HCAC POSITION ON  
PROPOSED MEDICAID RULE CHANGES  
(November 1999) 

1. Home Health Aide Incremental Reimbursement (circle page 44 of revised proposed rules): This is a change from the traditional "per visit" reimbursement of $38.43 per visit to $30.14 for the first hour and $9 for each subsequent ½ hour, with daily caps. This proposal is budget neutral. 

HCAC POSITION: We agree with this formula. 

2. Tracking type of client (Acute, Long Term or Long Term with Acute Episode) using newly assigned program or revenue codes (circle page 45 of revised proposed rules): 

HCAC POSITION: We support the department’s desire to track this very valuable information but we want to make sure that the tracking mechanism used is correct and is not overly burdensome or confusing to home care agency personnel. We oppose additional revenue codes due to this additional administrative burden and high probability of mistakes. We recommend using Condition Codes to capture patient specific information on home care visits. 

3. Teach and Access Visits Reimbursed at $50.04 (or even $55.28) vs. $69.32 which is reimbursed for other nursing services (circle page 44 of revised proposed rules): 

HCAC POSITION: Teaching clients and their families is the core of home care. If we don’t teach and assess, the clients and families will not be able to perform the tasks when we are away. Teach and Assess visits are sometimes shorter than others because only so much can be taught and assimilated by the client and family in one teaching session. But the nurse often spends more time in preparation and follow-up to these visits than others.  

Teaching is one of the most important and skillful things we do. New rules implemented on July 1, 1999 strictly define the circumstances when Teach and Assess visits can be provided. Statistics cited about abuse of Teach and Assess visits were gathered before 7/1/99. Let these new rules do their work. We oppose any Teach and Assess reimbursement amount lower than that of any other nursing visit. 

4. NORMS detail how many minutes each task should take and how frequently each task should be provided. NORMS do not fit all circumstances, every day. This adds nearly 30 pages of micro-managing language to the home care rule and adds much additional paperwork, re-training, supervision, documentation and tracking in order to maintain accountability. 

HCAC POSITION: We have already recommended that NORMS be  

- used as guidelines for Single Entry Points or better yet 
- placed in Single Entry Point rules with the accountability for adherence to the norms borne by the Single Entry Points

For further information, please call Ellen Caruso, Executive Director  at (303) 694-4728 or Betsy Clark Murray, Lobbyist  (303) 733-3875