HCA Responds to Questionable Northwestern U Study on Private Pay Home Care

The Home Care Alliance has responded to a Northwestern University report, titled “Hiring and Screening Practices of Agencies Supplying Paid Caregivers to Older Adults” that confuses different models of private pay home care and asserts that most aides are not properly screened or trained.  The report, from researchers at the NU Feinberg School of Medicine, appeared in the most recent issue of the Journal of the American Geriatrics Society.

The study authors telephoned agencies in Illinois, California, Florida, Colorado, Arizona, Wisconsin, and Indiana, pretending to be looking for home care for a family member.   The information provided by the agencies over the telephone was analyzed and some broad and negative conclusions were drawn about the lack of industry standard practices for background checks, training requirements, and supervision. The report was discussed this week in the New York Time’s “New, Old Age” blog in a post called “Who’s Watching Mom?

Please see the Home Care Alliance’s response to this report and feel free to use this in the event that your agency receive media inquiries.

Return to www.thinkhomecare.org.

Request for Responses for Consumer Consultants

MassHealth released an RFR to recruit “consumer consultants” that will assist with the review of applications from potential Integrated Care Organizations managing care for dual eligible individuals.

The demonstration project to better integrate and coordinate care for dual eligibles is still set to begin in January 2013 and the state remains on an aggressive pace to get the initiative underway. The RFR for Integrated Care Organizations (ICO’s) is due at the end of the month, and this separate RFR for “consumer consultants” is due July 20th.

These “consumers” must receive medical services, behavioral health services and/or long term services and supports (LTSS) from the state and will form a paid advisory subcommittee that shares its experiences and expertise with MassHealth and the state’s Executive Office of Health and Human Services.

The RFR is available on the state procurement website Comm-PASS as Document Number 13CBEHSCONSUMERCONSULTANTRFR and at this site on the Integrating Medicare and Medicaid for Dual Eligibles website under Related Information.

For those home care agencies that have patients with positive experiences of the care and services that have been delivered to them and that may be interested, please encourage them to apply.

Return to www.thinkhomecare.org.

CMS Home Health/Hospice Open Door Forum Tomorrow

The next CMS Home Health, Hospice, & DME Open Door Forum is scheduled for tomorrow, Wednesday, July 10, 2012 at 2:00pm ET.

To participate in this conference call, please dial (800) 837-1935 and use the conference ID 52259092. Participants are not required to RSVP and are asked to dial in at least 15 minutes prior to the call start time.

Two New ACOS Approved in Massachusetts

Health and Human Services (HHS) Secretary Kathleen Sebelius announced today the approval of 89 new Accountable Care Organizations (ACOs). The  89 new ACOs have entered into agreements effective July 1 with CMS, taking responsibility for the quality of care they provide to people with Medicare in return for the opportunity to share in savings realized through high-quality, well-coordinated care. Among the 89, there are two in Massachusetts:

  • Circle Health Alliance, LLC, located in Lowell, Massachusetts, is comprised of partnerships between hospitals and ACO professionals, with 353 physicians. It will serve Medicare beneficiaries in Massachusetts and New Hampshire.
  • Harbor Medical Associates, PC, located in South Weymouth, Massachusetts, is comprised of ACO group practices, with 116 physicians. It will serve Medicare beneficiaries in Massachusetts.

The 89 ACOs announced today bring the total number of organizations participating in Medicare shared savings initiatives to 154.  Of these, there are already five entities in Greater Boston designated as Pioneer ACOs  by CMS’ Center for Medicare and Medicaid Innovation (Innovation Center) announced last December.  There are an additional two physician  practice demonstrations, one south of Boston, the other on Cape Cod.

For 2012,  CMS has established for all ACOs 33 quality measures relating to care coordination and patient safety, appropriate use of preventive health services, improved care for at-risk populations, and patient and caregiver experience of care.

CMS Releases Proposed PPS rates for 2013

CMS on Friday released an advance copy of the proposed regulation for changes to the home health PPS rates for calendar year 2013.

