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!

New Emergency Prep 4-Part Webinar Series

Agencies continue to struggle with the development of a disaster preparedness plan that will not only be in compliance, but realistic in an event. Areas of weaknesses in the process have been identified by CMS and accrediting bodies. On top of that, there were changes made to regulations at the end of 2018 and appeared in the 2019 interpretive guidelines. This series of one-hour webinars will provide in-depth knowledge of the requirements that home health and hospice organizations are subject to, with specific focus on: an overview of the regulations, starting the agency-specific plan, building the plan, development of policies and procedures, communication, and testing and training.

Program Goals: Through attendance in this web series, participants will increase their understanding of the newly updated federal emergency preparedness requirements that are part of the home health and hospice
Conditions of Participation (CoPs) and become knowledgeable in how to apply the federal requirements for disaster preparedness in their own specific agencies. Enhance disaster plan development for all community based agencies.

Following is the planned content and schedule for the live webinar sessions; for those who are unable to attend the live sessions, recorded sessions will be available.
Please note there is limited seating in the live sessions so please register early.

Part 1: OVERVIEW OF THE REGULATIONS – June 4, 2019, 1:00-2:00 pm EDT
Including Lessons Learned, Home Health and Hospice’s Role in an Event, All-Hazards Approach, Regulatory changes since 2018 and survey findings from the first year under the disaster preparedness CoPs.
Part 2: STARTING AND BUILDING THE PLAN, – June 11, 2019, 1:00-2:00pm EDT
Including Four Phases of Emergency Management, Incident Command System, and Hazard Vulnerability Assessment , Infection control and prevention, Continuity of Operations (Defining Essential Function, Succession Planning, Human Resources, Alternate Location, Defining Patient Populations, and Data Management)
Part 3: DEVELOPMENT OF POLICIES AND PROCEDURES – June 18, 2019, 1:00-2:00 pm EDT
Patient Classification Systems, Transportation Classifications, Surge Capacity, HIPAA/IT, Tracking Patients and Staff, and Roles and Definitions., Organizing the plan.
Part 4: COMMUNICATION/TESTING AND TRAINING – June 25, 2019, 1:00-2:00 pm EDT
Health Care Coalitions; Specific Hospice Requirements; MOUs; Government Emergency Telecommunications System; Collaborative Relationships with Local, State, Federal, and Indian Tribe Nations; Annual/Orientation Requirements, Documentation of Training, Types of Exercises (Tabletop, Functional, Full-scale), After Action Report, Revising and Updating the Plan

REGISTER AT:
https://www.rbclimited.com/product/edp-4-part-series/

DISCOUNT CODE: RBCEDP

Good for all community-based, home care, hospice & Medicare certified home health agencies

A New Version of OASIS is Coming!

Is your staff just getting used to completing OASIS-D?  Surprise,   CMS recently announced there will be a new version for 2020!

It was a surprise to many when CMS declared during the April 3rd, Open Door Forum, that effective January 1, 2020 there would be a new version of OASIS. I know I was thinking at first that the presenter misread the effective date, but apparently this update is needed to support the Patient Driven Grouping Model (PDGM).  One more thing for HHA to deal with. But, HCA of MA will be here for you.  (See link at end to out Fall 2019 OASIS training.)  

Thankfully though, after reviewing the  CMS Memorandum,   I realize that there are only a few minor changes.

Quick synopsis:   Two items will be added to the Follow-Up assessment:  M1033-Risk for Hospitalization and M1800-Grooming. These items should pose no problem since staff is familiar with answering these items at SOC/ROC. Surprisingly, the other change involves the “option” to no longer answer 23 items!  Rather than leaving the items blank,  the clinician will be required, however,  to respond by using the equal sign (=).

Here are the “optional” items for your convenience.

Start of Care/Resumption of Care (SOC/ROC)

• M1910 Fall risk Assessment

Transfer (TRN) and Discharge (DC)

• M2401a Intervention Synopsis: Diabetic Foot Care

• M1051 Pneumococcal Vaccine

• M1056 Reason Pneumococcal Vaccine not received

Follow-Up (FU)

• M1021 Primary Diagnosis

• M1023 Other Diagnoses

• M1030 Therapies

• M1200 Vision

• M1242 Frequency of Pain Interfering with Activity

• M1311 Current Number of Unhealed Pressure Ulcers at Each Stage

• M1322 Current Number of Stage 1 Pressure Injuries

• M1324 Stage of Most Problematic Unhealed Pressure Ulcer that is Stageable

• M1330 Does this patient have a Stasis Ulcer

• M1332 Current Number of Stasis Ulcers that are Observable

• M1334 Status of Most Problematic Stasis Ulcer that is Observable

• M1340 Does this patient have a Surgical Wound

• M1342 Status of the Most Problematic Surgical Wound that is Observable

• M1400 Short of Breath

• M1610 Urinary Incontinence or Urinary Catheter Presence

• M1620 Bowel Incontinence Frequency

• M1630 Ostomy for Bowel Elimination

• M2030 Management of Injectable Medications

• M2200 Therapy Need

HCA of MA next Blueprint for OASIS Accuracy will be held on November 4th and 5th. Option to take the certification exam will be on the 6th.

