The American Association for Homecare's membership is opposed to competition that is unfair and unreasonable. Our providers, large and small, fight for the opportunity to serve patients each and every day in their communities. Home care, one of the most competitive segments of health care, is not for the faint-at-heart.
Let's remember that opportunity and choice are at the heart of democracy in this country. Regarding competition in home care, Les DeFelice, AAHomecare board member and president and CEO of West Virginia-based DeFelice Care Inc., said, “A competitive environment results in the best possible care for the patients we serve. As providers, competing with each other, we should not be afraid to say, ‘Bring it on!’”
AAHomecare opposes national competitive bidding — or more accurately, “restrictive contracting.” NCB is anti-competitive by its very design and does not allow any willing provider to compete in the bidding process. Each of us should take every opportunity to do what we can to stop the harmful effects that NCB will inflict on the home care community.
In a recent article on competitive bidding, Karyn Estrella, executive director of the New England Medical Equipment Dealers Association, referenced the Benjamin Franklin quote, “We must all hang together, or assuredly we shall all hang separately.” This could not be more true in home care, especially as we face competitive bidding.
Many components, working in sync with one another, must go into any effective strategy for competitive bidding. To begin, it makes sense to determine the maneuverability of the policy and to locate the various points in the timeline at which to supply input or apply pressure in Washington.
Proposed solutions on the table have included a legislative fix, further work with CMS and seeking to delay NCB implementation. If we are truly to impact an issue that is so critical to the home care community, we should look at it from every angle.
At AAHomecare we are working with a strategic team on a timeline for competitive bidding that has been in play since the passage of the Medicare Prescription Drug Improvement and Modernization Act of 2003 (MMA).
When in battle, it is important always to know who is on your side. AAHomecare boasts (if you'll excuse us) partnership with some of the brightest and most talented leaders in home care: our board of directors, our membership and the state home care associations around the country. We are also pleased to have congressional “champions” on Capitol Hill to aid us in this battle. Furthermore, due to competitive bidding, AAHomecare has expanded its utilization of some of the top health care consultants not only in Washington but in the nation. Our consultants include many partners of top Washington law firms as well as strategic data collection organizations.
AAHomecare has a wealth of dynamic and diverse members, walking with us every step of the way. It is important to remember that AAHomecare is a membership-driven organization, and the more that our members become involved, the more the association is able to work for them to advance sound policy for home care.
Association members have participated in the three meetings of the Program Advisory and Oversight Committee — which is advising CMS on the implementation of NCB — held since Oct. 6, 2004, and will continue to do so as the committee meets periodically throughout 2009.
AAHomecare will continue its comprehensive strategy alongside the following timeline for the implementation of NCB, working for a combined administrative and legislative fix.
-
In September 2005, CMS anticipates its release of the notice of proposed rule making discussing the provisions of the MMA. Following release of the proposed rule, AAHomecare and other stakeholders will have a period of 60 days in which to submit public comments.
-
By early to mid-year 2006, CMS will finalize its review of comments and discussions of outstanding issues with the PAOC.
-
The final rule for NCB is scheduled for publication by early summer 2006, for implementation in “10 of the largest MSAs” in January 2007, followed by the next 80 largest MSAs in 2009 and additional areas after 2009.
Kay Cox is president and CEO of the American Association for Homecare, Alexandria, Va. For more information about AAHomecare, visit www.aahomecare.org, or call 703/836-6263.
