ODF-Medical Review of Therapy Claims

The Centers for Medicare & Medicaid Services (CMS) will hold a Special Open Door Forum on the Manual Medical Review of Therapy Claims on October 22, 2012 from 2:00pm-3:30 pm.

The review of therapy claims applies to all Part B outpatient therapy settings and providers including home health agencies that bill Part-B outpatient (TOB 34X). The purpose of this Special Open Door Forum (ODF) is to provide an opportunity for providers to ask questions about the mandated manual medical review of therapy services from October 1-December 31, 2012 that was enacted by the Middle Class Tax Relief and Job Creation Act of 2012.

During this Special Open Door Forum, CMS will discuss therapy documentation requirements and answer any questions providers may have. Participants may submit questions prior to the Special ODF.

To participate in the call, dial: 1-866-501-5502; Conference ID: 44803009.

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OIG Releases 2013 Work Plan for Home Health

The HHS Office of Inspector General (OIG) Work Plan for Fiscal Year 2013 was recently release and provides brief descriptions of activities that OIG plans to initiate or continue in fiscal year 2013.

The Work Plan describes the primary objectives and provides for each review its internal identification code, the year in which we expect one or more reports to be issued as a result of the review, and indicates whether the work was in progress at the start of the fiscal year or will be a new start during the year.

The OIG’s Work Plan for home health addresses seven areas for review:

  • Home Health Face-to-Face Requirement (New)
  • Employment of Home Health Aides With Criminal Convictions (New)
  • States’ Survey and Certification: Timeliness, Outcomes, Follow-up, and Medicare Oversight
  • Missing or Incorrect Patient Outcome and Assessment Data
  • Medicare Administrative Contractors’ Oversight of Claims
  • Home Health Prospective Payment System Requirements
  • Trends in Revenues and Expenses

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NHIC’s Review of Home Health Claims with 5-7 Visits

The NHIC, Corp. Medical Review Department has recently completed a review of home health claims with five-seven visits billed. Of the 80 claims review, 28 were paid as billed. The remaining 52 claims had some denials resulting in a claim denial rate of 65%. The total charges reviewed included $72,694.98 of which $32,749.95 was denied. This resulted in a charge error rate of 45%.

The majority of the claims were denied because the skilled nursing services were not supported as being medically necessary in the medical records. Read more in the educational article Review of Home Health Claims with 5-7 Visits

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Skin and Wound Handoff Tool – for All Providers

The Massachusetts Pressure Ulcer Collaborative (PUC) recently developed a Skin and Wound Handoff Tool that can be used across the continuum of care.  The PUC was formed in 2010 by the Massachusetts Hospital Association (MHA), Massachusetts Senior Care Association, and the Home Care Alliance of Massachusetts to implement a statewide quality initiative to prevent pressure ulcers across the continuum of care through the promotion of best practice, education and improved communication.

The committee encourages all health care providers to pilot the form and to provide feedback to the committee. If you have any questions or comments please email Colleen Bayard.

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Home Health and Hospice ODF

This month’s CMS Home Health, Hospice & DME Open Door Forum  is scheduled for Wednesday, October 3, 2012 at 2:00 p.m.

To participate by phone:   Dial: 1-800-837-1935 & Reference Conference ID: 76245818.

The agenda includes:

1. Open Enrollment Announcement

2. Home Health & Hospice Quality Update

3. Home Health Care CAHPS Update

4. OASIS Training Update; OASIS-C Online Training: Integumentary Status Domain Pressure Ulcers

Open Q&A

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HHQI Campaign to be Revived

The now dormant Home Health Quality Improvement (HHQI) National Campaign will be relaunched with a free webinar for interested industry participants on  September 18 at 2:00 – 3:30 pm.   The webinar will be repeated from 4:00 – 5:30 and then posted for permanent viewing at the HHQI website:  http://www.homehealthquality.org.

The HHQI is a federal effort to improve quality through the dissemination and use of  evidence-based educational tools, individualized data reports and a variety of networking opportunities for home health and cross-setting providers.

The September 18th Webinar will detail  campaign enhancements and feature accounts of how home health providers have applied HHQI resources in the past to make an impact on their patients.

Alliance Submits Comments on PPS and Survey Rules

The Alliance today submitted comments to CMS on the proposed changes to the Medicare PPS rates for 2013 and the proposed new alternative sanctions in the survey enforcement process.  Specific issues that the Alliance addressed include the case mix creep adjustment, wage index concerns, proposed changes to the face-to-face and therapy reassessment requirements, and proposed Alternative sanctions—including civil money penalties – for agencies with condition-level deficiencies.  The Alliance’s comments are available on our website here

Alliance members are strongly encouraged to submit their own comments on the federal Regulations website.  Enter “CMS-1358-P” in the search box to find the PPS regulation, and follow the instructions to submit your comments.  Comments are due by September 4.

ACA Mandate Ruled Constitutional

In Plain English: The Affordable Care Act, including its individual mandate that virtually all Americans buy health insurance, is constitutional. There were not five votes to uphold it on the ground that Congress could use its power to regulate commerce between the states to require everyone to buy health insurance. However, five Justices agreed that the penalty that someone must pay if he refuses to buy insurance is a kind of tax that Congress can impose using its taxing power. That is all that matters. Because the mandate survives, the Court did not need to decide what other parts of the statute were constitutional, except for a provision that required states to comply with new eligibility requirements for Medicaid or risk losing their funding. On that question, the Court held that the provision is constitutional as long as states would only lose new funds if they didn’t comply with the new requirements, rather than all of their funding.

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Post Acute Patterns and Reform Possibilities Discussed at Annual Meeting

How and how much Medicare pays for post acute care and where there is room for reform was the subject of the featured presentation at the Alliance’s annual meeting by Al Dobson of the Washington think tank Dobson/DaVanzo.  The analysis was part of  the Clinically Appropriate and Cost‐Effective Placement (CACEP) Project, which D/D has been engaged in on behalf of the Alliance for Home Health Quality and Innovation (AHHQI).  According to Dobson, the data present a powerful case for rethinking the role of home health not only for patients leaving hospitals, but for deterring hospitalizations for patients residing in communities.    “The home health community has recognized that it is more cost‐effective than facility‐based settings,” said Dobson,  “but until now, has lacked the data analyses to support anecdotal evidence.”

One of the study’s findings is that of those patients referred for some form of post acute care, 38% are referred for home care; but these patients represent less than 30% of post acute payments.  Dobson also presented data on the range of patient pathways following an acute stay suggesting that globally paid providers and bundled demonstrations are going to take a hard look at these with an eye toward both costs and outcomes and with a goal of  simplification.

The CACEP study has now produced three working papers, all of which are on the AHHQI website,  free of charge.

HCA Updates “Regulatory Center” on Website

Get confused by all the home health care regulations? Have trouble finding the exact regulation you are searching for? Want to find one handy location with all the regulatory links?

Visit the “Regulatory Center” page on thinkhomecare.org  for convenient links to home health care’s federal and state regulations.  You will also find home care related links to Medicare, MassHealth, Managed Care and the Executive Office of Elder Affairs.

Return to www.thinkhomecare.org.