PUBLIC SUBMISSION | As of: 5/24/13 10:53 PM Tracking No. 80b4f0ea Comments Due: September 14, 2010 |
Docket: CMS-2010-0213
Home Health Prospective Payment System Refinements and Rate Update for CY 2011
Comment On: CMS-2010-0213-0001
Medicare Program: Home Health Prospective Payment System Rate Update (CY 2011); Changes in Certification Requirements for Home Health Agencies and Hospices
Document: CMS-2010-0213-0348
Hoosier Uplands Home Health Care & Hospice, IN
IN,
Therapy Services (page 43245) does not take into account patients who are receiving multiple therapies at one time, and it would make it confusing to try to figure out exactly when the patient hits the 13th and 19th visit mark. Adding to the financial burden of many agencies.
Home Health face to face encounter (page 43266) contradicts the purpose of home health care. By definition a home health medicare patient is to be homebound, meaning it is difficult and taxing for them to leave their home. However this would impose on the patient the need to leave home for increased, and unnecessary physician visits. Physicians have always relied upon home health nurses to be their eyes and ears in the patients home. Also, if the patient is discharged by a hospitalist, when they will be required to make an additional visit to their primary care physician. The face to face requirement will cause a huge increase in acute care hospitalizations, as many physicians call home health to go assess the patient with symptoms of an impending exacerbation, and thus home health keeps them out of the ER. Now many physicians will be forced to send their patients to the ER, making a huge step backwards for home health.
Hospice Certifications and Recertifications (page 43269) will place unreasonable barriers on the care of hospice patients. Most hospices do not employ a full-time hospice medical director. Therefore the patient who is terminally ill would be forced to leave their home and go to the physician.
I ask that face to face encounters not be in place for those of us in rural areas.