OASIS-D1 Guidance from Qualidigm

Changes to the OASIS data set will be incorporated into OASIS-D1 effective January 1, 2020. To help home health agencies understand these changes, Qualidigm has itemized the list of data set changes in a one-page document and four 90-second videos.

A number of changes to the OASIS data set have been made and will be incorporated into OASIS-D1 effective January 1, 2020 (click here for data submission specifications). These changes align with the new Patient-Driven Groupings Model (PDGM). Under this new model, OASIS accuracy will continue to be important with Functional Impairment Level derived directly from OASIS items.

To help home health agencies understand these changes, Qualidigm has itemized the list of data set changes outlined in this one-page document.  Additionally, Qualidigm recently released its Quality Quick Minute video series focused on the OASIS-D1 changes. The videos series is comprised of four brief, 90-second information videos outlining these changes to assist with preparation in anticipation of the January 1 effective date.

The OASIS-D1 Quality Quick Minute video series includes the following:

  1. OASIS-D1 Changes Overview
  2. Optional Items
  3. Follow-Up Timepoint Items
  4. M0090 Date Assessment Completed

All four videos can also be accessed from the home health section of the Qualidigm website at www.qualidigm.org/our-services/home-healthcare-consulting/.

Marissa Moncata
Senior Business Analyst, Consulting Services
Qualidigm
MMoncata@qualidigm.org

2019 Financial Management Conference Announced!

Join us on Tuesday, December 10th at the Beechwood Hotel in Worcester, MA for our Annual Financial Management Conference. Take a deep dive into the current trends and issues happening in the Home Health industry as you prepare for 2020.

Join us on Tuesday, December 10th at the Beechwood Hotel in Worcester, MA for our Annual Financial Management Conference. Take a deep dive into the current trends and issues happening in the Home Health industry as you prepare for 2020. This is the perfect conference for CFOs, CEOs, and Clinical Directors!
 
The 2019 Agenda Includes:
Hindsight is 2020: Hone into Home Health & Hospice Payment Compliance in the New Decade, Kathleen Hessler, Simione Healthcare Consultants
The HHS Office of Inspector General (OIG) continues its intense oversight and scrutiny of the Medicare home health and hospice programs by analyzing the rich sources of data available to them. With increase in survey and audit activity —including Targeted Probe and Educate (TPE), UPIC and SMRC audits, learn what your agencies need to do to ensure payment compliance in the new decade. The session will cover types of government audits, recommendations for internal-self monitoring, as well as what to do if your agency identifies an overpayment.

HHVBP Trends & Data, Chris Attaya, SHP Data
As we close out year 2 of the Home Health Value-Based Purchasing
Demonstration, Chris Attaya will take a deep dive and identify the latest updates and trends in HHVBP and Star Rating measure scores. Attaya will also discuss data points specific for Massachusetts state agencies.

PDGM Check Point, Mike Carr, Axxess
PDGM is almost here, now is the time to ensure you are ready for the changes. This session will review where you should be, and how to get there if you’re not. Carr will provide a high level overview of PDGM as well as understanding how past performance will be impacted by PDGM. Other elements to be discussed include technology challenges, therapy impact, and measures for survival.

Making Home the Center of Care: Opportunities & Challenges of Public Priorities, Mike Canter, Carecentrix & Reactor Panel
Recent public policy trends focus on cost containment, integrated care, and quality outcomes. Home care is in a unique position to thrive in this emerging environment. Is your agency poised to seize the opportunity?

Register Here

Haunted by TPE? Don’t Let It Frighten You!

Many home health care agencies have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE). Here are answers to many common questions.

Many home health care agencies (HHAs) have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE), so I thought I would review the rules because I am sure others have the same questions. NGS has contacted HCA to let us know that there are new TPE audits in Massachusetts: high therapy utilization, long lengths of stay, documentation supporting homebound for Heart Failure, COPD, Diabetes and Dementia, and medical necessity.

How Will the HHA Be Notified:  Agencies will receive a letter from NGS stating the focus of the targeted probe. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records. If you are currently in a TPE audit you will not be chosen for another. If for some reason you receive another TPE please contact Colleen Bayard because agencies should only be under one targeted probe and educate for home health at a time.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: Agencies will be notified of one-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

HHAs are Experiencing New Round of Targeted Probe and Educate

National Government Service (NGS) announces two new rounds of Targeted Probe and Educate (TPE) for home health agencies

Last month, the National Government Service (NGS) notified the Home Care Alliance of Massachusetts about two new rounds of Targeted Probe and Educate (TPE):

High therapy utilization. NGS will be reviewing documentation to ensure all CMS requirements have been met on therapy assessments and 30-day reassessments, as well as, medical necessity.

Documentation supporting homebound criteria. The second edit is specific to four diagnoses: Heart Failure, COPD, Dementia, and Diabetes and if the documentation confirms homebound status.

Many HHAs have contacted me over the past few weeks with questions about the TPE, so I thought I would review the rules because I am sure others have the same questions.

How Will the HHA be Notified: You will receive a letter from NGS stating the focus of the targeted probe: high therapy or homebound for one of the four diagnoses listed above. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: One-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

If you have any questions or concerns about TPE, it would be great to hear from you. Good Luck!

Advocate and Engage on PDGM

There are many ways that home health agencies will need to prepare their agencies for the radical changes coming from PDGM in January 2020. The Alliance is here to help.

Last month, the Centers for Medicare & Medicaid Services (CMS) issued its proposed rule for 2019 home health payment rates and policy changes, which includes significant provisions that will impact your organization, staff, and the patients you serve.

