CMS Finally Releases Updated ABN Form!

Providers will need to use the renewed ABN form starting this August.

CMS just released the long-awaited Advance Beneficiary Notice of Noncoverage (ABN). The current ABN form expired in March 2020, so CMS instructed providers to continue using the expired form, since the form’s renewal was on hold at the Office of Management and Budget during the Public Health Emergency. Yesterday, CMS posted the updated ABN Form CMS-R-131 and form instructions (see the Downloads section at the bottom of the linked page).

The renewed form (with the expiration date of June 30, 2023) will be mandatory beginning August 31, 2020.  The ABN is issued by home health and hospice providers to Medicare beneficiaries in situations where Medicare payment is expected to be denied. The ABN is issued in order to transfer potential financial liability to the Medicare beneficiary in certain instances. Guidelines for issuing the ABN can be found beginning in Section 50 in the Medicare Claims Processing Manual, 100-4, Chapter 30 (PDF).

Guidance for Home Health and Hospice Agencies on Admissions from Hospitals Related to COVID-19

The Alliance has unveiled detailed guidance for agencies regarding admissions from, and discharges to, hospitals related to COVID-19.

Today, the Home Care Alliance of Massachusetts unveiled detailed guidance for home health agencies regarding admissions from hospitals related to COVID-19. The guide is available as a Word document and providers are encouraged to create policies and procedures that reflect their own agencies’ operations, capabilities, and community/patient needs.

The guide was co-authored with Kimberly Skehan of Simione Healthcare Consultants. Because of the nature of the crisis, we are making this available to all agencies, regardless of current membership status.

Specific Topics Covered

  1. Screening and acceptance of home health or hospice patients who have been diagnosed with COVID19 from a hospital
  2. Denial of admission for a home health or hospice patient with known or suspected COVID-19
  3. Pre-visit COVID 19 Screening/Assessment
  4. In Home Visit Considerations for Known or Suspected COVID-19 Patients
  5. Personal protective equipment during home healthcare visits to patients and households with no signs and symptoms of COVID-19, or with a negative test
  6. PPE for a patient with signs and symptoms of COVID- 19, or with a positive COVID-19 test, or with pending test results:
  7. COVID-19: When to Discontinue Transmission-based Isolation Precautions
  8. Patient Education and Reassurance
  9. Hospice Inpatient Unit Considerations
  10. References (CDC guidelines)

For more on the novel Coronavirus, visit the Alliance’s COVID-19 Resource page. To learn more about how the Alliance serves its members and the home care industry, visit www.thinkhomecare.org/join.

Colleen’s Corner: Targeted Probe and Educate (TPE)

Did you know that National Government Service (NGS) is focusing one of the home health Targeted Probe and Educate on therapy utilization?

Therapy TPE Audits Lead to Home Health Denials

Did you know that National Government Service (NGS) is focusing one of the home health Targeted Probe and Educate on therapy utilization?

NGS is auditing home health rehab service concentrating on medical necessity, the timeliness of the 30-day reassessments that is performed in conjunction with an ordered therapy service, and the required reassessment content by each rehab discipline. For many of the denials, the reasons stem from the therapist not comparing the present assessment results to prior assessment measurements and failing to document the effectiveness of therapy, or lack thereof, as required by regulation.

It may be beneficial to review with your therapy staff the key components to the therapy reassessment documentation as outlined by CMS.

  • Each rehab discipline must document measurement results of functional reassessment compared to prior measurements
  • Each must also document why therapy should be continued or, if applicable, discontinued
    • Document therapist’s determination of effectiveness of therapy
    • Why therapy is beneficial?
    • Why does the patient need more?
  • Remember the re-assessment is only one component of the home visit; there must be evidence of an ordered intervention as well.
    • Document treatment performed the day of re-assessment
    • Re-assessment without care plan interventions is a not covered service

Be Aware…

If measurement results do not reveal progress toward goals and/or do not indicate that therapy has been effective — then, to continue therapy — there must be consultation with the physician and documentation showing why the therapist and physician determined therapy should be continued.

Don’t forget to confirm continuation of the therapy with the verbal order!

I hope to hear from folks who are experiencing any of these issues with the therapy TPE.

Colleen’s Corner: Quality Check

An Update on Quality Reporting Measures.

Did You Know?

