OIG Report: ALJs Need Training

Not surprisingly to any agencies involved in the TPL project, a new report from the Office of Inspector General of the US Dept. of Health & Human Services found a range in inconsistencies and shortcomings in the Administrative Law Judge level of the Medicare appeal process.

A sampling of some of the findings of the study:

  • Two State Medicaid agencies [one of which clearly is Massachusetts] filed more than 500 appeals each in 2010.  Many ALJ staff raised concerns about these frequent filers, noting that some of these appellants appeal every payment denial, and pointing out that these appellants have an incentive to appeal because the cost is minimal and a favorable decision is likely
  • The fully favorable [ALJ coverage decision] rate varied substantially by appellant type. For providers, it was 61 percent. In contrast, the fully favorable rate was just 22 percent for State Medicaid agencies.
  • ALJs tended to interpret Medicare policies less strictly than QICs
  • The favorable rate varied widely by ALJ.  According to many ALJ staff, different philosophies among ALJs contribute to the variation in fully favorable rates. They said that given the same facts and the same applicable Medicare policy, some ALJs would make decisions that are favorable to appellants, while others would not.

The report’s recommendations to CMS and the Office of Medicare Hearings and Appeals include:

  • Develop and Provide Coordinated Training on Medicare Policies to
  • ALJs and QICs
  • Identify and Clarify Medicare Policies That Are Unclear and
  • Interpreted Differently
  • Standardize Case Files and Make Them Electronic
  • Revise Regulations To Provide More Guidance to ALJs Regarding
  • the Acceptance of New Evidence
  • Improve the Handling of Appeals From Appellants Who Are Also
  • Under Fraud Investigation and Seek Statutory Authority To Postpone
  • These Appeals When Necessary
  • Seek Statutory Authority To Establish a Filing Fee
  • Implement a Quality Assurance Process To Review ALJ Decisions
  • Determine Whether Specialization Among ALJs Would Improve Efficiency.

Return to www.thinkhomecare.org.

Hospice WebEx Training on Data Submission — Taken Offline

CMS put out notification last week that the WebEx training related to the Hospice Quality Reporting Program (HQRP) was available online.  It was available for a BRIEF time on Wednesday night and Thursday; the WebEx training is temporarily unavailable due to technical issues.  Only the Technical User Guide is available on the website. The contractor is working to correct the issues and will get the training and manual back up as quickly as possible.  The HCA will keep you updated.

Return to www.thinkhomecare.org.

Hospice Quality Reporting WebEx Now Available

Looking for more information about the new requirements for Hospice Quality Reporting?

The CMS WebEx training module on data submission for the Hospice Quality Reporting Program is now available online.  It will remain available until April 2013. The training will help hospices prepare for web-based data entry and submission of quality data affecting the FY 2014 reimbursement rates.

To meet the hospice quality reporting requirements in order to qualify for full payment of Medicare rates in FY 2014, hospices must submit two measures: the Structural/QAPI measure and the NQF #0209 measure. Reporting of the structural measure may begin Jan. 1, 2013, and must be completed by Jan. 31, 2013, while reporting of data on the pain measure (NQF 0209) must be completed by April 1, 2013.

For more information visit Spotlight and Announcements on the Hospice Quality Reporting website.

Boston Globe Letter on Home Health and Readmissions

The following was published in the Boston Globe on Sunday, November 11th:

To the Boston Globe:

A renewed attention on the part of the health care delivery system in general, and hospitals specifically, to keeping people who have been hospitalized from quickly returning is welcome and long overdue (“Hospitals look to lower readmission rates,” G section, Nov. 5). However, in focusing on some new programs and services, the story seemed to miss the solution with a long track record of success. For more than a century, home health care as delivered by visiting nurses and other professionals has been the most valuable and valid means to support patients and minimize complications following a stay in a hospital.

These nurses have knowledge about the patient’s health and what in the home environment may be an obstacle to a patient’s medical progress. Yet, our experience is that far fewer patients are referred for home health services than could benefit from them, generally because of a lack of understanding of qualifying rules for coverage.

