Author: Colleen Pierro

Introducing Home Health 101

Introducing Home Health 101, our new online orientation for home health clinicians and managers, with a focus on compliance regulation.

Have you hired staff new to home health care? Need a refresher on the basics of home health compliance? Due for a review on the latest regulation changes?

As the Alliance’s director of clinical and regulatory affairs, I’m often asked these questions from members looking to ensure that their clinical staff and managers have the tools they need to successfully navigate the regulatory challenges they’ll face in home health. In the past, I’ve done in-person presentations on this material but now—to ensure that even more people have access to it—I’m pleased to announce that Home Health 101 is available digitally for the first time.

In Home Health 101, I highlight the Conditions of Participation standards (COPs), Medicare regulations related to the survey process, and how the survey process works. 5 CEU credits are available (for a small processing fee) to those who complete the course and pass an evaluation.

Learn More
Purchase HH101

Objectives include how to:

  • Review the Home Health’s Conditions of Participation (COPs);
  • Identify three of the five criteria for Medicare certification for home health benefit;
  • Understand Requirements for Physician Orders and Face-to-Face (F2F);
  • Identify Medicare’s definitions of “confined to home”; and
  • Review patient notices.

The program is broken into five sections:

  • Part 1: Orientation to Home Health
  • Part 2: Conditions of Participation (CoPs)
  • Part 3: Patient Notices
  • Part 4: Conditions of Participation, Contin.
  • Part 5: Skilled Professional Services and HHA Services

Alliance Releases COVID-19 Vaccines Guidance

To help members stay abreast of developments regarding COVID-19 vaccines, the Alliance has developed a guide that puts everything you need in one place.

To help member agencies (and the public) stay abreast of developments regarding COVID-19 vaccines, the Home Care Alliance of Massachusetts has developed a reference guide that puts everything you need in one place.

What You Need to Know About the COVID-19 Vaccines is based on guidance from the Centers of Disease Control (CDC) and Massachusetts Department of Public Health (DPH).  We are committed to keeping this guidance updated as new information becomes available and as additional vaccine products are authorized.

Return to www.thinkhomecare.org.

Photo by CDC on Unsplash

NGS Resumes Home Health Medical Record Review

NGS will resume medical record review after suspension from Public Health Emergency

National Government Services (NGS) recently contacted Alliance staff to review details for the resumption of medical record reviews. This follows the suspension of the Targeted Probe and Educate (TPE) audit because of the Public Health Emergency. We expect that this review will start this week. All the Medicare Administrative Contractors (MACs) will publish information indicating that medical reviews will resume.

NGS has shared some details with Alliance staff about this resumption, which are summarized below; however, the details are not yet posted on their website.

    • NGS will resume post-payment medical reviews. This is different than the TPE program. CMS has not provided any direction to the MACs thus far regarding the resumption of TPE.
    • The post-payment reviews are service-specific (as opposed to provider-specific) and will be a random sample. A service-specific review is one where the MAC is focused on the claim and not the provider.
    • CMS has given a resumption date of August 17, 2020. It is anticipated that providers will begin receiving Additional Documentation Requests (ADRs) once NGS posts more information on their website. NGS indicated it will post a brief description of the service-specific audits on its website and ADRs will be sent approximately 2-3 days after this posting.
    • The timeframe from which NGS will pull claims is January 2019 through February 29, 2020
    • The maximum number of claims to be pulled per provider is 20. There is no minimum. This is less than the total number under the TPE program, and a provider may or may not receive ADRs for a full 20 claims. It is anticipated that the majority of hospice and home health providers will not have this many claims pulled. Any providers having difficulty responding to the ADRs on time should contact NGS and they may be able to work with the provider if the provider makes them aware of the situation.
    • Providers should not wait to receive an ADR request in the mail, but should check the status of their claims processing and identify any with the S B6001 status. These are claims that have had an ADR generated.
    • NGS has 60 days to review the provider’s response to the post-payment ADR. Though providers have 45 days to respond to the ADR, a 30-day response is strongly recommended to ensure that the response is received and recorded by the 45th day.
    • A results letter will be sent after each claim is reviewed.
    • A provider may request education and the NGS may suggest education. Providers are not required to participate in education, although the Alliance strongly recommends it.
    • The error rate (payment error rate or claim error rate) is not as important with a service-specific post-payment review as it is with TPE, since there are no “rounds” in post-payment review as there are with TPE. The MACs are not setting error rate thresholds upon which further NGS action is predicated. As with all medical reviews, if NGS identifies a concern, i.e. a quality concern or indication of potential fraud or abuse, NGS will refer to the appropriate entity (i.e., the appropriate QIO or the division of CMS).
    • NGS will continue to make phone calls to providers for missing documentation or questions about documentation submitted.

It is still possible that providers will receive some other ADRs as part of other review programs such as CERT. CMS contractors, including Unified Program Integrity Contractors, may conduct targeted prepayment and post-payment reviews when there is evidence of potential fraud or gaming. CMS has not yet indicated if the results of the post-payment reviews that are resuming this month would be used for future TPE audits.

If you have any questions, please contact Colleen Bayard at cbayard@thinkhomecare.org.

DPH Released Updated Guidance on PPE Use

DPH has adopted a universal facemask use policy.

On July 6th, the Massachusetts Department of Public Health (DPH) updated the Comprehensive Personal Protective Equipment (PPE) Guidance based on CDC recommendations to clarify the PPE that health care personnel (HCP) use in a clinical care area, especially during this time when providers are trying to optimize PPE supplies. Although this guidance is specifically written for health facility use, there are some best practices that may be helpful for home health agencies when reviewing and updating their protocols.

In this updated guidance DPH has adopted a universal facemask use policy for health care personnel, to use at all times when in the clinical setting.  Facemasks are defined as surgical or procedure masks worn to protect the mouth/nose against infectious materials.  Homemade and cloth facemasks are not considered PPE. Their capability to protect HCP has not been demonstrated and they have not been shown to be effective in preventing transmission of illness.

DPH also updated the guidance regarding the use of KN95 respirators to be consistent with the Food and Drug Administration (FDA) update to the Non-NIOSH Approved Respirator Emergency Use Authorization (EUA) concerning non-NIOSH-approved respirators that have been approved in other countries.   Consistent with the FDA’s updated EUA, KN95 respirators may be considered for use as a substitute for N95 respirators only if:

  • N95 respirators are not available, and
  • The KN95 respirators have been tested for filtration effectiveness, and
  • The use of KN95 respirators has been approved by your organization.

If a N95 respirator or equivalent is not available, a facemask should be used.

For more details on optimizing PPE refer to the updated guidance.

Image Credit: NurseTogether / CC BY-SA (https://creativecommons.org/licenses/by-sa/4.0)

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.

Download the Guide

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!

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