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1. Admission of Medicare Patients in Home Health

Dobson DaVanzo & Associates, LLC has been commissioned by the Home Health Advocacy Coalition to identify the current process home health agencies use for the admission of Medicare patients in home health and investigate how the proposed home health benefit and payment changes set forth in the recently proposed rule may impact the patient access to home health.

We understand that to be eligible for Medicare's current home health benefit, the patient's attending physician must certify that the beneficiary needs intermittent skilled nursing care or physical therapy or speech language pathology and is essentially confined to the home. Under the proposed rule, patients are required to have a face-to-face encounter with the certifying physician within 30 days prior to, or 14 days following, the start of home health care. A qualifying face-to-face encounter with a physician must relate to the primary reason the patient requires home health care.*

The proposed rule also provides that therapy patients requiring 13 or 19 therapy visits require a reassessment by a qualified therapist before any more therapy visits are covered in their episode. This is to ensure that patients receiving therapy continue to remain eligible for the benefit and receive effective care.**

Dobson DaVanzo is surveying several home health providers to determine the effect these changes will have on patient access to home health. To facilitate the completion of this questionnaire, we encourage you to consult with individuals across your organizations, such as financial officers, clinical managers, hospital discharge planners, and home health nurses. Your responses will be used to better express to CMS and Congress how these changes may affect patients' access to home health. All results will be held confidential - only aggregated, unidentified results will be presented in either written or oral form.

The questionnaire is divided into two main sections: 1) Current Medicare Home Health Care Benefit and 2) Future Implementation of Proposed Medicare Home Health Benefits.

If you have any questions or comments regarding this questionnaire, please contact Audrey El-Gamil at Dobson DaVanzo at 703.260.1764 (direct); 301.518.3675 (cell) or by email at: audrey.el-gamil@dobsondavanzo.com.

Please submit your responses by August 20, 2010.


*Department of Health and Human Services, 74 Fed.Reg. 43267.
**Department of Health and Human Services, 74 Fed.Reg. 43246.
Agency Characteristics

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* 1. Are you responding to this survey on behalf of:

If you are responding on behalf of an entire home health company, please answer Questions #2-#7 below.

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* 2. How many home health agencies does this survey represent?

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* 3. How many unduplicated patients did these agencies serve in 2009?

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* 4. How many episodes of care did these agencies provide in 2009?

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* 5. What percent of the agencies are:

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* 6. Please identify the proportion of episodes and patients across agencies by state?

  State % Episodes % Patients
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* 7. What percentage of the agencies represented in this survey are:

If you are responding on behalf of a specific agency within a company, please answer Questions #8-#12 below.

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* 8. How many unduplicated patients did your agency serve in 2009?

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* 9. How many episodes of care did your agency provide in 2009?

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* 10. Which states does your agency serve?

  State State State State State State State State State
State

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* 11. What proportion of the areas served by your agency are:

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* 12. Is your agency

Process for admitting patient and providing home health care

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* 13. How does a physician determine if a patient needs home health care?

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* 14. How is a home health care treatment plan developed for a patient?

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* 15. How is the treatment plan implemented?

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* 16. Is there an organization-wide process for tracking a patient's evolving health and functional status?

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* 17. After the treatment plan has been developed, what is the current role of physicians throughout the home health episode?

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* 18. What criteria go into the decision to discontinue home health care for a given patient?

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* 19. After a patient's home health episode is complete, is there any follow-up from the nurses with the patient to ensure their safety and stability going forward?

From 2000-2007, CMS relied on a single therapy visit threshold for payment (10 visits per therapy episode). In 2008, however, CMS revised its methodology and implemented new payment thresholds at six, 14, and 20 therapy visits per episode, which aimed to better reflect the variation in therapy utilization and need among home health patients.

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* 20. How has your process and criteria for identifying patients to admit to home health care changed since 2007. Why?

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* 21. Do your current home health patients require a higher number of therapy visits than those treated prior to 2007? If so, why?

The Patient Protection and Affordable Care Act requires that a physician (or nurse practioners or nurse specialists working in collaboration with the physician) provide a face-to-face encounter with a patient prior to certifying the patient's need for home health services. CMS has proposed to implement this requirement through a rule that requires the certifying physician (or nurse practitioner or certified nurse specialist) to have a face-to-face encounter within 30 days prior to or 14 days following the start of the initial home health episode. The encounter must be related to the condition for which the patient is receiving home health services. The proposed rule also requires that the physician (or nurse practitioner or certified nurse specialist) document the encounter, maintain a record of the reasons why the patient meets the homebound requirement and why the patient needs the prescribed care, and provide written certification that the qualifying encounter took place.

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* 22. How do you expect this change in policy overall to affect patient referrals, care planning, management and/or delivery of home health care? (Check all that apply)

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* 23. How do you expect the proposed requirement that a face-to-face encounter take place within 30 days prior to or 14 days following the start of care will affect patient referrals, care planning, patient management, and/or delivery of home health care? (Check all that apply)

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* 24. How do you expect the proposed requirement that a face-to-face encounter be related to the condition for which the patient is receiving home health services will affect patient referrals, care planning, patient management, and/or delivery of home health care? (Check all that apply)

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* 25. How do you expect the proposed requirement that the certifying physician/practitioner document the face-to-face encounter and the clinical findings to support the certification that the patient is "confined to the home" and in need of intermittent skilled nursing care or therapy will affect patient referrals, care planning, patient management, and/or delivery of home health care? (Check all that apply)

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* 26. Are physicians/practitioners that certify home health services aware of the proposed requirement? If so, do they understand it fully?

The proposed rule requires that a professional therapist assess all Medicare patients at least on the 13th and 19th therapy visits prior to any further therapy visits. Additionally, the patient will be reassessed at least every 30 days. No additional therapy visits would be covered until the reassessment has occurred. The proposed rule also would require that the therapist document the assessments and therapy care using objective measurement of function and progress, a clinically supportable statement why there is an expectation that anticipated improvement is attainable in a reasonable and generally predictable period of time, plans for continuing or discontinuing therapy, and changes to therapy goals.

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* 27. How do you expect this requirement that a professional therapist assess a patient on the 13th and 19th visit and at least every 30 days will affect patient referrals, therapist care planning, patient management, and/or delivery of home health care? (Check all that apply)

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* 28. How do you expect this requirement that a professional therapist assess a patient using the proposed required assessment approach will affect patient referrals, therapist care planning, patient management, and/or delivery of home health care? (check all that apply)

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* 29. How do you expect this requirement that a professional therapist document the patient's care, care plan changes, progress (or lack thereof), and establishment and measurement of goals will affect patient referrals, therapist care planning, patient management, and/or delivery of home health care?

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* 30. Will these policy changes increase your agency's costs? If so, please estimate the per episode cost increases.

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* 31. Will these policy changes affect the types of patients that you admit to home health? If so, please specify the type of patients in box next to the listed impact.

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