You can register for the course here.

Blog post by:  Colleen Bayard.

Electronic Visit Verification (EVV) System Resource Page Now Available for HCA Members!

The Home Care Alliance of MA is happy to announce a resource page completely dedicated to keeping Home Health Care Providers informed for the upcoming Electronic Visit Verification (EVV) Mandate. You can access this page by going to www.thinkhomecare.org/EVV

Massachusetts Executive Office of Elder Affairs is moving forward with “deliberate speed” to implement the federal EVV mandate.  Massachusetts is developing a hybrid model for EVV, allowing agencies to use their current EVV vendor or choose any vendor that can collect and transmit the required data elements.  For those agencies without an EVV vendor, Massachusetts has contracted with Optum to design a free EVV system.  The current schedule would require personal care agencies that participate in the MA Home Care program that currently have an EVV system in place to begin testing in late 2018. Personal care agencies that don’t currently have an EVV system in place will have additional time to either go live with the Optum system or select and implement an EVV system from another vendor.

According to data collected by EOEA, well over half of the EOEA home care provider agencies in MA do not currently have an EVV vendor.  These agencies will have to make important purchasing decisions within the next year. This page is created to provide the must up to date information on EVV including important resources, vendor information and more.

EVV Vendor Webinar Series

Along with access to to important documents, websites, and contact information – HCA of MA has developed a monthly webinar series that allows EVV Vendors a one hour webinar to demonstrate their platform to our members for FREE! The webinars are typically held the 2nd Tuesday of every month and are recorded in the case you cannot listen to the series live.

The current schedule is as follows:

March 19th – Agency Workforce Management (Recording Available)

April 9th – HHAeXchange (Recording Available)

April 23rd – CellTrak

May 14th – Homecare GPS

June 11th – HomeCareIT

July 9th – Sandata

August 13th – 4Tellus

September 10th – ClearCare

REGISTER ONLINE

*Registering online gains you access to all webinars currently scheduled and any future webinars that may be scheduled

 

EVV Implementation: One Agency’s Experience

One additional resource webinar will be a one hour program with an agency member: HebrewSenior Life. Members of the HSL Leadership Team as they share their experience with implementing an EVV platform.  They will offer product highlights and the benefit and impact experience for clients, workforce, operations, and finances. They will also share their approach to the establishment of policies, procedures, and timelines for success with onboarding for caregivers and leaders.

This webinar will be held on Wednesday, April 24 at 1:00PM. This is also FREE to members!

REGISTER HERE

Access the EVV Resource page at: http://www.thinkhomecare.org/EVV

How CMS Stole Home Care Christmas!

Every person in Home Care liked caring a lot.
But the Grinches south of Baltimore, they surely did not!
The Grinches hated home care, delivered in any which way.
Now, please don’t ask why. No one knows what to say.

It could be CMS didn’t have a mom or a dad.
It could be their jobs were incredibly sad.
But, the most likely reason was this just this my dear,
Their hearts were hijacked by nasty old fear.

They feared the support, the need and the caring.
“It has to stop now,” they said, nostrils flaring!
“I hate all their teamwork! I despise all they do!
I’ll pick them all off, one-by-one, two-by-two!”

With a laugh and snort, they sneered, “I know just what to do!”
And put pen to paper to plot their evil, awful coup.
They threw it all at us, with the usual glee,
COPs, OASIS changes, and even VBP!
“I’ve ruined them now and forever, I swear,
Let’s see how you cope, how you can possibly still care!”

But across the Land of Home Care, they got down to work.
HCA had their back, a membership perk!
Every worker in home care, the small and the tall,
Still kept making visits, swearing once and for all:
“The families, they need us, and we will be there!
No Grinches in DC can stop us with fear.”

And what happened then? Well… in home they say,
Those Grinches’ hearts grew three sizes that day!
The true meaning of home care shined right on through.
They ripped up their papers, stopped pre-claim review.
“Maybe home care,” they said, “isn’t about regs, or rules.
Maybe home care is bigger, a national jewel!”

“Thank you, home care,” they said, now with a smile.
“For once, in your shoes, maybe I’ll walk a mile.
I’ll make a home visit, I’ll assist with a med.
I’ll listen to stories from clients in bed.”

“I’ve a new understanding why you do what you do.
Let’s make a new year that’s bright with a start that’s brand new!”

Return to www.thinkhomecare.org.