Essay on Health Professionals and Policy Implementation: The Role of Interested Parties

Introduction

When Congress passes a policy, Executive Branch agencies formulate and revise rules for the policy implementation. Interested parties may comment on these rules, and a policy competent organization tracks when the rules are considered and offers commentary (Longest, 2002). Health professional actively participate in the implementation phase of policies and influence decision using expertise (Longest, 2002). Health professionals are involved through demonstrations, interaction with advisory commissions and bodies of health policy advisory, and involvement in rulemaking. Through the website, (www.regulations.gov), health professional participates in rulemaking by submitting comments electronically. The following assignment uses information from the regulations government website, which facilitates participation in the rulemaking process for professionals such as those in the health sector to answer the questions provided in the template.

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Regulation 1: Medicare and Medicaid Programs: Home Health Prospective Payment System Rate Update, etc. ID: CMS-2017-0100-0002

Describe the issue of the pending regulation. The main issue is updating the home health prospective payment system (HH PPS) payment rates effective for episodes of care in home health for the period ending on or following January 1, 2018 (Regulations.gov, 2017c).

Who has sent in comments that are available for reading? Most of the comments have been sent by home healthcare groups such as Graham Healthcare Group and individual professionals in the healthcare such as physical therapist assistants.

In general, how influential do the various comments seem? Why? Give specific examples. Very influential. Home care organizations and professionals dispute the regulations based on facts and experience. For example, most comments recommend a budget-neutral implementation manner.

What is the general trend of the comments or do they differ dramatically? The comments seem to oppose the regulation citing the adverse impacts like an undue burden on both agency and patients. The comments do not differ significantly.

What, if any, comment would you have recommended Allen Care System should make during the comment period? I would recommend that the CMS defers the implementation of the regulation and seek input from external stakeholders like home health organizations. This will help to curb the adverse impact of the regulation and obtain better ways to implement the regulation.

Regulation 2: Medicaid Program: State Disproportionate Share Hospital Allotment Reductions. ID: CMS-2017-0101-0002

Describe the issue of the pending regulation. Delineates an implementation methodology for the annual allotment reductions to state Medicaid "Disproportionate Share Hospital" (DSH) allotment as required by the Affordable Care Act (Regulations.gov, 2017a).

Who has sent in comments that are available for reading? Healthcare facilities such as hospitals, health teaching institutions, and employees at these institutions are the major contributors of the comments.

In general, how influential do the various comments seem? Why? Give specific examples. The comments are very influential as they are practical. For example, a comment by Fairview Park hospital illustrates adverse impacts such as service cuts and staffing reduction due to the regulation.

What is the general trend of the comments, or do they differ dramatically? A general trend in the comment is an opposition to the regulation as it will affect service delivery at the facilities as consequences include services cuts to the community.

What, if any, comment would you have recommended Allen Care System should make during the comment period? That the proposal is not supported as uncompensated care has not been achieved. The DSH funds are crucial in ensuring quality health care delivery as hospitals incur losses from treating low income uninsured citizens.

Regulation 3: Medicare and Medicaid Programs: Conditions of Participation for Home Health Agencies; Delay of Effective Date CMS-3819-P2. ID: CMS-2014-0132-0196

Describe the issue of the pending regulation. The issue under this regulation is that the effective date set for this regulation is delayed from January 13, 2017, for an extra six months (Regulations.gov, 2017b).

Who has sent in comments that are available for reading? Comments are from health practitioners such as physical therapist in a home health facility, Association such as Alzheimer's Association, and from Home Healthcare such as Pinnacle Home Healthcare.

In general, how influential do the various comments seem? Why? Give specific examples. The comments are influential as they give direction for the time needed for implementation and areas of clarity. For example, Kristin Hessel, Manager of Quality Improvement, Pinnacle Home Healthcare, asks CMS to consider time for implementation, Providing Patient Plan of Care, and all revisions to the patient. This information could be used in the better formulation of the final rule.

What is the general trend of the comments, or do they differ dramatically? Most comments agree with the regulation set in place and commend it for being patient-driven, enhancing patients' rights protection, and driving improved patient care quality. The standard-issue seems to be the timeframe for the implementation.

What, if any, comment would you have recommended Allen Care System should make during the comment period? That CMS extend the timeframe and address concerns from different parties such as those seeking clarification on various areas such as criterion for investigating injuries from an unknown source. This would allow for a comprehensive regulation in the final rule.

References

Longest, B. B. (2002). Health policymaking in the United States.

Regulations.gov. (2017). Medicaid Program: State Disproportionate Share Hospital Allotment Reductions. Retrieved from https://www.regulations.gov/document?D=CMS-2017-0101-0002

Regulations.gov. (2017). Medicare and Medicaid Programs: Conditions of Participation for Home Health Agencies; Delay of Effective Date CMS-3819-P2. Retrieved from https://www.regulations.gov/document?D=CMS-2014-0132-0196

Regulations.gov. (2017). Medicare and Medicaid Programs: Home Health Prospective Payment System Rate Update, etc. Retrieved from https://www.regulations.gov/document?D=CMS-2017-0100-0002