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VNAA - Visiting Nurse Associations of America

VNAA 2012 Public Policy Priorities

2012 VNAA Public Policy Priorities

VNAA Public Policy Priorities for 2012 (January 30, 2012) VNAA advocates on behalf of nonprofit home health and hospice providers that offer comprehensive healthcare to Medicare, Medicaid, uninsured and under-insured patients as well as an array of community benefits. While the VNAA agenda is distinctive in terms of the mission and values of its nonprofit, safety net members, it addresses issues that impact all home health and hospice providers. VNAA advocates before Congress, the Centers for Medicare and Medicaid Services (CMS), Medicare Payment Advisory Commission (MedPAC) and other federal agencies and works in collaboration with other national organizations representing the healthcare continuum. Further information on VNAA policies and initiatives can be obtained at www.VNAA.org.

A. Ensure access to home health and hospice services for all patients regardless of their ability to pay or the severity of their illness. Oppose co-payments that discourage vulnerable patients from obtaining services and consequently receive care in more costly settings such as emergency rooms, hospitals etc.

B. Seek supplemental reimbursement for the treatment of high-cost, low reimbursement patients that is a) based on patient characteristics and risk adjustments and b) recognizes that safety net agencies serve a higher proportion of vulnerable patients and take high losses. Ensure that study and payment demonstration, required by Sect. 3131 (d) of the Affordable Care Act, are completed in a timely fashion and used to inform rebasing and all element of reimbursement.

C. Ensure appropriate Medicare reimbursement for home health:

  • oppose across-the-board cuts to base reimbursements (case-mix creep cuts, productivity adjustments, etc.);
  • ensure policymakers take into account "overall" margins of safety net providers when deciding reimbursement refinements;
  • ensure market basket adjustments reflect increases in cost and wages;
  • retain the rural add on;
  • advocate for wage index parity;
  • enhance cost reports to more accurately reflect costs of safety net agencies;
  • advocate to delay rebasing of reimbursements until an appropriate and reasonable process is established with changes phased in over time;
  • advocate to remove current barriers to appropriate and timely reimbursement.

D. Ensure appropriate Medicare reimbursement for hospice:

  • oppose raising, eliminating or otherwise compromising the effect of the aggregate hospice cap;
  • oppose the elimination of the budget neutrality adjustment factor (BNAF) until appropriate and reasonable wage adjustment alternatives can be found;
  • ensure policymakers take into account "overall" margins of safety net providers when deciding reimbursement refinements;
  • seek hospice reimbursement reforms that provide appropriate reimbursement for the care of high-cost vulnerable patients;
  • eliminate barriers to appropriate and timely reimbursement;
  • enhance cost reports to more accurately reflect costs of safety net agencies.

E. Ensure integrity of home health and hospice benefit and eliminate fraud and abuse, which results in inappropriate gaming by some and across-the-board cuts for reputable home health and hospice providers. A temporary moratorium for home health and hospice is needed along with other measures targeted to offenders.

F. Support a leading role for VNAA members in demonstration projects or initiatives such as post-acute bundling, chronic care management, transitional care management, Independence at Home or medical home.

G. Advocate for changes in federal regulations on behalf of safety net home health and hospice services on issues such as:

  • annual home health and hospice update regulations;
  • implementation of the Affordable Care Act;
  • Department of Labor companionship wage and hour regulations;
  • regulations related to Medicare or dually eligible Medicare/Medicaid patients.

H. Advocate for changes in federal legislation and regulation to expand the authority of nurse practitioners and other appropriate personnel in home health and hospice, including but not limited to signing plans of care, providing face-to-face consultations and certifying and re-certifying patients. Many rural and low-income patients depend on nurse practitioners for their primary care.

I. Reform Medicare Advantage to ensure appropriate and timely reimbursement:

  • promote appropriate reimbursement to providers for patients who transition during care from the traditional Medicare benefit into a Medicare Advantage plan;
  • advocate that Congress mandate that Medicare Advantage plans provide adequate reimbursement for comprehensive episodic care rather than a visit based home health service benefit.

J. Ensure that home health and hospice are Essential Health Benefits in all federal and state public plans. Ensure that home health and hospice agencies are included in any list of "essential community providers."

K. Advocate for full integration of home health and hospice in federal health information technology and health information exchange. Seek federal reimbursement and legislative/regulatory authority to enable home health and hospice providers to share appropriate patient data with other providers in the healthcare continuum including physicians and institutional providers.

L. Advocate for federal legislation/regulation to ensure appropriate Medicaid-only and dual eligible reimbursements. Support regional or national initiatives (such as third party liability) that promote and ensure that reimbursement is timely and appropriate for services to dual eligible and Medicaid-only patients.

M. Advance legislation and regulations that support home health and hospice providers to recruit and retain a viable workforce including nurses, therapists and other professionals.

Approved by VNAA Board of Directors, January 27, 2012.


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