Brief highlights:

• The proposal increases the national base episodic rate by 0.16%, from $2,138.52 to $2,141.95.  (calculated using a 2.5 percent inflation update, a 1 point reduction mandated by the health care reform law, and a 1.32 percent case mix creep adjustment.)

• The portion of the rate adjusted by the wage index is increased from .77082 to .78535

• The county wage index is available here (click on the “download” at the bottom of the page).:

Here are changes for MA counties:

Current                2013

Barnstable                        1.2838                   1.2872
Boston                              1.2283                   1.2394
Middlesex                         1.1210                   1.1285
Essex                               1.0698                   1.0575
erkshire                            1.0616                   1.0745
Bristol                               1.0639                   1.0718
Springfield                        1.0247                   1.0390
Worcester                         1.1076                   1.1230
Dukes/Nantucket              1.3962                   1.3570

The proposed rule also:

  • allows certain non-physician practitioners in inpatient settings to conduct the required Face-to-face encounter;
  • increases flexibility in complying with the therapy reassessment requirements;
  • establishes hospice quality reporting requirements to begin in 2014, including various proposed measures to report;
  • creates an Informal Dispute Resolution process that agencies can use to dispute survey deficiencies;
  • establishes a range of “Intermediate Sanctions” for non-compliance with the Medicare Conditions of Participation, including civil money penalties, suspension of payment for new admissions, and temporary management.

The Alliance will conduct a thorough analysis of the proposed rule and prepare comments.  Watch for additional details in the next few weeks.

Comments are due by Sept. 4.

Medicare Home Health Proposed Rule Issued: Clarifications and Improvements on Therapy Assessment Rules

The  Medicare Home Health Proposed Rule was release last week. Among proposed payment changes, Face to Face clarifications, and new sanctions for non-compliance with federal requirements, the Therapy Assessment Rule is also slated for changes and improvements. But are all of these proposed changes really improvements to this Therapy Rule?

Clearly an improvement to the rule—CMS proposes to revise the regulations to state that if a qualified therapist missed a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, not the visit after the therapist completed late reassessment.— Currently, when a qualified therapist misses one of the required reassessment visits, once the therapist has completed the required reassessment, coverage resumes after this reassessment visit.

In addition, CMS proposes to revise the regulations to state that” in cases where multiple therapy disciplines are involved, if the required reassessment visit was missed for any one of the therapy disciplines for which therapy services were being provided, therapy coverage would cease only for that particular therapy discipline”. Therefore, as long as the required therapy reassessments were completed timely for the remaining therapy disciplines, therapy services would continue to be covered for those therapy disciplines. Again this change appears to work in favor of the provider. — Currently the regulation states,  even if qualified therapists from the other therapy disciplines have completed all their required reassessment visits, therapy visits for these disciplines would not be covered until the qualified therapist who missed the reassessment visit has completed the previously missed reassessment visit.

This last change has potential to cause headaches for scheduling the multi-therapy visits. —CMS is proposing a change to allow “flexibility” and guidance to the provider.  This change would be applicable in cases where beneficiaries are receiving more than one type of therapy; the qualified therapists could complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th visit for the required 19th visit reassessment. — Currently the regulation states that therapist’s visit need only be “close to” the 13th and 19th visits. This proposed revision does not appear flexible but rather has great potential for scheduling patients’ visits for three disciplines to be extremely inflexible. Hopefully stakeholders will comment on this proposed change.


Skilled Teaching for Dementia Patients

NHIC, Corp. has just released a medical policy article that addresses a specific category of skilled nursing care currently available to Medicare home health beneficiaries who have dementia with behavioral disturbances; A51856 Home Health Skilled Nursing Care: Teaching and Training for Dementia Patients with Behavioral Disturbances.  The category of skilled nursing is called “teaching and training activities”, defined in the CMS Manual System. The Medicare beneficiaries with dementia and behavioral disturbances could receive a patient-centered care plan directed at teaching the family or caregiver how to manage the behavioral disturbances.

Refer to Article A51856 for sample case scenarios and details on documentation, coding guidelines, and potential interventions

Return to www.thinkhomecare.org.