Tuesday, August 7, 2018
Posted by: Kyle Simon
As the voice for home care providers in Florida representing the interests of agencies of all types – institution-based and freestanding, proprietary and not-for-profit – HCAF strongly opposes the proposed Review Claim Demonstration (RCD) for all providers and for all the patients they serve. We respectfully disagree with positions taken by some providers in the industry due to the RCD's unique threat it poses in our state.
This proposal is especially ill-timed for Florida providers that have been disproportionately subjected to: the ongoing Home Health Value-Based Purchasing Model (Florida is one of nine states selected for the demonstration); preparation for the previously withdrawn Pre-Claim Review Demonstration (Florida was one of five states selected for this demonstration); expansion of the Targeted Probe and Educate audit strategy; new Medicare Conditions of Participation; and, most recently, the proposed Patient-Driven Groupings Model, widely seen as most dramatic overhaul to the Medicare home health payment system in nearly two decades.
All the while, rampant and aggressive Zone Program Integrity Contractor (ZPIC) auditing practices have led to countless claim denials and recoupments for care already provided to seniors needing access to vital home health services. Providers here are already operating on razor-thin profit margins and program changes piling on too quickly. HCAF fears that the result of RCD's implementation will lead to unintended consequences, most concerningly reduced quality of patient care and access to the home health benefit.
Read our comments submitted to the Centers for Medicare & Medicaid Services here.