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HCAC e-news |
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ATTN: MEDICAID PROVIDERS |
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IF THIS AFFECTS YOUR AGENCY, YOU SHOULD BE THERE! The meeting will begin at 9:00 a.m. at the Colorado Department of Health Care Policy and Financing, 1575 Sherman Street, Room 4A/B, Denver, Colorado, 80203. The rule (Document 3) can be read at http://www.chcpf.state.co.us/msb/agenda/02Dec.html HCAC ANALYSIS OF ISSUE:
The Rule: MSB 02-10-25.A
1. The Home Care Association of Colorado agrees that the cost to the state for these brief 2x day insulin injection visits for stable clients should be reduced so these clients can remain at home. Being alone and too frail or afraid or shaky to self-inject two shots a day is not a good reason to go to a nursing home. 2. However, we do not agree that this qualifies as an “emergency” rule. This issue deserves further discussion with nurses who provide the care and home care agencies that will have to live with whatever decreased reimbursement is ultimately decided. In a poll of one-fourth of my agency members, not one had a client receiving 2x day insulin injections! This practice is not a common occurrence in home health. We need time to determine how many and what agencies are doing this? What else is going on with these clients? What are extenuating circumstances for each of these clients. We could do this investigation if this were a regular rule. 3. We also believe the rule as written far exceeds and greatly expands the original proposal to develop an “injection rate” for a certain number of individuals. The language opens ALL home health visit rates to be set at an unknown amount that the dept. will “determine” at a future date and that a SEP case manager, usually a non-medically trained person, will “authorize.” The rule does not relate back to the rule’s statement of basis and purpose. w The home care industry has worked hard to try to get nursing reimbursement rates to a level that will allow us to be competitive in hiring RNs. It is very competitive out there. Many agencies are having to turn away clients daily due to the nursing shortage. w Colorado’s current Medicaid skilled nursing rate is at the median nationally and is $28 less than what Medicare pays for the same visit. 4. This language expands the original intent of an “injection rate” to include other functions such as filling Med Minders; Medication Administration; Drawing Blood. These functions are not necessarily the same as an insulin injection. Filling a Med Minder can take an hour or more. It is not a brief visit. 5. There’s more to an RN visit than just coming in a person’s home and “giving a shot.” A home care visit encompasses much more than the time in the home (mandatory periodic OASIS certification and re-certification, travel which can be more than an hour in our rural communities, assessing the environment, nutrition including food and water, sores, meds, coordinating with physician, scheduling and paperwork which can take 1.5 hours for every hour of actual direct care). Nursing assessment must be done during first visit of day; Glucose levels must be checked; THESE ARE THE THINGS THAT KEEP THE CLIENT OUT OF THE HOSPITAL EMERGENCY ROOM. The nurse practice act and the agency’s Medicare/Medicaid certification are in jeopardy if these standards are not adhered to in a satisfactory manner. HCAC Recommendations: 1. Make this a regular rule that will allow for additional public discussion between the department and industry and advocacy groups before the next meeting. Determine if the clients in question could enter in the department’s new Disease Management program. 2. Change the rule as follows:
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