Category: Regulation

State Seeks Waiver from Three-Day Rule

With the input of several health care provider groups, including the Home Care Alliance, the state sent a letter on July 23rd to CMS Administrator Marilyn Tavenner officially requesting a waiver from the so-called “three-day rule.”

The rule refers to Medicare’s requirement that post-hospital extended care services in a skilled nursing facility are not allowed unless they are preceded by a hospital inpatient stay lasting three consecutive days. The Home Care Alliance joined other groups like Mass. Hospital Association, Mass. Senior Care Association, Mass. Medical Society and others in voicing support for such a waiver in multiple stakeholder meetings.

The idea is that patients can be properly directed to skilled nursing facility care and/or home health services, but eventually and ideally transitioning back into the community. All the while, patients would receive an appropriate level of care and avoid unnecessary hospitalizations.

The state’s Executive Office of Health and Human Services asks that the waiver include Medicare Fee-for-Service patients and last for three to five years.

The Home Care Alliance will continue to monitor the state’s request and provide updates.

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New OASIS Q&As Released

The July Q&As are here!

CMS has just released the latest guidance for OASIS, July 2013 Quarterly Q&As.  This quarterly update contains 16 new question and answers including guidance related to:

  • Observation stays-When a patient is in observation status at a hospital past day 60 of the current episode, treat this event as a missed recertification and complete the recertification as soon as possible after the patient returns home
  • M1055- clarifying the response if an agency does not immunize patients
  • Clarification to multiple questions related to pressure ulcers and surgical wounds
  • Clarifying time frames in multiple M-items
    • M1240- time frame used to assess pain,
    • M1620 time frame when to assess bowel incontinence and
    • Clarification to M1242, Response 4 – “All the time”
  • Timely resumption of care (ROC)-when a ROC OASIS is done outside the required 48-hour time frame, clinicians must answer “no” to several best practice questions:
    • M1240 (Pain assessment),
    • M1300 (Pressure ulcer risk assessment),
    •  M1730 (Depression screening),
    •  M1910 (Falls risk assessment) and
    • M2250 (Plan of care synopsis).-if a best practice listed under M2250 is not applicable to the patient, answer “NA.”

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Open Door Forum is Tuesday, July 9th

The next Home Health, Hospice & Durable Medical Equipment (DME) Open Door Forum is scheduled for Tuesday, July 9, 2013 from 2:00pm – 3:00pm ET.

Agenda includes:

  • Announcements & Updates
  • Updated Healthcare.gov Announcement
  • Hone Health CAHPS
  • Hospice Vendor Call
  • Requirements for Long Term Care Facilities & Hospice Services
  • Status Update on Home Health Advance Beneficiary Notice
  • Open Q&A

If you wish to participate, dial 1-800-837-1935; Conference ID: 97842778

CMS Reveals Proposed Rule with Further Cuts to Home Health Care

After Medicare payment cuts to home health agencies amounting to an estimated $72.5 billion over a 10-year period, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule on the Home Health Prospective Payment System with further cuts reducing payments by $290 million.

CMS announced the rule in a press release, which estimates that approximately 3.5 million beneficiaries received home health services from nearly 12,000 home health agencies, costing Medicare approximately $18.2 billion in 2012.

The release continues that the proposed decreases reflect the effects of the 2.4 percent home health payment update percentage ($460 million increase), the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, and the non-routine medical supplies (NRS) conversion factor ($650 million decrease), and the effects of ICD-9-CM coding adjustments ($100 million decrease). In addition, the rule proposes routine updates to the HH PPS payment rates such as updating the payment rates by the HH PPS payment update percentage and updating the home health wage index for 2014.

The CMS proposal is based on a projected 2013 differential between cost and revenue (margins) of 13.63 percent, which is at “severe odds” with calculations by the National Association for Home Care & Hospice (NAHC) and MedPAC.

Using a larger database than employed by CMS, NAHC estimates the 2013 margin at 8 percent to 9 percent. NAHC is seeking clarifications and a full disclosure of its calculation data and methodology. At this point, NAHC believes that the proposal is based on an unsupportable calculation.

“The proposal places the 3.5 million Medicare beneficiaries receiving home care services at risk of losing access to care as nearly half of the providers of this vital service would be paid less than the cost of care. It is neither fair nor right and needs to be changed,” stated Val J. Halamandaris, president of NAHC.

The Home Care Alliance is working with NAHC and other organizations to analyze the full extent of the proposed rule and advocate against these additional cuts.

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OASIS-C1 is Here!

CMS has issued a Notice in the June 21st Federal Register announcing the proposed version of the OASIS–C1.  This draft of OASIS C-1 has 110 items and reflects changes to accommodate the need to enable the coding of diagnoses using the ICD-10-CM coding set which goes into effect October 1, 2014. The draft also reflects changes to address issues raised by stakeholders, such as updating clinical concepts and modifying item wording and response categories to improve item clarity; and to reduce burden associated with OASIS data collection by removing items not currently used by CMS for payment, quality, or risk adjustment. The draft also adds one new item M1011 (Inpatient diagnosis) at Recertification/Follow-up for the purposes of potential case-mix adjustment.

Comments on the draft OASIS-C1 must be received by August 20, 2013. When commenting,  reference the document identifier or OMB control number (OCN). To be assured consideration, comments and recommendations must be submitted in any one of the following ways:

  1. Electronically.

You may send your comments electronically to http://www.regulations.gov. Follow the instructions for ‘‘Comment or Submission’’ or ‘‘More Search Options’’ to find the information collection document(s) that are accepting comments.

