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Home Health

  • VNAA Summary of Proposed Rule for Medicare Home Health for Calendar Year (CY) 2015: On July 7, 2014, CMS published in the Federal Register its Proposed Rule for Medicare Home Health for Calendar Year (CY) 2015. The rule proposes multiple changes to the home health payment rates as well as significant changes in other home health policies including face-to-face documentation, therapy assessment schedules, and requirements for OASIS data submission. The proposed rule also introduces CMS’ preliminary plan for a value based purchasing pilot in 2016 and requests industry input on the approach being considered.
Face-to-Face Encounter Documentation ToolkitNew

Below are links to a toolkit created by VNAA to help your agency address face encounter documentation issues to your local member of Congress. The toolkit includes a sample press release template for your customization and a sample letter to the editor or blog posting. If you need further assistance or have questions on communicating with the media, please feel free to contact VNAA.

  • Rebasing Dear Colleague Letters (Senate | House): On Sept. 25, members of the U.S. Senate and House of Representatives sent a letter to Marilyn B. Tavenner, Administrator of the Centers for Medicare and Medicaid Services, regarding the 2014 Home Health Perspective Payment System (HHPPS) and its proposed implementation of the rebasing provision.
  • Congressional Post-Acute Letter: On August 19, VNAA submitted comments in response to a request for information issued by the joint Congressional committees of health care jurisdiction. The letter, released June 19, invited VNAA and other post-acute providers and stakeholders to submit comments on ways to address substantial variations in Medicare spending, utilization, quality and profit margins within the post-acute care (PAC) sector.

Hospice and Palliative

  • Medicare Part D and Hospice Drug Coverage
    The Center for Medicare and Medicaid Services (CMS) recently issued guidance for Medicare-certified hospices and Part D plan sponsors to establish a procedure to limit instances in which Part D plans inappropriately cover prescription medications related to a hospice beneficiary's terminal condition. VNAA has been very active in response to this issue which creates confusion and delays in obtaining necessary medications for hospice beneficiaries. VNAA has met with CMS officials and also with Congressional staff in conjunction with a multi-stakeholder coalition of hospice organizations, Part D sponsors, pharmacists and consumer advocates. VNAA is closely aligned with these stakeholders in calling for a reversal of the new CMS policy on Part D coverage determinations for hospice beneficiaries.


  • VNAA Comments to the Senate Commission on Long-Term Care: In a letter to the Commission on Long-Term Care on Aug. 27, 2013, VNAA shared its guiding principles to reform the delivery of long term supports and services today and for future generations. The Commission was established under Section 643 of the American Taxpayer Relief Act of 2012 (P.L. 112-240), signed into law on Jan. 2, 2013.
  • Program Integrity: VNAA in conjunction with its members developed a white paper consisting of proposals to reduce the incidence of abuse in the Medicare program and enhance the quality of care agencies provide. VNAA began this project anticipating that the growth in reported abuse of the Medicare home health benefit would require action and that VNAA could and should take a leadership position.
  • Rural Issues: VNAA has been very active on rural and underserved health issues over the past year and will continue to be active in the coming year through the formation of a new interest group focused on helping rural home health and hospice members’ access opportunities through agencies like the Health Resources and Services Administration (HRSA) as well as network with each other.
  • VNAA Vulnerable Patient Study: VNAA, in collaboration with the Center for Home Care Policy and Research of Visiting Nurse Services of New York, has completed a study that analyzed data on a range of patients that VNAA members treat and the costs associated with providing care to these patients

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