Category: Regulation

ACOs Expanded in Massachusetts

Last week, CMS announced 106 new ACOs, bringing the total approved by CMS since passage of the Affordable Care Act to 250. The nine newly designated “Shared Savings”  ACOs in Massachusetts are:

Accountable Care Organization of New England (led by Mercy Medical Center President & CEO Dan Moen); Cambridge Public Health Commission (Cambridge Health Alliance CEO Patrick Wardell); Cape Cod Health Network ACO (Cape Cod Health’s Sr. VP, Managed Care Jack Lipomi); Lahey Clinical Performance Accountable Care Organization (Lahey Health System Chief Network Development Officer Gregory Bazylewicz, M.D.); Pioneer Valley Accountable Care (CEO of Baycare Health Partners Stephen Sweet, M.D., affiliated with Baystate Health System); Southcoast Accountable Care Organization (Southcoast Hospitals Group President & CEO Keith Hovan); Total Accountable Care Organization DBA Collaborative Health ACO (President of MetroWest Accountable Healthcare Organization Bethany M. Gilboard); Winchester Community ACO (Winchester Hospital Board of Directors member Dale Lodge); and Accountable Care Clinical Services (Chairman and CEO of Accountable Care Associates, Dr. Philip F. Gaziano).

Here is the official list from CMS of all 106 ACOs and their contact information.

In other ACO news, this week’s  MHA Monday Report reports that Boston’s Beth Israel Deaconess Medical Center (BIDMC) has redesigned  their existing Pioneer ACO.  They are entering into a partnership with the 1,600 physician Beth Israel Deaconess Physician Organization to create the newly designed Beth Israel Deaconess Care Organization (BIDCO).

According to a press release from BIDMC, “The hospitals and physicians will work in 50-50 partnership within BIDCO, sharing governance, joint contracting, and risk. It is designed to accommodate community hospitals and physicians that are not owned or employed by BIDMC, and results in a restructuring of the current Beth Israel Deaconess Physician Organization to add hospital ownership for purposes of jointly contracting with payers in the future.” The hospitals and physicians will jointly invest $12 million annually for five years to improve the coordination of patient care among hospitals and physicians, as well as to increase the ability of caregivers to focus on population health management.

The Beth Israel Deaconess Physician Organization had previously been designated by CMS as one of only 32 Pioneer ACOs – a designation recognizing groups that had taken an early lead in coordinating care for patients across care settings. That Pioneer designation transfers to the BIDCO.

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Home Health and Hospice Education Webinars for 1st Quarter 2013.

The Medicare Administrative Contractor for Massachusetts, NHIC, Corp. has posted upcoming Home Health and Hospice Education Webinars for January-March 2013.  Providers are encouraged to participate in these educational sessions.

More information on registration, materials, and training assessments are provided on the Education Programs Information section for NHIC website. Note: Registration is required for all programs.

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Reminder- “Home Health and Hospice ODF” – Wednesday, January 9th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, January 9, 2013 at 2:00 PM Eastern Time (ET).

Proposed Agenda

1. Proposal to discontinue the Home Health Advance Beneficiary Notice (HHABN), Form CMS-R-296, and replace the HHABN with a new Home Health Change of Care Notice (HHCCN), Form CMS-10280, and the existing Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131.

2. HHCAPS

3. Home Health Study regarding Access to Care

4. Home Health & Hospice Quality Reporting Update

5. Retroactive Grouper Change for Basel Cell, Squamous Cell, and Unspecified Malignant Cancers for Home Health Services Rendered October 1, 2011 through December 31, 2012

6. Update to OASIS Web-Based Training at: http://surveyortraining.cms.hhs.gov , Addition of Module, OASIS C Online Training: Patient Tracking Domain

7. Flu Vaccination Announcement

8.  Open Q&A

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Dial: 1-800-837-1935 & Reference Conference ID: 78868196.

