The Granite State Home Health Assocation (GSHHA) — HCANH’s advocacy affiliate — submitted a comment letter this week on NH DHHS’s draft Choices for Independence Waiver Renewal Document. The State must renew the waiver with CMS every five years. DHHS must obtain public comments and offer responses prior to submitting the waiver renewal document to CMS.
The draft waiver renewal document proposes to allow CFI determinations and redeterminations to based on the MEA clinical tool and also include info from current MDS or OASIS assessments. GSHHA supports this expansion of assessment tools. The document also includes a biennial rate update, based on the Medicare home health PPS market basket update. GSHHA supports the HHPPS market basket update, but recommended that rates be updated annually.
DHHS also proposed to introduce “Participant Direction of Services,” which would enable CFI clients to hire individual nurses, home health aides, PCSPs and homemakers, and supervise them directly. After input from members and thoughtful consideration by our Board of Directors, GSHHA opposes the introduction of this new option. We believe that it does not provide appropriate safeguards for clients and is contrary to New Hampshire’s Nurse Practice Act and home health provider licensure laws.