Author: Colleen Pierro

NHIC Ask the Contractor Nov. 15

NHIC Corp., the regional Medicare Administrative Contractor, will host a Hospice & Home Health Ask the Contractor Teleconference (ACT) on November 15, 2012, at 10:00 a.m.  This 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 Education Programs webpage

Return to www.thinkhomecare.org.

New OASIS Guidance from CMS

CMS has just released the latest guidance for OASIS, October 2012 Quarterly Q&As.  This quarterly update contains 11 new Q&As including the latest CMS OASIS-C guidance with a special item about selecting fall risk assessment tools based on standardization, validation and multi-factor requirements.Other highlighted items:

  • situations where the physician-ordered ROC date is outside the assessment time frame
  • selecting a response for patient confusion when confusion level varies
  • how/when bipolar disease and other psychiatric diagnoses might impact the depression process measure.

ODF-Medical Review of Therapy Claims

The Centers for Medicare & Medicaid Services (CMS) will hold a Special Open Door Forum on the Manual Medical Review of Therapy Claims on October 22, 2012 from 2:00pm-3:30 pm.

The review of therapy claims applies to all Part B outpatient therapy settings and providers including home health agencies that bill Part-B outpatient (TOB 34X). The purpose of this Special Open Door Forum (ODF) is to provide an opportunity for providers to ask questions about the mandated manual medical review of therapy services from October 1-December 31, 2012 that was enacted by the Middle Class Tax Relief and Job Creation Act of 2012.

During this Special Open Door Forum, CMS will discuss therapy documentation requirements and answer any questions providers may have. Participants may submit questions prior to the Special ODF.

To participate in the call, dial: 1-866-501-5502; Conference ID: 44803009.

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OIG Releases 2013 Work Plan for Home Health

The HHS Office of Inspector General (OIG) Work Plan for Fiscal Year 2013 was recently release and provides brief descriptions of activities that OIG plans to initiate or continue in fiscal year 2013.

The Work Plan describes the primary objectives and provides for each review its internal identification code, the year in which we expect one or more reports to be issued as a result of the review, and indicates whether the work was in progress at the start of the fiscal year or will be a new start during the year.

The OIG’s Work Plan for home health addresses seven areas for review:

  • Home Health Face-to-Face Requirement (New)
  • Employment of Home Health Aides With Criminal Convictions (New)
  • States’ Survey and Certification: Timeliness, Outcomes, Follow-up, and Medicare Oversight
  • Missing or Incorrect Patient Outcome and Assessment Data
  • Medicare Administrative Contractors’ Oversight of Claims
  • Home Health Prospective Payment System Requirements
  • Trends in Revenues and Expenses

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NHIC’s Review of Home Health Claims with 5-7 Visits

The NHIC, Corp. Medical Review Department has recently completed a review of home health claims with five-seven visits billed. Of the 80 claims review, 28 were paid as billed. The remaining 52 claims had some denials resulting in a claim denial rate of 65%. The total charges reviewed included $72,694.98 of which $32,749.95 was denied. This resulted in a charge error rate of 45%.

The majority of the claims were denied because the skilled nursing services were not supported as being medically necessary in the medical records. Read more in the educational article Review of Home Health Claims with 5-7 Visits

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Skin and Wound Handoff Tool – for All Providers

The Massachusetts Pressure Ulcer Collaborative (PUC) recently developed a Skin and Wound Handoff Tool that can be used across the continuum of care.  The PUC was formed in 2010 by the Massachusetts Hospital Association (MHA), Massachusetts Senior Care Association, and the Home Care Alliance of Massachusetts to implement a statewide quality initiative to prevent pressure ulcers across the continuum of care through the promotion of best practice, education and improved communication.

The committee encourages all health care providers to pilot the form and to provide feedback to the committee. If you have any questions or comments please email Colleen Bayard.

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Home Health and Hospice ODF

This month’s CMS Home Health, Hospice & DME Open Door Forum  is scheduled for Wednesday, October 3, 2012 at 2:00 p.m.

To participate by phone:   Dial: 1-800-837-1935 & Reference Conference ID: 76245818.

The agenda includes:

1. Open Enrollment Announcement

2. Home Health & Hospice Quality Update

3. Home Health Care CAHPS Update

4. OASIS Training Update; OASIS-C Online Training: Integumentary Status Domain Pressure Ulcers

Open Q&A

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Compliance Date for ICD-10 Announced

The deadline for the transition to ICD-10 is October 1, 2014.

Health and Human Services Secretary Kathleen Sebelius announced the release of the rule that makes final a one-year proposed delay—from October 1, 2013, to October 1, 2014—in the compliance date for the industry’s transition to ICD-10 codes. Secretary Sebelius first announced the proposed delay in April, as part of President Obama’s commitment to reducing regulatory burden.

Keep Up to Date on ICD-10,visit the ICD-10 website for the latest news and resources to help you prepare.

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Medicare Home Health Proposed Rule Issued: Clarifications and Improvements on Therapy Assessment Rules

The  Medicare Home Health Proposed Rule was release last week. Among proposed payment changes, Face to Face clarifications, and new sanctions for non-compliance with federal requirements, the Therapy Assessment Rule is also slated for changes and improvements. But are all of these proposed changes really improvements to this Therapy Rule?

Clearly an improvement to the rule—CMS proposes to revise the regulations to state that if a qualified therapist missed a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, not the visit after the therapist completed late reassessment.— Currently, when a qualified therapist misses one of the required reassessment visits, once the therapist has completed the required reassessment, coverage resumes after this reassessment visit.

In addition, CMS proposes to revise the regulations to state that” in cases where multiple therapy disciplines are involved, if the required reassessment visit was missed for any one of the therapy disciplines for which therapy services were being provided, therapy coverage would cease only for that particular therapy discipline”. Therefore, as long as the required therapy reassessments were completed timely for the remaining therapy disciplines, therapy services would continue to be covered for those therapy disciplines. Again this change appears to work in favor of the provider. — Currently the regulation states,  even if qualified therapists from the other therapy disciplines have completed all their required reassessment visits, therapy visits for these disciplines would not be covered until the qualified therapist who missed the reassessment visit has completed the previously missed reassessment visit.

This last change has potential to cause headaches for scheduling the multi-therapy visits. —CMS is proposing a change to allow “flexibility” and guidance to the provider.  This change would be applicable in cases where beneficiaries are receiving more than one type of therapy; the qualified therapists could complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th visit for the required 19th visit reassessment. — Currently the regulation states that therapist’s visit need only be “close to” the 13th and 19th visits. This proposed revision does not appear flexible but rather has great potential for scheduling patients’ visits for three disciplines to be extremely inflexible. Hopefully stakeholders will comment on this proposed change.

www.thinkhomecare.org.

Skilled Teaching for Dementia Patients

NHIC, Corp. has just released a medical policy article that addresses a specific category of skilled nursing care currently available to Medicare home health beneficiaries who have dementia with behavioral disturbances; A51856 Home Health Skilled Nursing Care: Teaching and Training for Dementia Patients with Behavioral Disturbances.  The category of skilled nursing is called “teaching and training activities”, defined in the CMS Manual System. The Medicare beneficiaries with dementia and behavioral disturbances could receive a patient-centered care plan directed at teaching the family or caregiver how to manage the behavioral disturbances.

Refer to Article A51856 for sample case scenarios and details on documentation, coding guidelines, and potential interventions

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