A new year is here, and it is bringing challenges and opportunities to home health and hospice. National Association for Home Care and Hospice (NAHC) President Bill Dombi shared his industry outlook for the new year in a webinar with Netsmart SVP of Post-Acute Strategy, Mike Dordick. Market dynamics, payment challenges, regulatory changes and legislative initiatives collectively shape the landscape. According to Dombi, navigating these complexities requires a strategic approach, collaboration with Congress and a commitment to addressing workforce challenges.
Challenges and Closures in Home Health Agencies
Market consolidation is a noticeable trend, with large organizations acquiring others, especially in the context of Medicare home health. Despite consolidation, Dombi reassured that this doesn't signal the end for small providers. However, ongoing threats to payment rates through the Medicare program remain a major concern.
Dombi also highlighted the impact of payment rate cuts on home health agencies, leading to closures, particularly in small areas. Even a century-old urban-based visiting nurse agency terminated its Medicare home health provider agreement, opting to continue hospice services.
Service area reductions and rejection of referrals by hospitals are contributing to the challenges. An estimated 48% of all home health agencies are expected to have negative margins in 2024 due to cuts. The negative margins are not solely attributed to the Medicare rate itself but also to subsidizing reimbursement from other payers like Medicare Advantage and Medicaid.
Congressional Support and Legal Action
The industry is actively seeking support from Congress to address negative rate adjustments. Bipartisan legislation aims to address these concerns and enhance transparency in analysis. NAHC has also taken legal action, bringing a lawsuit in Federal District Court in Washington DC, challenging the payment rate cuts.
Hospice: Program Integrity and Regulatory Changes
Shifting the focus to the hospice sector, Bill Dombi emphasized the intensive program integrity oversight on operations, quality, finances and claims. Recent regulatory tools, including changes in hospice ownership and the thirty-six-month rule, were introduced. The Special Focus Program is finalized and set to be implemented in the fourth quarter of the year.
Medicare is showing a keen interest in reforms for hospice, particularly in discussions about benefits structure and payment model reforms.
Medicaid Home and Community Based Services (HCBS): Policy Changes and Challenges
Medicaid HCBS, which totals over $100 billion, is undergoing potential changes. A proposed rule requiring 80% of payment rates to compensate direct care workers is under consideration. However, the analysis suggests that allocating eighty percent of Medicaid payments to caregivers will be very challenging for most organizations given current payment rates.
Personal Care Services: Workforce Challenges and Regulatory Focus
Workforce shortages are a significant challenge in personal care services. Some states are considering licensure of personal care providers for quality of care reasons. The department of labor is intensifying efforts to audit compliance with fair labor standards, particularly in overtime and basic non-compliance.
Medicare Advantage: Enrollment Surge and Oversight
Medicare Advantage is experiencing a surge in enrollment, leading to increased federal oversight. Focus is on marketing practices, with plans being instructed to rectify misleading information. Transparency regarding services, coverage and provider networks is emphasized, and efforts are underway to address prior authorization challenges.
Innovations and Legislative Initiatives
Innovative initiatives are on the horizon. The Choose Home legislation, reintroduced this term, aims to provide a skilled nursing facility at home benefit. There is growing interest, and flexibility might be introduced into its original structure. The Hospital at Home demonstration program, with reports showing improved mortality rates for patients at home, is anticipated to become a permanent program this year.
Telehealth legislation is expected to pass, but efforts are needed to ensure inclusion and reimbursement for home health care services. The Medicaid HCBS supports legislation pressed by Democrats faces challenges due to its substantial price tag.
Workforce Improvement and Congressional Support
Congress is working around the edges to address workforce challenges, with a focus on funding scholarships and career ladder opportunities. However, immigration-oriented approaches to workforce improvement are not being incorporated, limitations the potential impact.
Advocacy
Dombi also spoke extensively on advocacy efforts. There are many ways to get involved and lend your voice to the NAHC advocacy priorities. Visit https://nahc.org/ to learn more.
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To hear more of NAHC President Bill Dombi’s outlook for 2024, click here to watch our webinar.