can get the letter done by end of day on the 3^rd.

 

I know it’s not much time – I appreciate whatever you can offer!

 

Thanks,

Karen

 

 

 

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