President Clinton's proposal:

- Requires periodic recertification for home health agencies to ensure compliance with new policies;

- Increases the number of claims reviewed by 25 percent;

- Requires home health agencies to post a minimum surety bond of $50,000 and supply a proven track record in handling patients; and

- Requires disclosure of other businesses owned by home care agencies to ensure that costs of affiliated enterprises are not improperly shifted to Medicare.

We advocate taking President Clinton's proposals even further. VNAA recommends that:

- HCFA should determine the cause of the expansive variations in costs of care and utilization among different sectors of the industry;

- A per-episode prospective payment system for home health agencies should be implemented as soon as possible;

- HCFA should implement this year's budget legislation provision requiring that hospital patients be given full information on the availability of Medicare-certified home health agencies serving their local areas; and

- Hospital health systems should be prohibited from giving physicians with whom they maintain significant financial relationships direct financial incentives for increasing the volume of patient referrals to a system's particular home care agency.

While recent investigations have focused on for-profit provider agencies, we believe the current crisis in the home health care industry affects all of us. We all suffer from the negative publicity and loss of trust. Therefore, any agencies appearing to emphasize generating revenues more than helping to improve the health of patients must be sought out, removed and banned from participating in the Medicare program.

VNAA has worked hand in hand with for-profit agencies that share our dedication to bringing high-quality, skilled home nursing care to the communities we serve.

The need for home care has grown so rapidly that there is a place for both committed for-profits and non-profits. Working together toward the same goal quality care for our patients we can coexist competitively to make each other stronger businesses and better caregivers.

But our ability to do this will be hampered if the image of home health care providers continues to be tainted by the actions of those agencies that place profit-making before patients. The VNAA intends to work with authorities to monitor activities of home care organizations and will work diligently to advocate for government policies that eliminate fraud and abuse in the industry.

We resolve to be clearly at the forefront of efforts by President Clinton and others to ensure that patients have confidence in home health care. And we hope other agencies will follow our lead and join us in working together to bring about change in our industry, so that public and patient confidence and trust can be restored.

Carolyn S. Markey is chief executive of the Visiting Nurse Associations of America, a national non-profit membership organization and economic coalition representing more than 200 non-profit, community-based home and community health care providers.

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