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The Center for Medicare Advocacy has been hearing about people who clearly meet Medicare criteria but are unable to access home health care ordered by their physicians. In particular, people living with long-term and debilitating conditions find themselves without necessary home care. For example, they have been told Medicare will only cover 1 to 5 hours per week of home health aide care, or only one bath per week, or that they aren’t homebound (because they roam outside due to dementia), or that they must first decline before therapy can commence (or recommence). These individuals and their families are struggling as a result of these inappropriate limitations with too little care or no care at all.

Home health access problems have ebbed and flowed over the years, depending on the reigning payment mechanisms, systemic pressures, and misinformation about Medicare home health coverage.  Regrettably, if proposed payment rules are finalized, it appears these access problems will only get worse.

Comments regarding the proposed rules are due August 26, 2016.  The Center will be expressing our concerns that the proposed changes will result in drastically reduced access to Medicare home health care coverage, particularly for people who are clinically complex or who have poorly controlled chronic conditions.

We are also deeply concerned about, and urge reconsideration of, the proposed measure set for the “Home Health Value Based Purchasing (HHVBP) Model and Quality Reporting,” which is based largely on a discredited Improvement Standard, in conflict with the federal Jimmo v. Sebelius settlement. (CA No. 5:11-CV-17-CR; D. VT, January 2013.) Contrary to CMS’ stated desire that the HHVBP Model improve the quality and delivery of home health care to Medicare beneficiaries, the Model will actually reduce home health access to vulnerable people who cannot “improve,” but who require skilled care to maintain their conditions, or slow or prevent further deterioration. 

If your organization would like to sign-on to the Center’s comments contact us by 10:00 AM EDT Friday, 8/26/16 at

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