Agree, we should follow VNAA’s lead on requesting guidelines before a implementation date is established. Seems reasonable.
From: Susan Morgan [mailto:susanmorgan@accracare.org]
Sent: Tuesday, February 28, 2017 8:46 AM
To: mhcabod@list.mnhomecare.org
Subject: RE: ED Update and seeking input
Reaching out to the delegation makes sense to me, as well. I would agree with Jay’s suggestion, to request support for the VNAA approach and let them know that a July implementation
date is just too soon to expect agencies to be in full compliance with these new COPs.
Susan Morgan, RN, BSN
| Compliance Director
Office:
952-935-3515 | Fax:
952-935-7112 | Cell: 952-388-9043
1011 1st Street South #315
Hopkins, MN 55343
Email:
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www.accracare.org
Alexandria | Bemidji | Brainerd | Duluth | Fergus Falls | Grand Rapids | Hopkins | Lake City | Moorhead | New Ulm | Red Wing
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From:
mhcabod@list.mnhomecare.org [mailto:mhcabod@list.mnhomecare.org]
On Behalf Of Hespe, Linda J
Sent: Tuesday, February 28, 2017 8:34 AM
To: mhcabod@list.mnhomecare.org
Subject: RE: ED Update and seeking input
I don’t think it would hurt to reach out to the congressional delegation. In our area last week Amy Koublekar (sorry spelled that wrong) and Collin Peterson
were visiting our campus finding out what their constituents feel that needs to be supported when they start changing the ACA. I believe they were going to other areas also. Rep Peterson said his point was that when the Republican delegation looks for some
bi-partisan support, he wants to be ready with what his constituents want. Good point I thought.
Linda
From:
mhcabod@list.mnhomecare.org [mailto:mhcabod@list.mnhomecare.org]
On Behalf Of Kathy Messerli
Sent: Tuesday, February 28, 2017 8:26 AM
To: mhcabod@list.mnhomecare.org
Subject: Re: ED Update and seeking input
I should clarify what I meant by support - I was wondering whether we want to reach out to our congressional delegation with a request/position.
From:
mhcabod@list.mnhomecare.org <mhcabod@list.mnhomecare.org> on behalf of Jay <Jay@shhcare.us>
Sent: Monday, February 27, 2017 1:26:45 PM
To: mhcabod@list.mnhomecare.org
Subject: RE: ED Update and seeking input
Regarding your question on CoPs,
1. Although I’m not exactly sure what “support” means, it seems supporting the New York – sponsored bill would do no harm. I think a
legislative solution is unlikely to get any traction in DC because -
·
July 2018 is an unreasonably long postponement. More than 16 months? Seriously?
·
Congress has lots on their plate right now
·
They have way bigger Obamacare/Medicare/Medicaid issues
·
Most of them have no idea what a CoP is
2. The NAHC delay to January 2018 is more reasonable, but CMS is historically unwilling to delay their brainchildren, even the ugly ones
3. I think a hybrid of the VNAA approach makes the most sense – require that the Interpretive Guidelines be released by March 31, 2017,
and that the CoPs become effective 9 months after their release.
·
CMS won’t like a 10 month delay, but they understand how the linkage between their IGs and the CoPs ensures that things get implemented the way they intended
·
If provider agencies will need more time to get their head around the new CoPs, so will the entire CMS enforcement infrastructure (fiscal intermediaries, RACs, ZPICs, pre-claim
reviewers, ADR reviewers, et. al.)
·
One of the 3 or 4 people in congress who actually know what a CoP is can informally ‘encourage’ CMS to accept this reasonable compromise. No legislative action is required.
4. Although the Medicare Team’s recommendations are more targeted (and more thoughtful), I think they would be unattractive because they
are more confusing (exactly which requirements are
effective on
what dates?) and harder to implement (and enforce), given the large enforcement infrastructure that CMS relies on (referenced above).
Jay
From: Kathy Messerli [mailto:kmesserli@mnhomecare.org]
Sent: Saturday, February 25, 2017 09:34
To: mhcabod@list.mnhomecare.org
Subject: ED Update and seeking input
February has been filled with activity; so much so that my “brief” update is long today!! I hope you don’t miss the operational updates at the end of the lengthy advocacy updates!
Federal Advocacy
CoPs
I would welcome advice from the board on what action, if any, MHCA should take regarding the CoP Implementation. Three different strategies are occurring across the nation: New
York State association has received the support of GOP Congressman John Faso, who has drafted legislation to delay the CoPs until July 2018. They are asking us to seek support from our delegation. NAHC sent a letter to CMS, requesting a delay until January
2018 and VNAA, after seeking input from their members has decided to request the Interpretive Guidelines be released by early March – or delay the CoPs. The MHCA Medicare Team recommended that the following components be delayed and that the implementation
date should be staggered for the various components:
- Comprehensive Assessment
- Assure communication & integrate orders with ALL docs involved in POC
- Implement Official Infection Prevention Program
- Organization of Administration/Governing Body
** Do you advise we remain silent or support one of these initiatives?
Emergency Preparedness
We have confirmed that providers need to be prepared to meet the CoP Emergency Preparedness requirements in July vs the November Emergency Preparedness implementation date (although
I understand that the November requirements are more stringent).
State Advocacy
Our 3 priorities have multiplied! I am in continual communication with Kevin and providing direction on our priorities vs monitoring – but those lines are a bit blurry for several
items. Below is a high level overview of the top issues affecting providers as of today; I have included more information for the bills that are new to my ED Updates. I hope to see most of you at the Day at the Capitol – our voices are essential with all of
the issues facing home care!!