Between now and when the Patient Driven Grouping Model (PDGM) goes into effect on January 1, 2020, there are multiple ways that home health agencies will need to prepare their agencies for the radical change. (See Coding and Billing webinars coming in September, at the bottom of this page) At the same time, home care must take action to mitigate the impact of what PDGM will look like and how it will impact organizational viability.

Home care’s collective advocacy efforts have undeniably made a difference in the past, including putting a stop (at least in Massachusetts) to the Pre-Claim Review Demonstration and scrapping the Home Health Groupings Model thanks to more than 1,200 comments submitted to CMS last year. The more that CMS and lawmakers hear from home health professionals, the better our chances are at reducing the severe cuts that accompany PDGM in its proposed form.

As currently proposed, the 2020 rule will:

  • Reduce the Medicare base rate by 8.01% next year, which amounts to a $1.298 billion reduction in home health payments in 2020 alone. CMS proposes the reduction to account for anticipated changes in provider behavior that are unrelated to changes in patients served or services delivered that increase payments. This newly proposed “behavioral adjustment” reduction is up from the 6.42% reduction that CMS initially proposed, and the reduction would start before any actual behavioral changes occur.
  • Phasing out RAPS over 2020 with total elimination of RAPs in 2021. Next year, CMS proposed reducing RAPs from 60/50% to 20% for existing home health agencies (HHAs), while new agencies would get no RAP. CMS claims that RAPs create fraud risks.
  • Starting in 2021, a Notice of Admission (NOA) must be submitted Notice of Admission must be submitted within five days of the start of care. For every day late, CMS plans to reduce base-rate reimbursements for the unit of care.

The Solution: Pass S.433/H.R.2573

This month, Congress is in recess and back in the states, which presents a pivotal opportunity for home health industry professionals to engage with lawmakers about a key legislative priority – the Home Health Payment Innovation Act (S.433/H.R.2573).

This legislation prohibits CMS’s ability to adjust payment based on “behavioral assumptions” as opposed to observed evidence of behavioral changes, thus rescinding the proposed 8.01% adjustment.
Additionally, this important legislation would:

  1. Achieve full budget neutrality over the period of 2020-2029.
  2. Require behavioral adjustments based on real, actual changes in provider behavior in response to the new payment model.
  3. Permit a phase-in of rate adjustments (up or down) when an annual adjustment would be greater than 2 percent. However, the phase-in would operate to ensure full budget neutrality by 2029.

Email your Members of Congress

It’s not too late to get members of Congress informed and engaged on this important legislation. You can send an email directly from HCA’s member advocacy center.

At this point, Congressman Jim McGovern is the only member of the MA delegation signed on as a cosponsor. We must do better.

Fact Sheet: Senate 433 & HR 2573

Advocate in Person

Join home health industry advocates next month in Washington, D.C. for The Council of State Home Care Associations’ Third Annual Public Policy Summit and Advocacy Day!  On September 9, participate in a full-day summit featuring speakers including Hillary Loeffler, Director of the CMS’ Division of Home Health & Hospice.  On September 10, we be on Capitol Hill meeting with members of Congress to convey the critical need to pass S.433/H.R.2357.

Program details can be found here and registration information can be found at The Council’s website.

Submit Comments to CMS by September 9

Click here to submit comments to CMS in response to the 2020 proposed rule by 5:00 PM ET on Monday, September 9, 2019.

HCA and other industry organizations will provide more thorough comments on other problematic areas of the proposed rule. As previously stated, there is strength in numbers, so the more business-focused comments from providers – both large and small – are critical to giving CMS a full and clear picture of how devastating PDGM will be should it be implemented as proposed. Watch Update for draft comments.

Return to www.thinkhomecare.org.

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.

Return to www.thinkhomecare.org.

Members Flock to HCA’s Quality Improvement Meeting

Lots of member interest in HCA’s July QI meeting to discuss medical record audits and upcoming proposed rule changes.

With the sundry of regulation changes in the home health industry over the past few months, the July 24th Quality Improvement (QI) meeting had over 45 members participating in-person and by phone. The numerous medical record audits plaguing the industry dominated the meeting’s discussion.

Multiple agencies have received letters from C2C Innovation Solutions informing them that some claims under appeal have been selected for potential reopening as part of the Medicare Appeals Demonstration. The C2C auditors are conducting the analysis of claims previously adjudicated unfavorably by the Qualified Independent Contractor (QIC), that are currently pending at the Office of Medicare Hearings and Appeals (OMHA) and may be resolved favorably by the QIC.

Other audits that agencies are experiencing are new Targeted Probe and Educate (TPE) audits. These medical record requests are for 5-7 visits and lengths of stay greater than 90 days. No agency is in the third round of the Face-to Face TPE.

One agency reported at the meeting that they are facing three audits simultaneously; a hospice General Inpatient care (GIP) Targeted Probe from NGS, a home health PERM request for Face-to-Face (awaiting ALJ) and eight GIP Post Payment Review by Noridian.

During the meeting there was a lot of member engagement related the 2020 Proposed Rule; the proposal to require OASIS for all payors and the 8% behavioral adjustment. Agencies also discussed strategies for management with PDGM and the process for completing OASIS B-1 for January 1st episodes. PDGM will be a standing QI agenda item.

The HCA is planning to host a PDGM Networking Meeting to help our members with the transition to this new payment model. We are hoping to begin the meetings in September and have a guest speakers and consultants to assist with planning for this historic payment change. Stay tune for further details.

Don’t forget to check out our PDGM Bootcamp on September 24th!