The audio recording of this call that can be accessed by dialing 1-855-859-2056 and entering the Conference ID beginning 2 hours after the call has ended. The recording expires after 2 business days

Encore: 1-855-859-2056; Conference ID: 78868196

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Fiscal Cliff Deal Reached with No Home Care Cuts or Copays

In the waning hours of the federal legislative session, the Senate passed an agreement to avoid the fiscal cliff that was then approved by the House with none of the feared elements concerning home health care.

The bill extends tax rates for the vast majority of citizens along with a series of other tax-related extenders and unemployment benefits. It also includes a “doc fix” through New Year’s Eve 2013.

U.S. Capitol BuildingThe agreement was approved with bipartisan support and, according to the National Association for Home Care & Hospice (NAHC), there are no cuts to Medicare home health services or hospice care benefits, payments, or payment rates. No home health copays are in this bill and there are no Medicaid cuts affecting home care. Additionally, NAHC found that protection against the Medicare outpatient therapy cap is continued through December 31, 2013.

The “doc fix” is paid for primarily through cuts to hospitals with nearly $15 billion in a combination of coding adjustments and DSH payment reductions. ESRD payments are also affected by a reduction of $4.9 billion.

The CLASS program established to help finance long term care services through a voluntary insurance approach under the Affordable Care Act is repealed under the Senate bill. The repeal has no financial consequence as CMS earlier indicated that it would not implement the CLASS program due to its inability to assure financial viability.

NAHC also notes that a very important provision in the Senate bill is the establishment of a Long Term Care Commission that will be charged with the responsibility to develop a plan for meeting the needs of the growing population of Americans needing care in the home and in other settings. The Commission will have 15 members appointed by the President and Congressional leaders with representation of consumers, older adults, family caregivers, and care providers.

For more on the fiscal cliff and the health care-related implications, see stories below:

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Planned Revisions to Home Health Beneficiary Notice-Open for Public Comment

Presently home health agencies (HHAs) are required to use the Home Health Advance Beneficiary Notice (HHABN), CMS-R-296 to provide beneficiaries with change of care notification consistent with HHA Conditions of Participation (COPs) in addition to its liability notice function. Option Box 1 addresses liability, Option Box 2 addresses change of care for agency reasons, and Option Box 3 addresses change of care due to provider orders.

In CMS’ effort to “streamline, reduce, and simplify notices to Medicare beneficiaries,” HHABN Option Box 1, the liability notice portion, will be replaced by the existing Advanced Beneficiary Notice of Noncoverage (ABN) which is approved by Office of Management and Budget (OMB) for conveying information on beneficiary liability. CMS will introduce the “Home Health Change of Care Notice” (HHCCN) as a separate, distinct document to give change of care notice in compliance with HHA conditions of participation. The HHCCN will replace both Option Box 2 and Option Box 3 formats of the HHABN. The single page format of the HHCCN is designed to specify whether the change of care is due to agency reasons or provider orders. Form Number: CMS–10280 (OCN: 0938–New) To obtain copies of the supporting statement and any related forms for the proposed paperwork collections referenced above, go to CMS’ Web Site address at http://www.cms.hhs.gov/, or Email your request, including your address, phone number, OMB number, and CMS document identifier, to Paperwork@cms.hhs.gov, or call the Reports Clearance Office on (410) 786-1326.

The full notice and details for submitting public comments on the proposed changes can be accessed in the Federal Register.  Comments are due by February 11, 2013

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CMS Updates Policy Requirements for Medical Record Corrections

CMS released Transmittal 442, Change Request (CR) 8105 on December 7th. It provides instructions to Medicare contractors regarding amended, corrected, and delayed entries in medical records. This updates the CMS Medicare Program Integrity Manual, Section 3.3.2.5 effective January 8, 2013.

According to this Change Request, the MACs, CERT, Recovery Auditors, and ZPICs are instructed NOT to consider entries that don’t comply with recordkeeping principles, even if exclusion of an entry will result in a claim denial.

