Author: Colleen Pierro

CMS Releases Updated Q&As for F2F and Therapy

On February 28th, CMS released updated Q&As for the F2F Encounter and Therapy Reassessment requirements on the Home Health Center Web Site.

The revised F2F Encounter Q&As are essentially the same with clarification that the agency may title and date the encounter form if the physician fails to date his/her signature. (Question 17; page 6-7)

The revised Therapy Q & As provide several examples of when therapy visits would be non-covered, when the reassessment visit is missed, and clarifying when assessments are due in relation to “at least every 30 days”  according to the revised regulation effective Jan 1, 2013,

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Free Webinar on Establishing a Palliative Care Program

The Home Care and Hospice Financial Managers Association (HHFMA) will hold a free webinar: Palliative Care: A Business Analysis of the Pros and Cons of Establishing a Palliative Care Program. Presented by Daniel Maison, MD, Medical Director, and Larry Oberst, CPA, CFO, both of Spectrum Health Palliative Care Program.

Friday, Feb. 15, 2013
3:00 to 4:00 PM EST
Program Description:

Does your organization think about starting a palliative care program? What are palliative care services and where are these programs delivered? What are the factors to consider when developing a palliative care program? This program covers all of those bases and more to help  decide whether to start a palliative care program.

Webinar Objectives:

  1. Define what it takes to make a case for palliative care services;

  2. Identify how palliative care programs are delivered and financed; and

  3. Identify when palliative care programs should be integrated with home health and other providers.

To Register- Click Here

(If you cannot attend live, the webinar will be recorded and archived on the HHFMA website)

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February ODF

The next Home Health, Hospice & Durable Medical Equipment  Open Door Forum is scheduled for Wednesday, February 20, 2013 from 2:00pm – 3:00pm, ET.  To participate by phone, dial 1-800-837-1935; Conference ID: 78869441. The agenda will be posted before the call on the ODF Website

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ICD-10: Take Readiness Survey

CMS and the Workgroup on Electronic Data Interchange (WEDI) are conducting a survey on healthcare industry readiness for ICD-10. The purpose of the survey is to closely track industry progress in order to identify areas where additional focus may be needed. The survey is open through Wednesday, February 20, 2013 and available to any individual associated with health care organizations

The online survey, located at https://www.surveymonkey.com/s/WEDISurveyICD-10, will be used by WEDI and the Centers for Medicare & Medicaid Services to evaluate challenges and identify areas in need of additional education and assistance. This is a great opportunity to provide input about your readiness for the ICD-10 transition in 2014.

WEDI’s Survey on Industry Progress Now Open

The Workgroup for Electronic Data Interchange (WEDI) is conducting its latest online ICD-10 Industry Progress Survey. The survey will help CMS and WEDI:

  • Measure the health care industry’s ICD-10 progress
  • Evaluate challenges and identify areas where industry needs more education and assistance

The survey is open to all individuals associated with health care organizations, including vendors, health plans, providers, and payers.

Before taking the online survey, please scroll to the link at the end of the WEDI survey press release to preview the questions. The press release also includes a link to the online survey form.

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Invitation to Comment on QIO Changes

CMS’s Center for Clinical Standards and Quality (CCSQ) is inviting providers to offer input on plans for redesigning the Quality Improvement Organization (QIO) Program. By law, the mission of the QIO Program is to improve the effectiveness, efficiency, economy, and quality of services delivered to Medicare beneficiaries. QIOs convene providers, practitioners, and patients to build and share knowledge, spread best practices, and achieve wide-scale improvements in patient care, increases in population health, and decreases in health care costs.

CMS has just released the slides from the January 24th Special Open Door Forum, Future Development of the QIO: Getting Your Feedback.  This invitation to provide comments on the future development of the QIO is an excellent opportunity for home health agencies to request the support and resources they deserve in the QIO program. Home health has been left out of the last two Scope of Work (SOW) plans, which focused on hospital and skilled nursing facilities. The 8th SOW was the last time the QIO focused on home health.

Home health agencies should write to CMS and advise them of ways that QIOs can provide home care with guidance and tools to effectively care for the millions of Medicare beneficiaries they serve, help them learn to comply with their treatment regimens, trouble shoot  potential complications, and avoid costly emergent care and institutional services, as well as expand their involvement in preventative services,

Please share your comments and ideas on the role Quality Improvement Organizations can play in home health.  Submit your comments to OCSQBox@cms.hhs.gov by Friday, February 8th at 5:00 p.m. ET

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New Edits on Hospice Claims

Recently, CMS released Change Request (CR) 8142 – Hospice Monthly Billing Requirement, effective date of change- July 1, 2013. The CR instructs Medicare contractors to implement a system edit to return hospice claims to the provider when there is more than one hospice claim per month per beneficiary. The only exception to this requirement is in the case of the beneficiary being discharged or revoking the benefit and then later re-electing the benefit during the same month.

Medicare contractors will also implement a system edit when the provider submits claims that span more than one calendar month.  Any hospice claim spanning multiple months will be returned to the provider for correction.

