In June,2009 the Foundation for Home Health and the Massachusetts Senior Care Foundation sponsored a invitation only working session for educators, home health and long term care providers. The purpose of the day long session was to promote home health and long term care as clinical placement sites for nursing students thereby increasing their awareness of geriatrics and community based programs as desirable places to work. The program was funded by a grant from the Massachusetts Department of Higher Education Nursing and Allied Health Initiative. Click here for a copy of the report.
Category: Regulation
More OASIS-C Updates
We’ve posted PDF-version of three PowerPoint presentations from CMS OASIS-C implementation calls on the OASIS-C page.
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Updates to the OASIS-C Page
We’ve a new sample letter that explains OASIS-C to physicians, available for download in MS Word format. Elsewhere on the OASIS-C page, you’ll find summaries of information from NAHC and CMS, as well as other pertinent information.
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2010 PPS Rates Finalized: Alliance Calculates Local Rates
CMS posted the final rule on Medicare Home Health PPS rates for 2010 to the web on Friday, October 30, 2009. Compared to the proposed rates released in July, the final rule lowers the market basket adjustment from 2.2% to 2.0%, which lowers the national standard episode rate to $2,312.94. The final rule also makes small adjutments to the regional wage index to reflect updated hospital wage data.
The Alliance has prepared a spreadsheet of all HHRG rates for each geographic area in MA.
The final rule also delays for six months the requirement that agencies survey patients using the standard HHCAHPS satisfaction tool.
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Alliance Comments on PPS Rules
The Alliance submitted comments to CMS on September 28 regarding the proposed PPS rate update for 2010. In the comments, the Alliance recommended that CMS delay OASIS-C implementation and the new HHCAHPS to give agencies additional time to prepare for these changes. We also recommended that CMS rely on targeted fraud enforcement activities rather than across-the-board cuts to weed out abusive providers. See our comments here.
Thanks to the members of the Alliance’s Clinical Directors, Reimbursement, and QI Committees for their assistance in developing our comments.
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Delays in Seasonal Flu Vaccine Distribution
We recognize that this is major inconvenience for all providers who have plans in place for administering seasonal flu vaccine. However, please remember that the pandemic H1N1 virus is currently circulating in our communities and it is important to vaccinate as many people as possible as soon as possible with H1N1 vaccine to mitigate the impact of the H1N1 virus. In New England, we usually don’t experience sustained transmission of seasonal flu virus strains until late fall or early winter, so there is still time to administer seasonal flu vaccine through the fall and winter. While every flu season, and especially this one, reminds that here is very little that is predictable about influenza, CDC and other federal decision making bodies must make decisions based on the best data available at the moment.
We are all in this together, and together we will do the best job possible to protect the residents of the Commonwealth against both seasonal and H1N1 influenza.
Please see attached DPH memo based on the most recent CDC information.
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CMS Releases Case Mix Analysis
CMS recently posted to its website a Final Report prepared by Abt Associates titled “Analysis of 2006 – 2007 Home Health Case-Mix Change.” The report is dated August 20, 2009.
According to the Report, the average case-mix score of Medicare home health patients increased by 15.03 percent between 2000 and 2007, of which 13.56 percent is atributable to “case mix creep,” according to Abt’s analysis.
OASIS-C Final Version
The final version of OASIS-C is now available on the CMS website and the implementation date is January 1, 2009. The guidance document will be available as soon as the OASIS Education Coordinator training is completed in September, 2009. Also posted is a crosswalk from the current B1 version to this final version of “C.”
On October 26th & 27th, the Alliance is sponsoring a 2-day workshopat the Sheraton Hotel in Framingham to assist providers in the transition process. Registration information is now available.
Providers to Receive Letters for TPL Claims Beginning September 8, 2009
Providers should expect to see letters from “Commonwealth Medicine” representing the MassHealth TPL (Third Party Liability) Unit on or about September 8, 2009. The letter, which will take the form of an “Initial Overpayment Notice,” will list those claims for dually-eligible beneficiaries that MassHealth has identified as requiring a Medicare determination of coverage. MassHealth is the payer of last resort and as the subrogee for these beneficiaries is requesting that you begin the demand bill process to determine if Medicare should have been billed for these services. The claims in dispute are for Federal Fiscal Year 2008 or dates of service October 1, 2007 through September 30, 2008.
In preparation for this initiative, the Alliance in cooperation with MassHealth held 2 workshops for providers in July and August. The process and expectations were discusses by representatives of the TPL Unit and the Provider Outreach and Education department of National Government Services reviewed the “demand bill” process.
For a copy of the TPL Powerpoint which includes an excellent timeline, click here. For a copy of the NGS presentation discussing the demand billing process, click here
CMS Publishes HHPPS Updates for CY 2010
The August 6, 2009 Federal Register sets forth an update to the home health prospective payment system for calendar year 2010. In addition, CMS proposes changes to the outlier policy and a submission of OASIS data as a condition of payment. This rule also proposes changes to the language clarifying “skilled services” and seeks input on physician/patient interaction associated with the home health plan of care.
It is important that the industry comment on these proposed changes. Comments are due to CMS by September 28, 2009 at 5PM. Please send a copy of your comments to the Alliance: hsiegel@hcalliancema.org
For a copy of the complete document, click here (large file, please allow a few moments to load).
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