In the manual update, “providers are encouraged to enter all relevant documents and entries into the medical record at the time they are rendering the service.” However, the policy goes on to acknowledge that there may be occasions when documentation was not completed or completed properly and may need to be amended. Medicare contractors are told that they are to consider all submitted entries that comply with the widely accepted Recordkeeping Principles, but NOT consider any entries that do not comply with the principles.

Recordkeeping principles for record amendments apply to both paper and electronic medical records. These principles include:

  • Clearly and permanently identify any amendment, correction or delayed entry as such; 
  • Clearly indicate the date and author of any amendment, correction or delayed entry; 
  • Not delete but instead clearly identify all original content.

When correcting a paper medical record, the “principles are generally accomplished by using a single line strike through so that the original content is still readable. Further, the author of the alteration must sign and date the revision. Similarly, amendments or delayed entries to paper records must be clearly signed and dated upon entry into the record.”

CMS acknowledges that although “record keeping within an EHR deserves special considerations” the same principles apply. EHR corrections or delayed entries must:

  • Distinctly identify any amendment, correction or delayed entry, and;
  • Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.

The manual update also states “If the MACs, CERT or Recovery Auditors identify medical documentation with potentially fraudulent entries, the reviewers shall refer the cases to the ZPIC and may consider referring to the RO and State Agency”.

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Encore-Special ODF for Hospice Providers

Did you miss the December 19th Open Door Forum that presented information about the Hospice Quality Reporting Program?

CMS announced that this ODF will have an encore recording available until midnight December 22nd

Agenda Topics included:

  • Updates about the upcoming availability of the data submission website
  • Information about how to access the data submission website and create a user account
  • Details about the data submission process
  • Question and Answer session

ENCORE CALL IN:  1-855-859-2056

CONFERENCE CODE:  81540883

 

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DPH Mandates-Electronic Submission of Plans of Correction

The MA Department of Public Health, Division of Health Care Quality, recently announced in Circular Letter 12-12-577 effective January 1, 2013, certified facilities, agencies and providers will be required to submit Plans of Correction (POC) by email for all statements of deficiencies.

DPH has created three email addresses to ensure that POCs can be submitted to the appropriate surveyors and regions for review:

Detailed instructions for the submission of POCs by email, including the specific email address to which the POC should be sent, will be included in the cover letter to the facility for each Statement of Deficiency.

The following must be observed when submitting POCs by email:

  • Title the email “[Facility/agency name] POC for Survey Ending [date of survey]
  • Scan the POC, signed and dated, separately from any supporting documentation
  • Scan the POC and supporting documentation as separate .pdf files
  • Name the scanned files using the facility name and ending date of the survey
  • Do not send a hard copy of the POC by mail or fax when emailing a POC

When the POC is received at the appropriate email address, the agency/provider will receive an automated response indicating that the POC has been received. Addressing the email with a facility name and date of survey will generate an auto-reply email which will serve as a receipt for the initial submission of a POC, and indicate that the POC has been received by the Department and is being processed for review.

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Therapy Questions and Answers – Revised December 2012

On December 14th CMS released revised Therapy Q&As that reflect the changes for the therapy reassessment requirement from the Final Rule 2013. The provisions in this final rule are effective for episodes ending on or after January 1, 2013, unless otherwise specified in the final rule. For episodes that begin in CY 2012 and end in CY 2013, the therapy provisions of this final rule do not apply. The therapy provisions of this final rule are applicable to episodes that begin on or after January 1, 2013.

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Special ODF for Hospice Providers

CMS is hosting a Special Open Door Forum for all hospice providers on December 19 from 1-2 pm EST. The Special ODF will present information about the Hospice Quality Reporting Program

Agenda Topics will include:

  • Updates about the upcoming availability of the data submission website
  • Information about how to access the data submission website and create a user account
  • Details about the data submission process
  • Question and Answer session
The Participant Dial in is: 1-800-837-1935
The Conference ID: 81540883

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