Electronic Visit Verification (HF 1649 Haley)
Link to bill: House
MHCA has now introduced the bill that directs the state to move forward with developing an electronic visit verification system to be in compliance with new federal regulations.
The bill directs DHS to bring together a stakeholder group to help produce a report with recommendations for how to move forward by January of 2018. Fiscal Note: $230,000
MA Face to Face Legislation (HF 1532 Zerwas)
Link to bill: House
DHS had created language for MA F2F but because it's in the Governor's budget, it was unclear whether it was going to be heard. So, MHCA proactively drafted language and
incorporated our desired changes to the Governor's Face to Face Requirement legislation. We included language that managed care plans and county-based purchasing plans must not require face-to-face encounter requirements for home health services provided under
medical assistance managed care. Kevin has communicated with DHS but they have not yet requested a meeting to address our differences. Fiscal Note: $140,000
Raising of the Medical Assistance Spenddown Income and Asset Limits
Link to bill: House and
Senate
This bill was heard on 2/13 in the Senate Human Services Reform Committee and was laid on the table for further discussion once a fiscal note becomes available.
Best Life Alliance Bill
Link to bill: House and
Senate
This bill was heard in the Senate Human Services Reform Committee and the House Health and Human Services Policy Committee. There was an amendment brought forward by the
counties to address concerns they have about how the wage increase would work for a select number of county run service settings. The unions have some concerns about this amendment so the counties and the unions will work over the coming weeks to try to find
compromise. In the Senate, the bill was then laid on the table to be brought back up when further information on the cost of the proposal is presented in the fiscal note from DHS. In the House, the bill was passed out of committee and on to the House Health
and Human Services Finance Committee.
Certified Paraprofessional - We joined a group of stakeholders in meeting with PHCC and are
awaiting further communication from PHCC.
Hearing Loss Care Requirements (HF 952 Kiel; Allen; Baker; Murphy, E.; Theis / SF 818 Housley;
Abeler; Eken; Lourey; Relph)
Link to bill: House and
Senate
We were just approached today regarding bill amendment which will be heard Weds. The amendment requires home care to provide staff training on hearing loss care. We have
indicated that generally, we are supportive of person-centered training that fits the needs of the individual being served, but are concerned with broadly mandated training on specific needs. Kevin has been invited to a stakeholder meeting Monday to address
this bill amendment.
Office of the Legislative Auditor Report on Financial Oversight of HCBS Services
A recently released report (www.auditor.leg.state.mn.us) includes recommendations related to DHS’s activities overseeing
service delivery for HCBS services. Of concern is a recommendation that home health aides and homemakers register with the state, have limitations on hours billed and increased documentation. If DHS is going to expand the UMPI number requirement, they need
to provide a plan on how they are going to meet the requirement for processing them in 30 days. Validating that services are being provided via phone calls was mentioned. It appears to me that they are not familiar with the fraud reduction measures that are
currently in place and certainly not familiar with EVV. I've indicated to Kevin that we should use the opportunity to inform & educate.
Requiring State Uniformity for Employment Mandates (SF 580 Miller; Benson; Gazelka; Housley;
Rosen / HF 600 Garofalo; Albright; Anderson, P.; Backer; Baker; et al.)
Link to bill: House and
Senate
This preemption bill would prevent local initiatives around employment mandates (requirements related to sick leave, minimum wage, etc...) from being implemented.
An MDH initiative would require
hospices to give a 30 day discharge notice when the patient no longer qualifies for hospice. MNHPC is taking the lead on this but I’ve asked Kevin to weigh in, if possible as the network doesn’t have a lobbyist.
DHS’
S.F. 1291 is being heard Monday; this bill includes new
documentation and billing requirements
for all waivered service. MHCA had weighed in previously, along with many other stakeholders, indicating that the
proposed language is overly prescriptive and problematic. DHS doesn’t appear to have made any changes in their language.
We are participating in a stakeholder meeting prior to the hearing and AARM will be testifying on behalf of the group.
There are various
workforce related bills that include options such as loan forgiveness, employee scholarships, innovation grants, and funding for educational materials that increase awareness of career opportunities available in senior care.
There are a couple of bills that require a report on Resource-Based Relative Value System and Alternate Payment Methodologies, which may provide additional information of
our payment reform discussions.
Operational
In addition to keeping up with the various advocacy issues, staff is busy with membership renewals, recruitment, Day at the Capitol and Annual Meeting planning! Mandy hit the ground
running and has accomplished a great deal in her first month!
The Membership Team reviewed the ‘all of none’ membership questions and has a recommendation for the board’s consideration at the March meeting.
We will be reviewing the teams/workforce structure at the March meeting. Please give some thought as to how MHCA should best approach covering increasing health plan issues, payment
reform and workforce challenges, with the resources at hand.
Kathy Messerli
Executive Director | Minnesota HomeCare Association
2550 University Ave. W., Ste. 350 S | St. Paul, MN 55114-1900
Direct: 651.635.0038 | Main: 651.635.0607
Toll-free: 866.607.0607 | Fax: 651.635.0043
www.mnhomecare.org
| kmesserli@mnhomecare.org
Mission:
MHCA represents and supports Minnesota home care providers committed to high quality home care services.
Vision:
MHCA will shape the home care landscape to improve and sustain quality home care services.
MHCA supports the
Best
Life Alliance.