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.

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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
  • Home Health Quality Update

For details visit the ODF Website

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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.


  • 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
  • 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.

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

Home Health ODF: Ask-the-Contractor Teleconference

National Government Service’s  Home Health Open Door Forum: Ask-the-Contractor Teleconference (ACT) is scheduled for Tuesday, December 10, 2013 from 1:30-3:00 pm  This teleconference will provide updates to the home health provider community and a forum for questions and answers. The ACT is an opportunity to speak directly to the contractor, so please have your questions ready for the contractors to answer!

Date: Tuesday, December 10, 2013
Time: 1:30-3:00 p.m. ET

Register for session

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Good News! HIPPS Codes for Medicare Advantage Claims Delayed

Health Insurance Prospective Payment System (HIPP)S codes on Medicare Advantage (MA)  plan claims will be delayed until July 2014 according to information from NAHC.  Bellow is an excerpt from a letter CMS sent to the health plan.

”MAOs and other entities were instructed that effective December 1, 2013 dates of service (DOS), the disposition for the HIPPS codes edits would be changed from ‘Informational’ to ‘Reject’ for any Skilled Nursing Facility (SNF) and Home Health (HH) encounters submitted without the appropriate HIPPS codes. The purpose of this notification is to let you know that the December 1, 2013 DOS ‘Reject’ edit will be delayed to July 1, 2014 DOS. The ‘Informational’ edit for HIPPS codes would remain in place until that time.”

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Deadline Approaching for OSHA’s Hazard Communication Standards Training

To better protect workers from hazardous chemicals, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (HCS) aligning it with the United Nations’ global chemical labeling system. There will be new labeling and data sheets on chemicals according to the Globally Harmonized System (GHS). GHS is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets.

OSHA is requiring all employers, including home health and hospice, to train all employees on the revised hazard communication labels and data sheets elements (e.g., pictograms and signal words) by December 1, 2013. The Hazard Communication Standard, will be fully implemented in 2016 and benefit workers by reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards, especially for low literacy workers. OSHA’s standard will classify chemicals according to their health and physical hazards, and establish consistent labels and safety data sheets for all chemicals made in the United States and imported from abroad.

Further information can be reviewed at OSHA’s Hazard Communication Safety and Health which includes links to OSHA’s revised Hazard Communication Standard and guidance materials such as Q and A’s, OSHA fact sheet and Quick Cards.

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CMS Posts Clarification of the Definition “Confined to Home”

On October 18th, Centers for Medicare & Medicaid Services (CMS) released Change Request 8444Home Health Clarification of Benefit Policy Manual Language on Confined to Home.  This Change Request requires Medicare contractors to be aware of the clarification of the definition “confined to the home” as stated in the revised section 30.1.1 of Chapter 7 of the “Medicare Benefit Policy Manual”. In addition, CMS removed vague terms, such as “generally speaking”, to ensure the definition is clear and specific. CMS has also release a MLN Matters for provider reference. The implementation date for this clarification is November 19th, 2013

CMS is amending its policy manual as follows:

For purposes of the statute, an individual shall be considered “confined to the home” (homebound) if the following two criteria are met:


The patient must either:

Because of illness or injury, need the aid of supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person in order to leave their place of residence


Have a condition such that leaving his or her home is medically contraindicated.

If the patient meets one of the Criteria-One conditions, then the patient must ALSO meet two additional requirements defined in Criteria-Two below.


There must exist a normal inability to leave home;


Leaving home must require a considerable and taxing effort.


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Government Shutdown Delays Quarterly OASIS Q&As

Due to the government shutdown, the CMS OASIS Quarterly Q&As will not be released on October 16, 2013 as previously expected. As soon as the government reopens for business, the Q&A release will be rescheduled and the HCA will post the results in our Update

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CMS Issues HHA Reporting Requirements- CR-8441

HHA Reporting Requirements for the Certifying Physician and the Physician Who Signs POC

CMS has issued Change Request 8441 which instructs home health agencies to report the NPI and name of the physician who certifies the patient for home health services and to also report the NPI and name of the physician who signs the POC. CMS is instructing agencies that both the attending physician and the other physician fields should be completed even if the certifying physician is the same as the physician who signed the plan of care. The additional reporting requirements do not go into effect until July 1, 2014.

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