August 16, 2013

Partnership Submits Comments to Congress on Beneficiary Cost-Sharing

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Washington, DC – The Partnership for Quality Home Healthcare – a coalition of home health providers dedicated to developing innovative reforms to improve the program integrity, quality, and efficiency of home healthcare for our nation’s seniors – today commended leaders of the House Ways and Means Committee for their commitment to ensuring Medicare beneficiaries’ access to high-quality healthcare services and expressed concern about the negative impact any re-imposition of a home health copayment would have on the nearly 3.5 million homebound seniors and disabled Americans who depend on the Medicare home health benefit.

In its letter to the House Ways and Means Committee, the Partnership outlined a series of factors which underscore the risk that the re-imposition of home health cost-sharing would jeopardize beneficiary access to care, increase State and Federal spending, and hinder economic and job growth:

A home health copayment was initially included in the Medicare program, but was repealed by Congress in 1972 due to its unanticipated impact on vulnerable beneficiaries and program costs.

Congress repealed the Medicare home health copayment in 1972 because it was found to be ineffective in reducing costs, imposed “a financial burden to many elderly persons living on marginal incomes,” and led to patients being served in more expensive facility-based settings. Re-imposing a policy that has already been found to be flawed and counterproductive would expose beneficiaries and taxpayers to risk.

Medicare home health beneficiaries are poorer, older and sicker than the Medicare population as whole, already bear considerable costs, and would be seriously impacted by a copayment.

Analyses demonstrate that Medicare home health beneficiaries are disproportionately more vulnerable than the Medicare beneficiary population as a whole, with lower annual incomes, more advanced age, and more numerous chronic conditions. In addition, homebound seniors and disabled individuals already bear considerable at-home living expenses and would therefore be deeply impacted by a re-imposed copay.

Re-imposition of the home health copayment will increase Medicare spending as well as State Medicaid costs, due to copayment coverage and the shift of patients to more costly settings.

Avalere Health estimates that re-imposition of a home health copayment could lead to $16.7 billion in additional Medicare spending due to increased facility-based care. Because it would impose a substantial financial burden on low-income Medicare beneficiaries, a home health copayment would also be a new unfunded mandate on States, which would have to cover the cost of the copayment for dual-eligibles and Qualified Medicare Beneficiaries (QMBs).

Governors, patient advocates, and policy experts have expressed concern with any re-imposition of a home health copayment, and surveys of seniors find high levels of opposition to such a policy change.

Due to the anticipated consequences of cost-sharing on the vulnerable home health population – including a shift of patients to costly institutional settings and higher Medicare and State Medicaid expenses – leading Governors, advocates, and policy experts have urged Congress not to re-impose the home health copayment. Recent polling also reveals extraordinarily strong opposition among registered senior voters.

Re-imposition of a copayment would impact the home healthcare sector, which is an engine of new job creation but which is already struggling with the impact of unprecedented legislative and regulatory cuts.

According to the U.S. Bureau of Labor Statistics, the home health sector was again a leader in job creation in July with 3,900 new jobs (nearly two-thirds of all new jobs created in the ambulatory healthcare services sector). The re-imposition of a copayment, coupled with the $72.5 billion in cuts made since 2009 and the proposed additional cuts of nearly $22 billion, threatens the sector and its ability to maintain job growth.

Targeted program integrity reform is a proven and preferred way to achieving sustainable program savings without harming vulnerable beneficiaries or increasing State and Federal costs.

Instead of re-imposing a home health copayment, the Partnership urges Congress to advance program integrity reform. Targeted solutions like the Skilled Home Health and Integrity Program Savings (SHHIPS) proposal would prevent the payment of aberrant claims, strengthen the claims review process, improve conditions of participation standards, and achieve billions in savings without impacting vulnerable patients.

“We appreciate the opportunity to share our perspectives regarding Medicare beneficiary cost-sharing and look forward to working with the Committee to advance pro-patient solutions that ensure beneficiary access to clinically-advanced, cost-effective, patient preferred home healthcare,” said Eric Berger, CEO of the Partnership. “The Committee is undertaking a thoughtful process and is to be commended for its consideration of the many concerns raised regarding re-imposition of a home health copayment.”

The Partnership is also a member of Fight Fraud First! – a coalition of groups representing millions of older Americans, persons with disabilities, minorities, veterans and healthcare providers – which also submitted a letter to the Committee noting, “Imposing increased out-of-pocket costs on a vulnerable population of older Americans is not a solution that will stabilize this vital program. We instead urge lawmakers to advance policy solutions that will safeguard beneficiaries through program integrity reforms.”