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Document ID: CMS-2010-0213-0006
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 27 2010, at 12:00 AM Eastern Daylight Time
Date Posted: August 5 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: July 23 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: September 14 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b2205c
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REGARDING PROPOSED CHANGES TO HOME HEALTH CARE Regarding proposed payment decreases in Medicare payments to HHA’s: CMS will severely restrict access to home health services to the patients who need home health the most. HHA’s have already sustained a significant cut in outlier payments, leaving insulin dependent and wound care patients without a nurse to provide injections and necessary wound care treatment. Further payment cuts will force many HHA’s out of business, forcing patients to go to the hospital ER for care. This will cost the U.S. taxpayer even more money and cause extreme hardship to our patients. Regarding face –to-face encounters with the MD to receive home health benefits: Physician’s already see too many patients in a day to truly provide the quality care our seniors deserve. Requiring them to see a patient prior to certifying them for home health is unrealistic and an unnecessary burden on overworked physicians. Also, given the very nature of a home health patient is by definition, homebound, it is ludicrous to then expect seniors to secure transportations to their doctor’s office to become home health certified. Regarding increased therapy and nursing documentation requirements: Therapist already visit and document changes for home health patients on the 1st, 30th, and final day of the certification period. Adding visits on the 13th and 19th will be prohibitively expensive to the HHA, and an unnecessary intrusion for the patient. Proposed increased paperwork for the skilled nursing visit will further drive up costs to the HHA, and diverts attention away from devoting quality time with the patient to completing more unnecessary claim codes etc.

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