Author: James Fuccione

OIG Examines Hospice Services for Nursing Facility Residents

A new report from the Office of Inspector General has found that Medicare spending on hospice care for nursing facility residents has grown nearly 70 percent since 2005.  Many hospices had a high percentage of their beneficiaries residing in nursing facilities, and most of these hospices were for-profit. Compared to hospices nationwide, these high-percentage hospices:

  • received more Medicare payments
  • had a longer average length of stay
  • served Medic are patients whose diagnoses required less complex care
  • served more patients who already lived in nursing facilities before they elected hospice care.

A previous OIG study published in September, 2009, concluded that Eighty-two percent of hospice claims for beneficiaries residing in nursing facilities did not meet Medicare coverage requirements.

The OIG report notes that Medicare currently pays hospices the same rate for care provided in nursing facilities as it does for care provided in the home, but nursing facilities are staffed with professional caregivers and are often paid by third party payers, such as Medicaid. These facilities are required to provide personal care services, which are similar to hospice aide services that are paid for under the hospice benefit.

The OIG concluded that some hospices may be seeking beneficiaries with particular characteristics, including those with conditions associated with longer but less complex care. Such beneficiaries are often found in nursing facilities. By serving these beneficiaries for longer periods, the hospices receive more Medicare payments, which can contribute to larger profits.

The OIG report recommends that CMS (1) monitor hospices that depend heavily on nursing facility residents and (2) modify the payment system for hospice care in nursing facilities. CMS concurred with both of our recommendations. It also agreed that the current payment structure may provide incentives for hospices to seek out beneficiaries in nursing facilities, who often receive longer but less complex care

The OIG website has a special page devoted to Medicare hospice issues.  The page includes links to the new report, a podcast interview with Jodi Nudelman, the Region II Inspector General for Evaluation and Inspections, and several other OIG studies of hospice issues.  This is the first in a series of three studies by the OIG of hospice services to nursing facility residents.  Additional studies will examine the marketing practices of hospices that focus on nursing home residents and the business relationships of such hospices with nursing facilities.

Return to www.thinkhomecare.org.

CMS Community-Based Care Transitions Program Update

The Centers for Medicare and Medicaid Services (CMS) has provided new guidance and updates on their Community-Based Care Transitions Program.https://i0.wp.com/www.gmcf.org/transitions/images/transitions_image.jpg

New panel review dates for submitting applications beyond August 18th have been posted and are as follows:

  • October 6 & 7, 2011 – Applications must be received by September 6th to be considered for this review.
  • November 15 & 16, 2011 – Applications must be received by October 14th to be considered for this review.
  • November 30 & December 1, 2011 – Applications must be received by October 28th to be considered for this review.

Secondly, more than a full page of new guidance has been added to the program’s Question & Answer section. Below are a few examples:

  • Q: How shall we anticipate to cover up front costs? I heard that CBOs would be paid a per eligible discharge rate that is determined by target population, interventions proposed, anticipated volume and expected reduction in readmissions (cost savings) Can you give a concrete example of how this payment methodology would work?

A: Because this program seeks to build off of earlier care transitions initiatives and requires applicants to have a track record in the delivery of care transition services we are not paying “start up” costs. CBOs will be paid on a monthly basis for services delivered in the previous month. This payment will be whatever the agreed upon per eligible discharge rate is multiplied by the number of eligible beneficiaries served in the previous month. Please refer to the budget worksheet available on our program webpage for additional guidance on developing the per eligible discharge rate.

A: These are the patient experience measures that CBOs will be required to collect and report during the program. We will provide the instruments to awardees at the time of award.

The Home Care Alliance has also made a webinar available on the experiences from a previous CMS care transitions demonstration program that worked through 14 QIO’s across the US. The webinar focuses on, among other things, drawing from the Home Health Quality Improvement campaign’s Best Practices Intervention Package.

More info from this newsfeed on care transitions is available here.

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Gov. Patrick Signs FY12 State Budget

Governor Deval Patrick signed the state’s fiscal year 2012 budget amounting to $30.6 billion with a victory for home health.

Language that would move MassHealth one step closer to reimbursing home health agencies for telehealth services was included in the “MassHealth Managed Care” line item:

…for purposes of long-term health care cost savings and enhanced patient care, the commonwealth may recognize telehealth remote patient monitoring provided by home health agencies as a service to clients otherwise reimbursable through Medicaid

The key word in this language is “may.” MassHealth is not directly instructed in the budget to reimburse for telehealth (as if the word “shall” was used), but it presents the state with the option to do so, which means that continued advocacy will be required to push the state towards that end. This is a solid victory for the Alliance’s budget advocacy thanks to the hundreds of emails that were sent from the HCA website’s Legislative Action Center and to the office of Senator Richard Moore.