The quality measure Improvement in Pain Interfering with Activity is being removed from Home Health Compare as of the April 2020 Compare Refresh. However, home health agencies are still collecting data for this measure through CY2020.

This quality measure will also be removed from the Quality of Patient Care Star Rating which will be calculated using seven measures beginning April 2020. Make sure to check how this will impact your agency’s star rating, so check out your Quality of Patient Care Star Rating Provider Preview Report in your agency’s CASPER Folders

The January 2020 Compare Refresh will be available this week, on January 23. CMS is no longer publicly reporting Emergency Department Use without Hospital Readmission During the First 30 Days of Home Health, and Rehospitalization during the First 30 Days of Home Health on Compare beginning with this January 2020 Refresh.

The OASIS Quarterly Q&As are scheduled to be posted on January 21, 2020.

Make your Star Ratings Rise to the Top

Provide focused education to your clinical staff with Blueprint for OASIS Accuracy training hosted by the Home Care Alliance on April 15-16, 2020 at the Sheraton Framingham Hotel & Conference Center, 1657 Worcester Rd, Framingham, MA.

Registration fills up fast so be sure to register early.

Click Here to Register

Haunted by TPE? Don’t Let It Frighten You!

Many home health care agencies have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE). Here are answers to many common questions.

Many home health care agencies (HHAs) have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE), so I thought I would review the rules because I am sure others have the same questions. NGS has contacted HCA to let us know that there are new TPE audits in Massachusetts: high therapy utilization, long lengths of stay, documentation supporting homebound for Heart Failure, COPD, Diabetes and Dementia, and medical necessity.

How Will the HHA Be Notified:  Agencies will receive a letter from NGS stating the focus of the targeted probe. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records. If you are currently in a TPE audit you will not be chosen for another. If for some reason you receive another TPE please contact Colleen Bayard because agencies should only be under one targeted probe and educate for home health at a time.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: Agencies will be notified of one-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

HHAs are Experiencing New Round of Targeted Probe and Educate

National Government Service (NGS) announces two new rounds of Targeted Probe and Educate (TPE) for home health agencies

Last month, the National Government Service (NGS) notified the Home Care Alliance of Massachusetts about two new rounds of Targeted Probe and Educate (TPE):

High therapy utilization. NGS will be reviewing documentation to ensure all CMS requirements have been met on therapy assessments and 30-day reassessments, as well as, medical necessity.

Documentation supporting homebound criteria. The second edit is specific to four diagnoses: Heart Failure, COPD, Dementia, and Diabetes and if the documentation confirms homebound status.

Many HHAs have contacted me over the past few weeks with questions about the TPE, so I thought I would review the rules because I am sure others have the same questions.

How Will the HHA be Notified: You will receive a letter from NGS stating the focus of the targeted probe: high therapy or homebound for one of the four diagnoses listed above. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: One-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

If you have any questions or concerns about TPE, it would be great to hear from you. Good Luck!

CMS Proposes Changes to HH Quality Reporting Program

Proposed Changes Could Result in Another Revision to OASIS in 2021! How will this impact you? HCA is looking for your input.

CMS is proposing several changes to the Home Health Quality Reporting Program (HHQRP) in the CY 2020 Home Health Proposed Rule.

The Rule proposes to eliminate one measure (OASIS Item M1242, Frequency of Pain Interfering with Patient’s Activity of Movement), add two new measures, and add several new Standardized Patient Assessment Data Elements (SPADEs) to the Outcome and Assessment Information Set (OASIS) in CY 2021. The revised OASIS for 2021 will be very different from the current OASIS data items collected by your clinical staff.

As required by the IMPACT Act, the proposed two new measures are:

    1. Transfer of Health Information to the Provider-Post-Acute Care (PAC)
    2. Transfer of Health Information to the Patient-Post-Acute Care (PAC)

These measures are designed to improve patient safety by ensuring that the patient’s medication list is accurate and complete at the time of transfer or discharge. These proposed measures also supposed to fulfill CMS’s strategic initiatives to promote effective communication and coordination of care, specifically in the Meaningful Use Initiative area of transfer of health information and operability.