  1. By regular mail.

You may mail written comments to the following address:

CMS, Office of Strategic Operations and Regulatory Affairs,

Division of Regulations Development,

Attention: Document Identifier/OMB Control Number__ Room C4–26–05,

7500 Security Boulevard, Baltimore,

Maryland 21244–1850.

The revised instrument, a table that compares the OASIS-C (Current Version) to the OASIS-C1 (Proposed Data Collection), and the supporting documentation can be found on CMS Paperwork Reduction Act (PRA) listing page, click here and scroll to CMS-R-245.

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CMS Competitive Bidding Program Starts July 1st

Starting on July 1, 2013, Medicare is scheduled to expand the Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) Competitive Bidding Program to some areas in Massachusetts (Boston-Cambridge-Fall River-New Bedford- Quincy- Springfield-Worcester)  This program changes the amount Medicare pays for certain DMEPOS, and makes changes to which suppliers Medicare will pay to supply these items to Medicare beneficiaries.

To find out if a supplier is a contract supplier for the program check on the CMS DMEPOS Competitive Bidding Website for the “Supplier Directory” or by calling 1-800-MEDICARE (1-800-633-4227).

The eight product categories that are included in this program are:

1. Oxygen, oxygen equipment, and supplies;

2. Standard (power and manual) wheelchairs, scooters, and related accessories;

3. Enteral nutrients, equipment, and supplies;

4. Continuous Positive Airway Pressure (CPAP) devices, Respiratory Assist Devices (RADs) and related supplies and    accessories;

5. Hospital beds and related accessories;

6. Walkers and related accessories;

7. Support surfaces (Group 2 mattresses and overlays); and

8. Negative Pressure Wound Therapy pumps and related supplies and accessories.

 

For more information, CMS also published a Tip Sheet “What You Should Know if You Need Medicare-covered Equipment or Supplies”

Return to www.thinkhomecare.org.

Home Health & Hospice ODF

The Centers for Medicare & Medicaid Services (CMS) will hold the next Home Health, Hospice & Durable Medical Equipment (DME) Open Door Forum on Wednesday, June 26th from 2:00pm – 3:00pm, ET. (The agenda has not yet been released)

If you wish to participate, dial 1-800-837-1935; Conference ID: 97842778.

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RFA Available for ‘Money Follows the Person’ Transition Coordination

The team managing the Money Follows the Person Demonstration released the following announcement regarding RFA’s to provide “transition coordination.” Any agencies interested are encouraged to either apply or at least become familiar with some of the community supports and services involved in the demonstration.

 

The Executive Office of Health and Human Services (EOHHS) has issued an RFA to contract with multiple qualified entities to provide MFP transition coordination to MassHealth Members enrolled in the Money Follows the Person (MFP) Demonstration. MFP transition coordination involves the performance of a broad a range of functions that will assist and enable individuals to transition from a nursing facility, long-stay hospital or intermediate care facility for people with intellectual disabilities to a community-setting with supports and services.

To view this document, please follow the directions below:

  • On the Comm-pass Home Page (http://www.Comm-pass.com), click on the “Solicitations” tab.
  • Click on the tab “Browse all Open Solicitations”.
  • Click on the second bullet “By Entity/Department”.
  • Find the Executive Office of Health and Human Services, and select by clicking on the check box.
  • On the Department page, Executive Office of Health and Human Services should be the only agency listed.  Click on the Select check box.
  • Scroll down to the procurement: 13MEEHSMFPTRANSITION (“Request for Applications for MFP Transitio …”)
  • Click the eyeglass icon on the right.
  • Click on the “Specifications” tab.

 

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Guest Post: ICD-10 Preparedness – Where Are You in the Process?

Guest Post by: Joan L. Usher, BS, RHIA, COS-C, ACE

Medicare Certified Home Health Agencies need to implement their ICD-10 preparedness plans now.  This is the single largest change the health care system has seen since the inception of Medicare.  Changing to ICD-10 is not a simple coding change: it impacts every department in the organization.  Follow these 5 steps to develop your agency’s ICD-10 preparedness plan.

Organize

Establish a Steering Committee with key players from major departments.  The ease and success of the transition relies heavily on strong leadership support.

Assess

Assess the impact on all departments.  This step is crucial in determining which items need to be completed pre-ICD-10, including testing of claim submissions with ICD-10 codes, redesign of EHR screen, or paper documents to capture documentation needed. Consider vendor and payer readiness.  Determine how to operate dual systems, and for how long.  Assess coder’s knowledge of the current coding model.  Assess whether the coding model will work under the increased specificity of ICD-10. Continue reading “Guest Post: ICD-10 Preparedness – Where Are You in the Process?”

CMS Releases Hospice Item Set Draft

CMS recently published a  draft version of the Hospice Item Set (HIS) that hospice agencies will be required to collect for patients admitted on or after July 1, 2014.

The HIS has two versions: Admission and Discharge. The admission version needs to be completed within 30 days of admission and CMS estimates that it will take your hospice 19 minutes to gather and input all the information needed to complete. The discharge version of the HIS must be completed within 30 days of discharge and is estimated to take 10 minutes to complete the shorter discharge set.

Information CMS is proposing to collect includes numerous process measures, such as whether the patient was asked about preferences regarding CPR and other life-sustaining treatment, and whether the patient or caregiver was asked about spiritual or existential concerns.

If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850.

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