Review Choice Demonstration Comment Letter

ElevatingHOME and VNAA submitted comments to CMS on the Review Choice Demonstration. We are very concerned about the potential implication of such a demonstration on patient access, the focus on paperwork over patients and the burden on providers. We shared those concerns and a series of questions for CMS to answer to ensure a better implementation.

Specifically, we wrote:

“Regardless of the lack of success in curbing waste, fraud and abuse in the Pre-Claim Review Demonstration, CMS seems to be determined to move forward with minor modifications in the Review Choice Demonstration. ElevatingHOME and VNAA continue to stand ready to assist in this manner and have volunteered guardrails to both CMS and the HHS Office of Inspector General. We believe that there are many avenues that can be pursued to reduce waste, fraud and abuse and RCD and PCRD are just focused on documentation processing. With regulations that continue to minimize the role of home health records (regardless of recent passage of legislation), home health agencies are continually in the crosshairs for documentation. However, despite the slow progress in improving the reporting process, the improper payment rate continues to drop.

This demonstration sadly seems to be in complete opposition to the Administration’s claim of wanting to place patients over paperwork. This sadly requires highly qualified and trained clinicians to focus on paperwork over patients. The following comments are provided in the hopes of improving the RCD. However, it is our fervent belief that CMS and HHS could achieve much more with a collaborative effort amongst the home health industry and their representatives. No one wants there to be waste, fraud and abuse in the industry; it lowers the standing of the vital services provided to the current and future patients and their families.”
While we believe that CMS is fully determined to start this demonstration on October 1, 2018, we will continue to pursue legislative solutions. Please contact Joy Cameron with any questions or concerns.

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