In addition, CMS is proposing to adopt several standardized patient assessments (SPADEs) to the OASIS data set. CMS plans to implement three assessment screens for mental status, confusion/delirium, and mood. The special service, treatments, and intervention assessment require the agency to identify the services and treatment the patient is receiving and if they are taking any high-risk drugs. The assessment item for medical conditions and comorbidities checks for pain during specific activities and checks for hearing and vision impairments. Click click here to see the proposed Item Mockup for the “Transfer of Health” and the “SPADE”

According to the National Association of Home Care & Hospice (NAHC), the organization sees two possible approaches in addressing the proposed changes to the HH QRP.

    1. Recommend that CMS stagger the implementation of the assessment items over several HHQRP years. However, this would result in more iterations of the OASIS assessment tool, and any changes to the assessment tool carry its own burdens and costs; or
    2. Support the new assessment items with the condition that CMS issues a draft version of the revised OASIS data set no less than six months before the implementation date.

Please let the Alliance know how these changes will impact you.

Return to www.thinkhomecare.org.

ODF for Home Health and Hospice, March 5th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday,, March 5, 2014 at 2:00 PM

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 71246014

Proposed Agenda

1. Opening Remarks

2. Announcements & Updates

  • Hospice and Part D
  • Hospice Claims Reporting
  • Hospice & CAHS
  • Hospice Quality Update
  • FY2015 and FY2016 reporting cycles
  • Hospice CAHPS survey
  • HH CAHPS
  • Home Health Quality Update

For details visit the ODF Website

Return to www.thinkhomecare.org.

CMS Presents Jimmo v. Sebelius Manual Update

CMS is conducting a call on program manual updates related to the Jimmo v.Sebelius law suit on the CMS MLN Connects,  Thursday, December 19th at  2-3pm ET.  The program title is Program Manual Updates to Clarify SNF, IRF, HH, and OPT Coverage Pursuant to Jimmo v. Sebelius

To Register: Visit MLN Connects™ Upcoming Calls. Space may be limited, register early.

Agenda

  • Clarification of Medicare’s longstanding policy on coverage for skilled services
  • No “Improvement Standard” is to be applied in determining Medicare coverage for maintenance claims that require skilled care
  • Enhanced guidance on appropriate documentation

On January 24, 2013, the U. S. District Court for the District of Vermont approved a settlement agreement in the case of Jimmo v. Sebelius, involving skilled care for the inpatient rehabilitation facility (IRF), skilled nursing facility (SNF), home health (HH), and outpatient therapy (OPT) benefits. “Nothing in this Settlement Agreement modifies, contracts, or expands the existing eligibility requirements for receiving Medicare coverage.”

The goal of this settlement agreement is to ensure that claims are correctly adjudicated in accordance with existing Medicare policy, so that Medicare beneficiaries receive the full coverage to which they are entitled. The settlement agreement sets forth a series of specific steps for CMS to undertake, including issuing clarifications to existing program guidance and new educational material on this subject.

As part of the educational campaign, this MLN Connects™ Call will provide an overview of the clarifications to the Medicare program manuals. These clarifications reflect Medicare’s longstanding policy that when skilled services are required in order to provide reasonable and necessary care to prevent or slow further deterioration, coverage cannot be denied based on the absence of potential for improvement or restoration. In this context, coverage of skilled nursing and skilled therapy services “…does not turn on the presence or absence of a beneficiary’s potential for improvement, but rather on the beneficiary’s need for skilled care.” Portions of the revised manual provisions also include additional material on the role of appropriate documentation in facilitating accurate coverage determinations for claims involving skilled care. Target Audience
Skilled Nursing Facilities; Inpatient Rehabilitation Facilities; Home Health Agencies; and providers and suppliers of therapy services under the Outpatient Therapy Benefit

ODF on December 11th

Save the Date!

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, December 11, 2013 at 2:00 PM Eastern Time. If you wish to participate, dial 1-800-837-1935; Conference ID: 70980706.

Tentative Agenda:

I. Announcements & Updates

  • Ordering & Referring Physician
  • HHCAHPS
  • Home Health Rule Publication
  • Q Code Requirement

II. Open Q&A

III. Special Breakout Session with Q & A Hospice Item Set (HIS) and upcoming Training. Session starts promptly at 2:40 p.m.

Visit the Open Door  Forum Website for more information.

Return to www.thinkhomecare.org.

NB: The original post accidentally indicated that the forum was to be on December 11; the post has since been corrected.