Category: Regulation

Good News! HIPPS Codes for Medicare Advantage Claims Delayed

Health Insurance Prospective Payment System (HIPP)S codes on Medicare Advantage (MA)  plan claims will be delayed until July 2014 according to information from NAHC.  Bellow is an excerpt from a letter CMS sent to the health plan.

”MAOs and other entities were instructed that effective December 1, 2013 dates of service (DOS), the disposition for the HIPPS codes edits would be changed from ‘Informational’ to ‘Reject’ for any Skilled Nursing Facility (SNF) and Home Health (HH) encounters submitted without the appropriate HIPPS codes. The purpose of this notification is to let you know that the December 1, 2013 DOS ‘Reject’ edit will be delayed to July 1, 2014 DOS. The ‘Informational’ edit for HIPPS codes would remain in place until that time.”

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Comments Sought on Palliative Care/EOL Education Regulations

The MA Department of Public Health recently released a set of draft regulations relative to a new requirement that – effective next year – will require  hospitals and skilled nursing facilities to distribute information on palliative care and end of life care. Under the draft regulations, the facilities will be required:

    1. Have a process to identify appropriate patients
    2. Ensure that appropriate patients receive information
    3. Distribute information about hospice and palliative care in a timely manner

Some HCA members have reviewed these draft regulations and believe that the draft definitions do not make a clear enough distinction between palliative care and hospice care almost using the terms interchangeably.  There will be a public hearing on these rules in Boston on Nov 21st  at 2 PM in the Public Health Council Room, Second Floor, Department of Public Health, 250 Washington Street, Boston.

The Alliance will be providing comments and encourages other members to do so, either in person or in writing. Electronic or written testimony can be submitted  to: Reg.Testimony@state.ma.us   as an attached Word document or as text within the body of an email and type “End-of-Life” in the subject line.   All submissions must include the sender’s full name and address.  The Department will post all electronic testimony that complies with these instructions on its website  All testimony must be submitted by 5:00 p.m. on November 22, 2013.

Members are encouraged to also provide feedback to the Alliance for our testimony as well.

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Deadline Approaching for OSHA’s Hazard Communication Standards Training

To better protect workers from hazardous chemicals, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (HCS) aligning it with the United Nations’ global chemical labeling system. There will be new labeling and data sheets on chemicals according to the Globally Harmonized System (GHS). GHS is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets.

OSHA is requiring all employers, including home health and hospice, to train all employees on the revised hazard communication labels and data sheets elements (e.g., pictograms and signal words) by December 1, 2013. The Hazard Communication Standard, will be fully implemented in 2016 and benefit workers by reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards, especially for low literacy workers. OSHA’s standard will classify chemicals according to their health and physical hazards, and establish consistent labels and safety data sheets for all chemicals made in the United States and imported from abroad.

Further information can be reviewed at OSHA’s Hazard Communication Safety and Health which includes links to OSHA’s revised Hazard Communication Standard and guidance materials such as Q and A’s, OSHA fact sheet and Quick Cards.

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CMS Posts Clarification of the Definition “Confined to Home”

On October 18th, Centers for Medicare & Medicaid Services (CMS) released Change Request 8444– Home Health Clarification of Benefit Policy Manual Language on Confined to Home.  This Change Request requires Medicare contractors to be aware of the clarification of the definition “confined to the home” as stated in the revised section 30.1.1 of Chapter 7 of the “Medicare Benefit Policy Manual”. In addition, CMS removed vague terms, such as “generally speaking”, to ensure the definition is clear and specific. CMS has also release a MLN Matters for provider reference. The implementation date for this clarification is November 19th, 2013

CMS is amending its policy manual as follows:

For purposes of the statute, an individual shall be considered “confined to the home” (homebound) if the following two criteria are met:

Criteria-One:

The patient must either:

Because of illness or injury, need the aid of supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person in order to leave their place of residence

OR

Have a condition such that leaving his or her home is medically contraindicated.

If the patient meets one of the Criteria-One conditions, then the patient must ALSO meet two additional requirements defined in Criteria-Two below.

