Author: Colleen Pierro

New Claims-based Measures for Hospitalization and ED Use

As reported in the Final Rule for CY 2013, there are significant changes in how the home health hospitalization rates are calculated. On January 17, 2013, the hospitalization measures based on these new calculations were posted on Home Health Compare.  Specifically, the Acute Care Hospitalization (ACH) and Emergency Department (ED) Use Without Hospitalization are now based on Medicare claims-based data rather than on OASIS-based data.

Key points to note:

  • Claims-based measure is based on the Start of Care (SOC) date instead of the transfer/discharge date.
  • Numerator:  the number of home health stays for patients who have a Medicare claim for an admission to an acute care hospital or for an emergency department visit in the 60 days following the start of the home health stay.
  • Exclusions from the Measure Numerator
    • Planned hospitalizations are excluded from the acute care hospitalization claims-based measure numerator.
  • Observation stays that begin in a hospital emergency department but do not result in an inpatient stay within the 60 days after the start of home health care are counted in the ED Use without Hospitalization measure.
  • Observation stays that result in an inpatient stay within the 60 days after the start of home health care are counted in the Acute Care Hospitalization measure even if the patient is discharged from the home health agency.
  • Denominator:  the number of home health stays that began during the reporting period.
  • Exclusions from the Measure Denominator
    •  Home health stays for patients who are not continuously enrolled in fee-for-service Medicare during the 60 days following the start of home health stay. (Medicare lacks full information about the patients utilization of health care services and cannot determine if care was sought in an ED during the numerator window,  60 days time period)
    • LUPAs are excluded from claims-based measure
    • Home health stays in which the patient receives service from multiple agencies during the first 60 days are excluded from the denominator.
    • Home health stays for patients who are not continuously enrolled in fee-for-service Medicare for six months prior to the start of the home health stay. (This is excluded because Medicare lacks information about the patient’s health status that is needed for risk adjustment)
  • There is significant difference in the claims-data and the OASIS-data for the ACH measures so they are not comparable. To continue to track your ACH rate by OASIS-based data, this data will continue to be reported on the CASPER Reporting System.

For Specifications for Home Health Claims-Based Utilization Measures, Click Here

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REMINDERS RE ACCOUNT ACTIVATION AND DATA SUBMISSION

Hospice Information from CMS ––

CMS requested that providers are reminded about registering for accounts for the Hospice Quality Reporting Program – the text follows.

Hospice Quality Reporting Program Data Entry/Submission Website now Available

Structural Measure Data Submission Deadline 1/31/13

 The data entry site for Hospice Quality Reporting Program (HQRP) data submission is live and active for provider use. The link to the data entry site is available on the Data Submission portion of the CMS HQRP website under “Related Links.” As providers may experience unexpected technical issues when registering for/activating their account, providers should not wait until all of their data is compiled to register for and activate their account. Early account creation and activation will help ensure that providers do not miss the 1/31/13 deadline for the structural measure. In order to meet the 1/31/13 structural measure deadline, providers should:

  1. Review the Technical User Guide for Hospice Quality Reporting Data Entry and Submission located on the CMS Hospice Quality Reporting Data Submission web page. It is imperative that providers review the Guide prior to registering for a user account. The Guide provides step-by-step instruction on registration, data entry, and submission of hospice quality reporting data. Also available is the Hospice Quality Reporting Program Data Entry and Submission WebEx recording. The recording is available on the Hospice Training page of the QTSO website.
  2. Register for a User Account. Visit the data entry website and create an account. Please note, hospice organizations will only be allowed one user account per CMS Certification Number (CCN). Hospices should carefully select the ONE individual that will enter required quality data for both measures. Thus, if you do not intend to complete the tasks of registration, data entry, attestation and submission for a specific hospice provider, please do not register for an account.
    Providers should register for an account now, even if they are not ready to submit their data immediately.
  1. Activate the User Account. After registering for an account, providers will receive a registration activation email from hospice.quality.report@GDIT.com to activate their account. To activate your account you must click on the link in the body of the email. If the Hospice Registration Activation E-mail is not received, please take the following steps:
    1. If you have more than one e-mail address, check all your email accounts in case you registered with a different account.
    2. If the activation email has not been received at any of your email accounts, take the following steps for each account:
      1. Check all your Mail folders, not just your inbox.
      2.  Look in any folders marked Junk or Spam for an e-mail from hospice.quality.report@GDIT.com.
      3. If you do not have access to a Junk or Spam folder, check with your e-mail technical support staff to see if your mail server may have trapped the e-mail.
      4. If you are unable to locate the e-mail, contact the QIES Help Desk at help@qtso.com for a Deactivation Form.
      5. Once you receive the Deactivation Form, fill it out completely and return it to the address on the form. Your registration attempt will be removed and you will be notified when you can register once again.  We strongly recommend you use a different e-mail address for the new registration.
  2. Once the account is activated, login and complete the Hospice Provider Information page on the data entry website.
  3. Enter your structural measure and NQF #0209 data. Providers do not have to enter all of their data in one sitting. Data for both measures can be saved on the data entry website and returned to at a later date.
  4. Attest to and submit data to CMS through the data entry website. Once your data entry for either measure is complete and accurate, submit and attest to the data for that measure.
    • Data for the structural measure must be attested to and submitted to CMS no later than January 31, 2013. Data for the NQF #0209 Pain Measure must be attested to and submitted to CMS no later than April 1, 2013.

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NHIC- Ask the Contractor January 17th

The Medicare Administrative Contractor, NHIC. Corp., will hold the Hospice & Home Health Ask the Contractor Teleconference (ACT) on January 17th at 10:00 a.m.

Ask-the-Contractor Teleconference is an opportunity to speak directly with the contractor. NHIC staff representing a variety of functions will be available to answer questions. NHIC usually will provide some updates to the home health and hospice community but the majority of this call is dedicated to providers as a question and answer open forum.

Registration is required on NHIC’s website- Education Programs.

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HIPAA Breaches Must be Reported to Secretary of HHS by March 1, 2013

Breaches involving less than 500 individuals

For breaches of unsecured protected health information involving less than 500 individuals, a home health agency must maintain a log or other documentation of these breaches. The agency must also provide notification of breaches to the Secretary of HHS by March 1, 2013. (no later than 60 days after the end of the calendar year)

This notice must be submitted electronically (Instructions for Submitting Notice)  and all information must be completed on the Breach Notification Form. A separate form must be completed for every breach that has occurred during the calendar year.

For specifics of the federal regulation see Notification in the Case of Breach of Unsecured Protected Health Information

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Home Health and Hospice Education Webinars for 1st Quarter 2013.

The Medicare Administrative Contractor for Massachusetts, NHIC, Corp. has posted upcoming Home Health and Hospice Education Webinars for January-March 2013.  Providers are encouraged to participate in these educational sessions.

More information on registration, materials, and training assessments are provided on the Education Programs Information section for NHIC website. Note: Registration is required for all programs.

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Reminder- “Home Health and Hospice ODF” – Wednesday, January 9th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, January 9, 2013 at 2:00 PM Eastern Time (ET).

Proposed Agenda

1. Proposal to discontinue the Home Health Advance Beneficiary Notice (HHABN), Form CMS-R-296, and replace the HHABN with a new Home Health Change of Care Notice (HHCCN), Form CMS-10280, and the existing Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131.

2. HHCAPS

3. Home Health Study regarding Access to Care

4. Home Health & Hospice Quality Reporting Update

5. Retroactive Grouper Change for Basel Cell, Squamous Cell, and Unspecified Malignant Cancers for Home Health Services Rendered October 1, 2011 through December 31, 2012

6. Update to OASIS Web-Based Training at: http://surveyortraining.cms.hhs.gov , Addition of Module, OASIS C Online Training: Patient Tracking Domain

7. Flu Vaccination Announcement

8.  Open Q&A

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Dial: 1-800-837-1935 & Reference Conference ID: 78868196.

The audio recording of this call that can be accessed by dialing 1-855-859-2056 and entering the Conference ID beginning 2 hours after the call has ended. The recording expires after 2 business days

Encore: 1-855-859-2056; Conference ID: 78868196

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Home Health, Hospice & Durable Medical Equipment Open Door Forum

Save the Date:

The Centers for Medicare & Medicaid Services (CMS) will hold the next Home Health, Hospice & Durable Medical Equipment (DME) Open Door Forum  on Wednesday, January 9, 2013, from 2:00pm – 3:00pm, ET.

