New CMS Proposal Would Save Home Health, Hospice $137M Annually

Federal policymakers are again taking aim at costly administrative and paperwork burdens for the home health and hospice industries in order to help providers save tens of millions of dollars annually.

The Centers for Medicare & Medicaid Services (CMS) on Monday announced its latest proposed rule focused on minimizing burdens on home health agencies, hospice providers, hospitals, skilled nursing facilities and other health care entities. The proposed rule, a response to the Trump administration’s “cut the red tape” initiative, would save all health care providers an estimated $1.12 billion a year, according to CMS.

Thanks to provisions targeting patient rights requirements, medication staffing stipulations and deficiency training rules, home health and hospice providers, in particular, would stand to save an estimated $137 million combined.

Hospice providers would likely reap more savings than home health agencies under the newly proposed rule.

“We are committed to putting patients over paperwork, while at the same time increasing the quality of care and ensuring patient safety and bolstering program integrity,” CMS Administrator Seema Verma said in a statement. “With this proposed rule, CMS takes a major step forward in its efforts to modernize the Medicare program by removing regulations that are outdated and burdensome.”

Burdens for home health agencies

Among suggested changes, Monday’s proposed rule would remove the requirement that home health agencies provide a copy of clinical records to patients during the very next home visit following a request. Instead, agencies would have four business days to provide copies if patients or their families ask for them.

Providing clinical record copies by the time of next visit is “not practical or even possible in some cases,” according to CMS.

In addition to those changes, CMS’ proposed rule also calls for eliminating the requirement that home health aides receive full competency evaluations when supervisors visit in the field and identify deficiencies in caregiving ability. Currently, home health agencies must conduct — and aides must complete — full competency evaluations that assess all aide skills whenever an issue is observed.

In lieu of full competency evaluations, CMS is proposing that agencies need only retrain an aide in the observed deficient skill or skills, with aides likewise completing evaluations that are directly relevant to the issues at hand.

In a change that is more consistent with requirements for other provider types, such as hospices, ambulatory surgery centers and mental health centers, the proposed rule also seeks to scrap the requirement that home health agencies must provide verbal notification of all patient rights. Written notification, though, would still be required.

Those and other burden reductions proposed by CMS would save an estimated $55 million annually, according to the agency.

Hospice cost savings

CMS’ proposed rule also included suggested changes to hospice requirements, most notably a change related to the requirement of having an individual with specialty knowledge of hospice medications on staff.

The requirement “is no longer necessary for various reasons” and should be eliminated, according to CMS .

CMS is also proposing to replace the requirement that hospices provide a copy of medication policies and procedures to patients, families and caregivers with a requirement that hospices provide information regarding the use, storage, and disposal of controlled drugs to the patient, patient representative or family. The proposal calls for that information to be provided in a more user-friendly manner, as determined by each hospice.

The hospice burden reductions proposed by CMS would save the industry an estimated $82 million annually, according to the agency.

Tracking CMS progress

Since CMS’s Patients Over Paperwork initiative began in 2017, the agency has conducted interviews with health care stakeholders, visited various care settings and worked to identify instances where paperwork burden and administrative requirements could be alleviated.

So far, those effort have uncovered 3,040 “mentions of burden,” which CMS has categorized as related to 1,146 different issues. CMS has taken action to address 55% of the burden topics raised.

Across rules finalized in 2017 and 2018 and current proposed rules to address these topics, CMS projects savings of nearly $5.2 billion and a reduction of 53 million hours through 2021.