Two weeks ago, the HCA provided public comment to MassHealth and CHIA at their listening session, which marked the kick-off of the Continuous Skilled Nursing (CSN) rate review process. And last Friday, HCA submitted written comments to the Department.

In our comments, HCA advocated for a ten percent rate increase across all CSN rates. In addition, HCA advocated that any increases should only be applied to agency-based rates, and not Independent Nurse rates. HCA has long communicated concerns over the lack of oversight in the Independent Nurse program, which puts safety and quality at risk for CCM members. Lastly, HCA conveyed its concerns regarding discussions of a wage pass-through provision being implemented in this program and the anti-competitive nature of pass-throughs and how it would threaten benefits, training, and support currently offered by provider home health agencies.

A copy of our comments can be found here.