This is not new policy but is a new enforcement.  After July 1, 2013 claims not in compliance with the monthly billing requirement will be returned to providers.  A corresponding MedLearn Matters article is expected to be posted in the near future.

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CMS Clarifies Titling and Dating F2F

Good News for HHAs…

Face to Face (F2F) changes finalized in the 2013 Home Health PPS update Federal Register notice are effective for episodes ending on or after 1/1/2013.  In this notice the Centers for Medicare & Medicaid Services (CMS) wrote: “We are finalizing regulatory text changes as proposed. The regulation text will be changed to not be prescriptive as to what entity needs to date and title the face-to-face documentation, but will still require the same content and the certifying physician’s signature.”

The National Association for Home Care & Hospice (NAHC) in an effort to clarify the intent of changes related to titling and dating F2F encounter documentation, asked the CMS to confirm whether home health agencies are now permitted to title and date F2F encounters, and to clarify what “date” the change is referring to.

In the response received by NAHC, CMS wrote: “the new regulations are not prescriptive as to what entity may date/title the encounter documentation.” CMS further qualified this statement saying “to comply with documentation requirements, the face-to-face encounter document has to have two dates: the date of the encounter and the date of the documentation. Our new regulations are not prescriptive as to who can title or date the form, but the form must be signed by the physician. As such, the HHA may add the title and the date of the documentation if this was not done by the physician.”

CMS also reported to NAHC that, “if the physician does not date next to his/her signature, then it would be acceptable for the HHA to date the documentation and consider it the “date of documentation.” This date does not need to be the date that the physician affixed his/her signature in cases where the physician did not date the form at the time of signing.”

This change in the regulation will ease the burden for home health agencies for all the times when they needed to return the F2F document back to the physician  because of a missing date.  In the near future, CMS plans to update its Manuals and F2F Questions and Answers to address the F2F regulatory and policy changes detailed in the 2013 Home Health PPS update Federal Register notice.

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Judge Approves ‘Improvement Standard’ Settlement

On January 24, 2013, the Chief Judge of Vermont’s U.S. District Court gave her approval  during a scheduled fairness hearing for an ‘improvement standard’ settlement (Jimmo v. Sebelius).  This settlement could lead to more long-term care in the home health setting and open the benefit to patients who were previously denied coverage.

According to The Center for Medicare Advocacy, that helped litigate the case on behalf of beneficiaries, “With the settlement now officially approved, the Centers for Medicare & Medicaid Services (CMS) is tasked with revising its Medicare Benefit Policy Manual and numerous other policies, guidelines and instructions to ensure that Medicare coverage is available for skilled maintenance services in the home health, nursing home and outpatients settings. CMS must also develop and implement a nationwide education campaign for all who make Medicare determinations to ensure that beneficiaries with chronic conditions are not denied coverage for critical services because their underlying conditions will not improve.”

It should be noted that the Settlement Agreement standards for Medicare coverage of skilled maintenance services applies immediately, The Center of Medicare Advocacy encourages people to appeal should they be denied Medicare coverage for skilled maintenance nursing or therapy because they are not improving.

For more information read, Judge Approves Settlement in Jimmo vs. Sebelius After Court Hearing

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January 31- Deadline for Submission of Structural Measure Data for Hospice

Reminder:   The deadline for attestation and submission of structural measure data for the Hospice Quality Reporting Program (HQRP) is Thursday, January 31, 2013.

Hospice providers that have not already created a user account and begun structural measure data entry should do so immediately. The link to the data entry site is available on the Data Submission portion of the HQRP website at the bottom of the webpage under “Related Links.” For step-by-step guidance on account creation, account activation, data entry and data submission, refer to the Technical User’s Guide for Hospice Quality Reporting Data Entry and Submission

For any questions about using the Hospice Quality Reporting Data Entry and Submission Site  contact the QIES Technical Support Office Help-desk by phone at 1-877-201-4721 or email at help@qtso.com

Technical Help-Desk hours are 8:00 a.m. through 8:00 p.m. ET.

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HIPAA Final Rule Brings Changes to Health Care Industry

On January 17, 2013 the U.S. Department of Health and Human Services (HHS) announced the release of the HIPAA final omnibus rule, which was years in the making. It modifies the HIPAA privacy, security and enforcement rules and breach notification. The regulation is effective March 26, 2013 with a compliance date of September 23, 2013, for both covered entities and business associates.

Features of the regulation:

  • Expands an individual’s right to receive electronic copies of his or her PHI
  • Restricts disclosures to a health plan concerning treatment for which the individual has paid out of pocket in full.
  • Requires covered entities to modify certain elements of their notice of privacy practices and redistribute those revised forms.
  • Holds business associates liable for certain HIPAA requirements.
  • Clarifies requirements for when a breach must be reported to authorities.
  • Adopts increased and tiered civil monetary penalties of up to $1.5 million per violation
  • Strengthens the limitations on the use and disclosure of protected health information for marketing and fundraising purposes
  • Prohibits the sale of protected health information without individual authorization.
  • Prohibits most health plans from using or disclosing genetic information for underwriting purposes, as required by the Genetic Information Nondiscrimination Act.

Stay tuned-the HCA is working on an educational program for our members on these HIPAA changes.

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