ADHCC Submits Comments on 2019 Medicare Advantage Draft Call Letter
The following comments were uploaded to CMS's website and is available for public viewing.
On behalf of 130 New York adult day health care (ADHC) providers and the families they serve, the Adult Day Health Care Council (ADHCC) commends CMS for its proposal to expand the scope of the primarily health related supplemental benefit standard (pp. 182-183) to benefits that enhance beneficiaries’ quality of life and improve health outcomes. We believe adult day health care meets the broader definition of “primarily health related” and we strongly encourage CMS to issue guidance to include ADHC in plan offerings.
Adult day health care, licensed and certified by the New York State Department of Health, is designed to meet the needs of chronically ill, frail elderly and disabled adults who require primary, preventive, diagnostic, therapeutic rehabilitative or palliative services. Services provided in every ADHC program in New York State include: skilled nursing care, pharmaceutical services, clinical and case management, medical and diagnostic care, social, therapeutic and recreational programs, rehabilitative and maintenance therapies, personal care and dietary services. Participants have all of their health care needs assessed and met (or arranged for) by the program. This comprehensive, integrated care leads to stabilization of chronic health conditions and reduced incidence of physician and emergency room visits.
Across New York State and the nation, ADHC participants experience reductions of avoidable hospitalizations and delayed nursing home placement. A study by the New York State Department of Health credited the continuous health monitoring and health education provided in medical model adult day programs, with the findings that 70 percent of participants with multiple chronic conditions had no hospitalizations over the course of a 12-month period. A study conducted by the Adult Day Health Care Council found that 1,000 participants with five or more chronic conditions had less than one-fifth of the hospitalization rates round in the similarly situated Medicare population.
ADHC services must be ordered by the participant's primary care physician prior to admission. The community physician will renew orders every six months if ADHC continues to be medically appropriate. ADHC services are provided at a per-diem rate, which is much lower, and has more benefit, than providing individual services in the home. Simply being in the center provides a safe, supervised and socially stimulating environment which reduces chronic isolation often experienced by older adults and supports the overall physical, cognitive and mental health of the beneficiary.
Thank you for this opportunity to comment on CMS-2017-0163. We strongly encourage CMS to recognize ADHC as one of the expanded health-related supplemental benefits to be included in Medicare Advantage Plans during the bidding process.