Alliance Submits Comments on PPS and Survey Rules

The Alliance today submitted comments to CMS on the proposed changes to the Medicare PPS rates for 2013 and the proposed new alternative sanctions in the survey enforcement process.  Specific issues that the Alliance addressed include the case mix creep adjustment, wage index concerns, proposed changes to the face-to-face and therapy reassessment requirements, and proposed Alternative sanctions—including civil money penalties – for agencies with condition-level deficiencies.  The Alliance’s comments are available on our website here

Alliance members are strongly encouraged to submit their own comments on the federal Regulations website.  Enter “CMS-1358-P” in the search box to find the PPS regulation, and follow the instructions to submit your comments.  Comments are due by September 4.

Mass. Thanks HCA and Members for Survey Participation

The state’s Executive Office of Health and Human Services thanked the Home Care Alliance and member agencies who participated in the recently completed Direct Service Workers (DSW) Survey.

A comprehensive report of the survey results is underway and those results will be available Fall 2012. Results will be shared with all providers who received the survey. Below is part of the ‘thank you’ statement:

Thanks in large part to outreach assistance provided by Home Care Alliance of Massachusetts, we received a survey response rate of 36%.  We’re happy to announce that the federal contractor, The Lewin Group, who has provided assistance through the survey process, is preparing a report which will include an analysis of the Massachusetts survey results. The Lewin Group anticipates this report will be ready for distribution by the end of September and we plan to share the report, along with additional survey results and analysis, with all providers who received the DSW Employer Survey.  We will distribute the report by email and will send a postcard to all providers asking them to submit an email address for this purpose.

The Direct Service Worker Employer Survey is a collaborative effort with the Home Care Alliance of Massachusetts and Massachusetts Council for Home Care Aide Services, Inc. to collect state-specific data on the home and community-based direct service workforce including volume, stability, wages and compensation.

According to EOHHS, information from this survey will be used to develop ways to attract more workers and keep workers longer.  The information from this survey can also assist organizations in understanding how they compare to other organizations in Massachusetts, and how organizations in Massachusetts compare to those in other states. Survey results will be used to better understand the current state of the direct service workforce in Massachusetts and areas for policy improvement.

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Compliance Date for ICD-10 Announced

The deadline for the transition to ICD-10 is October 1, 2014.

Health and Human Services Secretary Kathleen Sebelius announced the release of the rule that makes final a one-year proposed delay—from October 1, 2013, to October 1, 2014—in the compliance date for the industry’s transition to ICD-10 codes. Secretary Sebelius first announced the proposed delay in April, as part of President Obama’s commitment to reducing regulatory burden.

Keep Up to Date on ICD-10,visit the ICD-10 website for the latest news and resources to help you prepare.

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Be Prepared: Audit Activity on the Increase

Locally, regionally and across the nation, home care agencies are reporting increased federal scrutiny.  Every agency should be especially attentive to regulatory compliance.

The Boston Office of the HHS Inspector General is visiting many agencies across New England to conduct an audit of OASIS processes, with a focus on proper and timely submission of the OASIS to the state. They are looking closely at evidence of the OASIS transmission to the State before the submission of the claim, as well as at each agency’s process to review “fatal errors” and validation reports. We believe as many as 70 agencies may ultimately be asked for records.  We have not heard of any results or payment penalties as yet as a result of these audits.

Agencies also report that as a result of the submission of their Medicare Provider Enrollment Application (CMS 855a), federal inspectors are visiting on site to verify – often with camera’s – that the physical address reported on the form is operational.

Finally, it appears the ZPIC – Zone Program Integrity Contractors – are moving into home health. Unlike RACs which just look at  overpayment issues, the ZPICs are tasked with assisting HHS in discovering fraudulent practices.  A fairly detailed legal explanation of the roles of these federal contractors can be found here.

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Last Chance to Apply for CMS Community-Based Care Transitions Program

The final deadline for applications for the Community Based Care Transitions Program, administered by the Center for Medicare and Medicaid Innovation (CMMI), is quickly approaching.

Any interested applicants must have their proposals in by September 3rd to make the final panel review on September 20th. Any interested home health agencies can contact James Fuccione at the Home Care Alliance for assistance. Additionally, CMMI has made a slide deck available with everything health care providers and community-based organizations need to know for the application process.

Recently, there were 17 proposals that were accepted in the third round of site selections and, again, a Massachusetts project was among them. Here is the “site summary:”

Somerville-Cambridge Elder Services, a Massachusetts-designated Aging Services Access Point (ASAP) and an Area Agency on Aging (AAA), is partnering with Mystic Valley Elder Services,  two large integrated hospital networks (Cambridge Health Alliance and Hallmark Health System) and dozens of community-based health and social service providers to provide care transitions services to high-risk Medicare beneficiaries throughout Middlesex County, Massachusetts.

For more on HCA’s work on care transitions issues, see these blog posts.

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HCA Continues Response to Home Care Aide Report

Picking up on news stories developed by the New England Center for Investigative Reporting,  WCVB-TV in Boston plans to run a television story on the private pay home care industry, with an expected focus on the state’s lack of licensure of agencies.    While both the New England Center and WCVB have been looking for cases of private care elder mistreatment, both stories appear focused on a single case of an aide who stole from multiple clients before being charged and convicted in both the Brockton and Wareham District Courts.

Alliance Executive Director Patricia Kelleher was interviewed by WCVB for the news story.  During the interview, Ms. Kelleher emphasized the following points:

  • While no abuse is to be tolerated, instances of theft or abuse are very rare given the thousands of clients and million of visits in a given year.
  • The Alliance had filed licensure legislation in 2010 that was not passed.
  • In response to no legislative action, the Alliance and its private care members developed a rigorous industry accreditation program that establishes high standards for worker screening and training, organizational management and workforce safety.
  • Prospective clients in Massachusetts are fortunate to have a robust industry with many options to choose from.  Educated consumers are our best clients.

The Home Care Alliance has also placed letters to the editor in two major Massachusetts daily newspapers to clarify some points in the story. See HCA’s letters in the Worcester Telegram & Gazette and the Springfield Republican.

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‘Home Care Votes’ Program is Back

With the deadline to register to vote rapidly approaching on August 17, the state primary election just around the corner (September 6), and the state’s general elections not far past that (November 6), the Home Care Alliance is encouraging its member agencies across the state to help “get out the vote.”  

The Alliance has a fact sheet with instructions and a sample press release (available upon request) for those agencies willing and interested in helping their homebound patients obtain absentee ballots so they can vote in the upcoming elections. With important policy issues looming, this program is a great way to mobilize a population that may not otherwise have the chance to have their voices heard.

For those interested in obtaining the sample press release, contact James Fuccione at the Alliance.

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