Another item of interest is in regards to Adult Day Health where the Governor approved a budget that makes “no changes prior to December 31, 2011 in the clinical eligibility or level of reimbursement paid to providers of adult day health services for basic and complex levels of care.”  The budget also imposes a temporary moratorium on enrollment of new Adult Day Health providers until such time that a study is completed by the Executive Office of Health and Human Services. The study, due to the Legislature by December 31, 2011, will provide a basis for new licensure and rate structure and also will provide a needs assessment of ADH services going forward.

For more information, the full budget is available on Mass.gov.

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Advocacy Alert: Oppose Co-Pays for Home Health

The debt ceiling negotiations are accelerating in Washington and a deficit reduction deal could be imminent.  Clearly, from news reports, we know that  Medicare cuts are under serious consideration, including the imposition of a home health co-payment.

The Medicare Payment Advisory Commission (MedPAC), the National Commission on Fiscal Responsibility and Reform, and the Congressional Budget Office have all supported a copayment as a deficit reduction measures.   Also on the table, as reported in today’s Boston Globe, a substantial cut to medical education funding for Massachusetts teaching hospitals.   Given the clear evidence that imposing copayments can lead to delaying accesses to needed services (adding costs longer term), home health must send a message to their Senators and Representative urging them to oppose a home health co-pays in deficit reduction negotiations.

Given that these decisions may be made as early as next week, we are asking that you contact our federal officials, especially Senators Kerry and Brown today.

You may send a message using the NAHC Legislative Action Network (NAHC LAN). To oppose home health co-pays and payment cuts, click here. The sample messages found on the NAHC LAN should be personalized to provide members of Congress with your background and the potential impact payment cuts and co-pays would have on senior and disabled Medicare beneficiaries and their families in your state and district.

We suggest also weighing in by phone.  When calling, ask to speak to the staffer who handles Medicare issues.  You may obtain contact information for your Senators and Representative here:  Contact Your Elected Officials.  For a sample phone message, click here.

Return to www.thinkhomecare.org.

 

CMS Proposes Medicare Home Health Payment Changes for 2012

The Centers for Medicare and Medicaid Services (CMS) have issued a proposed rule regarding payment changes as well as revisions to the physician face-to-face and therapy assessment rules.

Below is a summary of the most noteworthy aspects of the proposed rule provided by the National Association for Home Care & Hospice (NAHC):

1.       Proposed 2012 payment base episode rates are reduced to $2112.37 from the current $2192.07. This is a reduction of approximately 3.56%.

2.       The rate changes are due to a proposed 2.5% market basket index inflation update, a 1 point reduction in the MBI under the health care reform law, and a 5.06% case mix creep adjustment.

3.       The increase in the case mix creep adjustment is due to the evaluation of 2009 coding weight changes. CMS found that ¾ of the coding increases was a result of increases in therapy visits above the 14 and 20 visit thresholds.

4.       The 3.56% rate reduction will impact individual providers unevenly. CMS proposes to make significant changes in coding weights by eliminating hypertension as a factor in the calculation, reducing the weights on therapy episodes, and increasing weights on non-therapy episodes. Providers with high volumes of therapy cases could see greater net rate reductions. A provider-specific analysis using the provider’s particular case mix is the only reliable way to assess impact.

5.       CMS proposes to change the face-to-face rule and allow one physician to do the encounter and report the information to another physician who completes the certification and plan of treatment documentation. This should help in circumstances where a patient is under the care of a hospitalist who transfers the patient to a community physician.

6.       CMS proposes to clarify the therapy assessment standard where more than one discipline is involved.

The proposed rule on rates is in line with what had been expected. Nevertheless, that does not turn a lemon into lemonade. The change on the face-to-face rule is appreciated, but will only make a slight improvement as the documentation requirements remain a problem.

CMS also posted the proposed rule on the Medicaid face-to-face encounter requirements. The proposal aligns the Medicaid time frames with the Medicare time frames while providing some flexibility to states to determine other aspects such as the content and form of documentation. The proposal also reaffirms CMS’s position that a homebound requirement in Medicaid home health is not permitted and that services can be provided outside the home. Finally, the proposal offers clarifications on the coverage of medical supplies and equipment.

Another summary is available in a press release issued by CMS with a few more specifics on payment. The Home Care Alliance is working on a specific analysis regarding the payment changes based on the northeast’s wage index and will have that available soon.

