November 2017 Newsletter
Executive Director's Message
November is the time of year when the work of home health and hospice agencies is recognized by national associations and states across the country. Here in Vermont, Governor Scott proclaimed November "Home Care, Hospice and Palliative Care Month." This year, the staff of Vermont's home health agencies will drive more than 6 million miles to provide just about a million hours of care to Vermonters across the state, no matter how remote their homes might be.
November is also the time of year when we look ahead to the next Vermont legislative session that begins in January. The items on our advocacy agenda may change each year, but the goal remains the same-to preserve access to home health services for every Vermonter. This year, we expect to focus on three primary issues in the State House: an increase in Medicaid payments for our services to cover inflations in medical costs, legislation aimed at raising the minimum wage, and the certificate of need process.
Minimum wage policy is a complex issue for employers like VNAs whose budgets are highly dependent on the decisions of state and federal policymakers in the form of the Medicaid and Medicare budgets. While 10 years of declining Medicare reimbursement and nearly stagnant Medicaid reimbursement rates have left home health agencies with little capacity to raise entry-level wages for staff providing homemaker and personal care services, wage growth could help our members recruit and retain those staff members. Our hope is that the focus on minimum wage policy for all employers will draw attention to the important issue of adequate funding for Medicaid services.
The Green Mountain Care Board is also considering recommending a proposal to the legislature that would adjust the criteria that health care providers must meet to expand their services or bring new services to Vermont. This process is known as the "certificate of need" or CON process. For decades, Vermont has had a robust public planning process and extensive state oversight, an approach supported by the VNAs of Vermont. Thanks to the CON process, Vermont has a largely not-for-profit health care system with little duplication of services. At this writing, we are pleased to report that the proposal made by the Green Mountain Care Board's expert staff recommends an update to the CON law, but not a change in direction.
Finally, a November newsletter would not be complete without acknowledging that this is the time of year when we spend a little extra time giving thanks for blessings both large and small. I'm deeply grateful that my oldest child will be home from college for the holiday, and that my husband-the most relaxed cook I know-will once again be in charge of the Thanksgiving meal so I can make sure we all have our favorite desserts.

Jill Mazza Olson
Executive Director
Federal Update
Home Health Groupings Model
Home health agencies across the country have been sounding the alarm about the Home Health Groupings Model since it was proposed by the Centers for Medicare and Medicaid Services (CMS) back in July as part of the annual release of the Medicare prospective payment system (PPS) rule. The model represents a significant cut to home health Medicare payments through an untested payment reform model that is not aligned with Vermont's health care reform efforts,  which focus on delivering care in the least expensive settings. It was slated to go into effect on January 1, 2019. CMS recently finalized the 2018 PPS rule without the Home Health Groupings Model. That's good news, but there is still a long way to go. CMS did not entirely withdraw the model and it could be proposed again when the draft 2019 PPS rule is released in July. Between now and then, our national associations will be hard at work to negotiate a more thoughtful approach to home health payment reform. One thing has become abundantly clear: CMS is no longer willing to allow home health Medicare payments to subsidize state Medicaid home health payments. That posture will have a significant impact on Vermont VNAs who serve an especially large number of individuals covered by Medicaid in skilled home health and long term care programs.
Emergency Preparedness
New federal emergency preparedness regulations for all participating Medicare and Medicaid providers, including home health agencies, went into effect on November 15. VNAs of Vermont members have been hard at work implementing the new rules and working with their local department of health offices to coordinate with other providers in their communities. To learn more, visit the Centers for Medicare and Medicaid Services page on the new rule
Conditions of Participation
The first major overhaul of federal regulations governing home health agencies in decades goes into effect on January 13, 2018. The Centers for Medicare and Medicaid Services (CMS) has been slow to issue the interpretive guidelines that are the roadmap to compliance, hampering the efforts of home health agencies across the county to implement the new rules. Draft interpretive guidelines are now available, but they will probably change again after CMS reviews the comments submitted by national home health associations. In addition, CMS recently announced that it will delay the implementation of civil monetary penalties on any re-certification survey, except in cases where patient health or safety is in "immediate jeopardy." Learn more about these interpretive guidelines by attending our 2-part webinar series on January 9 and 10.

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