To participate in the call, dial: 1-800-837-1935; Conference ID: 78868196

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Planned Revisions to Home Health Beneficiary Notice-Open for Public Comment

Presently home health agencies (HHAs) are required to use the Home Health Advance Beneficiary Notice (HHABN), CMS-R-296 to provide beneficiaries with change of care notification consistent with HHA Conditions of Participation (COPs) in addition to its liability notice function. Option Box 1 addresses liability, Option Box 2 addresses change of care for agency reasons, and Option Box 3 addresses change of care due to provider orders.

In CMS’ effort to “streamline, reduce, and simplify notices to Medicare beneficiaries,” HHABN Option Box 1, the liability notice portion, will be replaced by the existing Advanced Beneficiary Notice of Noncoverage (ABN) which is approved by Office of Management and Budget (OMB) for conveying information on beneficiary liability. CMS will introduce the “Home Health Change of Care Notice” (HHCCN) as a separate, distinct document to give change of care notice in compliance with HHA conditions of participation. The HHCCN will replace both Option Box 2 and Option Box 3 formats of the HHABN. The single page format of the HHCCN is designed to specify whether the change of care is due to agency reasons or provider orders. Form Number: CMS–10280 (OCN: 0938–New) To obtain copies of the supporting statement and any related forms for the proposed paperwork collections referenced above, go to CMS’ Web Site address at http://www.cms.hhs.gov/, or Email your request, including your address, phone number, OMB number, and CMS document identifier, to Paperwork@cms.hhs.gov, or call the Reports Clearance Office on (410) 786-1326.

The full notice and details for submitting public comments on the proposed changes can be accessed in the Federal Register.  Comments are due by February 11, 2013

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CMS Updates Policy Requirements for Medical Record Corrections

CMS released Transmittal 442, Change Request (CR) 8105 on December 7th. It provides instructions to Medicare contractors regarding amended, corrected, and delayed entries in medical records. This updates the CMS Medicare Program Integrity Manual, Section 3.3.2.5 effective January 8, 2013.

According to this Change Request, the MACs, CERT, Recovery Auditors, and ZPICs are instructed NOT to consider entries that don’t comply with recordkeeping principles, even if exclusion of an entry will result in a claim denial.

In the manual update, “providers are encouraged to enter all relevant documents and entries into the medical record at the time they are rendering the service.” However, the policy goes on to acknowledge that there may be occasions when documentation was not completed or completed properly and may need to be amended. Medicare contractors are told that they are to consider all submitted entries that comply with the widely accepted Recordkeeping Principles, but NOT consider any entries that do not comply with the principles.

Recordkeeping principles for record amendments apply to both paper and electronic medical records. These principles include:

  • Clearly and permanently identify any amendment, correction or delayed entry as such; 
  • Clearly indicate the date and author of any amendment, correction or delayed entry; 
  • Not delete but instead clearly identify all original content.

When correcting a paper medical record, the “principles are generally accomplished by using a single line strike through so that the original content is still readable. Further, the author of the alteration must sign and date the revision. Similarly, amendments or delayed entries to paper records must be clearly signed and dated upon entry into the record.”

CMS acknowledges that although “record keeping within an EHR deserves special considerations” the same principles apply. EHR corrections or delayed entries must:

  • Distinctly identify any amendment, correction or delayed entry, and;
  • Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.

The manual update also states “If the MACs, CERT or Recovery Auditors identify medical documentation with potentially fraudulent entries, the reviewers shall refer the cases to the ZPIC and may consider referring to the RO and State Agency”.

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Encore-Special ODF for Hospice Providers

Did you miss the December 19th Open Door Forum that presented information about the Hospice Quality Reporting Program?

CMS announced that this ODF will have an encore recording available until midnight December 22nd

Agenda Topics included:

  • Updates about the upcoming availability of the data submission website
  • Information about how to access the data submission website and create a user account
  • Details about the data submission process
  • Question and Answer session

ENCORE CALL IN:  1-855-859-2056

CONFERENCE CODE:  81540883

 

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