The Honorable Marilyn Tavenner
Administrator
Centers for Medicare & Medicaid Services
Department of Health & Human Services
200 Independence Avenue, SW
Washington, D.C.  20201
 
Dear Administrator Tavenner:
 
The availability of home healthcare services is important to millions of frail elderly and disabled patients across our nation. It is important that laws set by Congress and rules and regulations administered by the executive branch take proper care of the issues which affect the access to care for this community. As such, we write to express our comments on the 2015 proposed Home Health Prospective Payment System (HHPPS) rule by the Centers for Medicare and Medicaid Services (CMS) which will be finalized in the coming months and take effect on January 1, 2015.
 
We acknowledge that progress was made towards eliminating the required physician narrative as part of the Face-to-Face (F2F) requirement in the 2015 proposed HHPPS rule and support the inclusion of this provision in the final rule. However, concerns remain over the providers and patients whose claims are still being denied due to an insufficient physician narrative while they wait for the rule to be finalized. CMS signaled with the proposed rule that it intends to no longer enforce the physician narrative requirement.  Therefore, we urge CMS to suspend audits related to the physician narrative beginning with the date that the 2015 proposed HHPSS rule went on display (July 1, 2014).  Similarly, in light of the changes announced in the proposed rule, we urge CMS to establish a process that would allow providers to receive full reimbursement if a claim was previously denied for an "insufficient physician narrative."
 
As Representatives concerned about the impact that the final 2015 HHPPS rule from CMS will have on the ability of the elderly and disabled to receive proper care and treatment through home healthcare services, we appreciate your attention to this matter.
 
Sincerely,