Criteria-Two:

There must exist a normal inability to leave home;

AND

Leaving home must require a considerable and taxing effort.

 

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Government Shutdown Delays Quarterly OASIS Q&As

Due to the government shutdown, the CMS OASIS Quarterly Q&As will not be released on October 16, 2013 as previously expected. As soon as the government reopens for business, the Q&A release will be rescheduled and the HCA will post the results in our Update

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CMS Issues HHA Reporting Requirements- CR-8441

HHA Reporting Requirements for the Certifying Physician and the Physician Who Signs POC

CMS has issued Change Request 8441 which instructs home health agencies to report the NPI and name of the physician who certifies the patient for home health services and to also report the NPI and name of the physician who signs the POC. CMS is instructing agencies that both the attending physician and the other physician fields should be completed even if the certifying physician is the same as the physician who signed the plan of care. The additional reporting requirements do not go into effect until July 1, 2014.

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Deadline to Register for MAC Satisfaction Survey is September 30th

Let your voice be heard!

Time is running out to participate in the MAC Satisfaction Indicator (MIS).  Registration will close on Monday, September 30th. Your opinion counts so please participate by completing the  Registration Form

Medicare Administrative Contractor Satisfaction Indicator

CMS strives to continually refine its processes, systems and services in the pursuit of excellence which is our commitment to continuous improvement. In living this commitment, we are providing a tool, the Medicare Administrative Contractor Satisfaction Indicator (MSI), to measure the level of satisfaction providers and suppliers experience with their Medicare Administrative Contractors (MACs).  The MSI allows providers the opportunity to influence CMS’ understanding of Medicare contractor performance.  The goal of the MSI is to evaluate these experiences and determine the key drivers of customer satisfaction.  In addition, CMS will use the results of the MSI to monitor trends, improve oversight and increase the efficiency of the Medicare program.

 

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Revised Publication Available for Reporting Fraudulent Home Care Referral Practices

In an effort to help home health agencies educate their partners in the provider community about lawful referral practices, the Home Care Alliance has revised and updated the first in a publication series called “Keeping It Legal.”

The document below is intended for distribution to hospitals, physicians, skilled nursing facilities and other sources that refer patients for Medicare-certified home health services. The Alliance has updated contact information for oversight entities so that providers, patients or the families of patients can accurately report fraudulent activity if they wish to do so. The document also lays out some of the basic examples of wrongful activity that should be reported.

With the help of HCA members and those they work with and work for, the Alliance hopes that this document will be passed along and posted prominently in an effort to promote home health services that are high-quality and ethical.

 

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Alliance Submits Comments on PPS Rule

The Home Care Alliance of MA today submitted comments to CMS on the proposed rule setting Medicare home health rates for 2014. CMS has proposed cutting rates by 3.5% for each of the next four years.

Citing data concerns, inadequate allowances for increasing regulatory costs and operating margins, inequities in the proposed wage index, and an incomplete analysis of the impact on both agencies and Medicare patients of CMS’s proposal to cut rates for each of the next four years, the Alliance urges CMS to go back to the drawing board on 2014 rates.

The Alliance’s comments are available here.

Comments to CMS on the proposed rule are due TODAY at 5:00 p.m., and can be submitted online at www.regulations.gov.  Enter “RIN 0938-AR52” in the search box to find the proposed rule.

Home Health and Hospice ODF- August 7th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, August 7, 2013 at 2:00 PM  (ET).

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 14952615.

 Proposed Agenda

1. Opening Remarks

2. Announcements & Updates

  • Marketplace Websites Re-Launch

Website: https://www.healthcare.gov/

Website: http://marketplace.cms.gov/

  • FY 2014 Hospice Wage Index and Payment Rate Update
  • HHCAHPS
  • CMS.net Upgrade
  • Status Update on Home Health Advance Beneficiary Notice – Caroline Baker

Website:   http://www.cms.gov/Medicare/Medicare-General-Information/BNI/HHABN.html

Questions: RevisedABN_ODF@cms.hhs.gov

  • DME Cert Task Force

3. Open Q&A

 

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