See links to the specific proposed rules in the Federal Register below:

 

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Health Care Cost Trends Hearings and Panels This Week

The state’s Division of Health Care Finance & Policy (DHCFP) is holding a series of presentations, speeches and panel discussions this week in regards to health care cost trends reports and cost containment efforts currently underway.

The full agenda for the week features a range of health care experts and stakeholders, including government officials, and there will also be limited room for public comment. This is another opportunity for those interested to hear the state’s work in highlighting cost disparities as well as an attempted move for the state towards global payments and health care cost control.

The hearings are being held from Monday, June 27, 2011 through Thursday, June 30, 2011 at Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129.

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Monday, June 27, 2011 through Thursday, June 30, 2011

Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129

MA Congressional Delegation Weighs in on Physician Face-to-Face Requirement

The Massachusetts Congressional Delegation has stepped up again, this time sending a letter to CMS Administrator Dr. Donald Berwick with concern over the physician face-to-face requirement.

Every member of the delegation – Senators Kerry and Brown, as well as US Reps Markey, Frank, Neal, Olver, McGovern, Tierney, Capuano, Lynch,  Tsongas and Keating – signed onto the letter noting that the Massachusetts health care community has made considerable efforts to comply with the rule, but the paperwork burden and duplicative nature of the requirement are proving problematic and that CMS should consider changes.

The letter itself is available here and the Home Care Alliance greatly appreciates the work and support from the Congressional Delegation.

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State Seeks Comments on Accountable Care Organizations Through New RFI

The state’s Executive Office of Health and Human Services has released a Request for Information regarding the formation of Accountable Care Organizations (ACO’s) and are seeking comments from “all interested partComm-PASS logoies.”

The RFI includes an introductory letter from Health and Human Services Secretary Dr. JudyAnn Bigby and a thorough explanation of the state’s intentions for the transition to a new payment system. A response template is included in “Attachment A” of the document and comments should be submitted electronically through the Commonwealth Procurement Access and Solicitation System (Comm-PASS). Instructions are available in the RFI and the Home Care Alliance encourages home care agencies to submit comments as they see fit.

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Panel Review Dates Announced for Care Transitions Program

The Centers for Medicare and Medicaid Services announced panel review deadlines for applications to be submitted for the Affordable Care Act’s Section 3026 Community-Based Care Transitions Program.

  • July 19, 2011 – Applications must be received no later than June 20, 2011 to be considered for this review.
  • August 24, 2011 – Applications must be received no later than July 15, 2011 to be considered for this review.
  • September 19, 2011 – Applications must be received no later than August 18, 2011 to be considered for this review.

The Home Care Alliance has received questions regarding the assembly of a budget for the application and a helpful guide  is available upon request for those interested.

Guidance is also still available on the Q&A section of the CMS Care Transition Program’s web page.

Return to www.thinkhomecare.org.

 

CMS Home Health Quality Campaign will Continue, NAHC Announces

The National Association for Home Care & Hospice (NAHC) has announced that the CMS Home Health Quality Improvement Campaign (HHQI) will continue after July 31, 2011.

The goal of the HHQI Campaign is to improve the quality of care home health patients receive as measured by a reduction of avoidable hospitalizations and improvement in the management of oral medications. Throughout the campaign, a variety of materials as well as online communication and sharing tools have been and will continue to be available to Campaign participants. These include Best Practice Intervention Packages (BPIPs), which will be released quarterly to share effective strategies with home health care providers.

Campaign participants will also be able to set improvement targets and view rates related to the publicly reported acute care hospitalization and oral medication measures through a free target-setting tool at the Home Health STAR (Setting Targets Achieving Results) Web site.

According to NAHC, the  second phase of the campaign was set to conclude at the end of July, but CMS has indicated that the HHQI movement will proceed into a third phase. As a result home health agencies will be able to continue to access free quality improvement resources at www.homehealthquality.org.

Before the next phase starts later this year (the details on what the third phase will entail has yet to be announced) home care agencies are asked to fill out a simple form and share input on how the campaign can improve. The HHQI National Campaign has created a brief three-question assessment that asks for insights, along with name, e-mail address and phone number. It can be filled out at: http://www.homehealthquality.org/hh/about/feedback/default.aspx.

The Home Care Alliance is a Local Area Network of Excellence (LANE), which means that the association is responsible for agency recruitment in Massachusetts and the dissemination of information and materials from the national campaign. For more information on the campaign, please visit www.homehealthquality.org/.

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