As we broaden the post-acute-care safety net, it’s important to remember that visiting nurses, who heal and teach, are most successful at delivering what patients need to avoid a return hospital visit.

Patricia  Kelleher, Executive Director

Home Care Alliance of Massachusetts

Return to www.thinkhomcare.org.

Enhanced Agency GoogleMap Now Available

With 200 member agencies across the state, there’s a Home Care Alliance member near just about everyone.

Now, the Alliance is pleased to announce an improved referral tool to show exactly how close on GoogleMaps:


By clicking on an icon, the map provides contact information about each member while letting you know whether it accepts Private Care, is Medicare Certified, and/or Accredited by the Home Care Alliance.

In it’s current form, the map shows the physical locations of our members.  To do a detailed search by Service Area — i.e., where agencies actually serve — and service type, you can still rely on our Find-An-Agency Search.

Return to www.thinkhomecare.org.

State Reveals ICOs in Dual Eligible Care Demonstration

More than a month passed their anticipated announcement date of September 21st, the state’s Executive Office of Health and Human Services (EOHHS) named the Integrated Care Organizations, or ICO’s, that will be managing and directing both payment and care for the demonstration to integrate services for dual eligibles.

The six organizations are Blue Cross and Blue Shield of Massachusetts HMO Blue Inc. (BCBSMA), Boston Medical Center HealthNet Plan (BMCHP), Commonwealth Care Alliance (CCA), Fallon Total Care, LLC (FTC), Neighborhood Health Plan (NHP), Network Health, LLC. Only Network Health was picked to serve every county in the state and will be the only ICO in Nantucket and Martha’s Vineyard.

Aside from Network Health, all other ICO’s are listed in as few as three counties and as many as eleven.

These organizations were selected for full (F) or partial (P) Massachusetts counties as follows:

BCBSMA BMCHP CCA FTC NHP Network Health
Barnstable F F F F
Berkshire F F
Bristol F F F F
Dukes F
Essex F F F F F
Franklin F F F F
Hampden F F F F F
Hampshire F F F F F
Middlesex F F F F F F
Nantucket F
Norfolk F F F F F
Plymouth F F P F F
Suffolk F F F F F F
Worcester F F F F

These organizations will now be engaged in a “readiness review” over the next two months. As part of the review, EOHHS and CMS will require that the organizations demonstrate full readiness and meet operational requirements.  An ICO will not be able to accept enrollments without successfully completing the joint Readiness Review, negotiating and executing a three-way contract, and receiving any necessary state and federal approvals.

Return to www.thinkhomecare.org.

DHCFP Has Changed to CHIA

The state’s Division of Health Care Finance & Policy (DHCFP) is now an independent state agency called the Center for Health Information and Analysis (CHIA) thanks to the new Health Care Payment Reform Law (Chapter 224 of the Acts of 2012).

The new state agency will have most of the responsibilities pertaining to health care data collection, dissemination and analysis, but according to their website, “CHIA will also take on new roles in support of its mission to examine health care cost and quality information and provide objective data and analysis to assist in the formulation of health care policy.”

CHIA will continue to manage the All-Payer Claims Database and run the annual Cost Trends hearings, but will be collecting and analyzing data in particular that deals with how the new health care payment law is affecting cost trends. Last year, the Home Care Alliance sat on an expert panel to help provide a broader picture of cost trends in Massachusetts and the potential impact of Accountable Care Organizations.

HCA will continue to report on the implementation of Chapter 224 as information becomes available.

Return to www.thinkhomecare.org.

 

NAHC’s Preliminary Summary of PPS Rule

The following was prepared and shared by Bill Dombi of the National Association for Home Care:

The Centers for Medicare and Medicaid (CMS) issued the final rule regarding 2013 payment rates late Friday. The proposal includes the 2013 Market Basket Index (MBI) update of 2.3%, the required 1 point reduction under the Affordable Care Act, and the previously set 1.32 percent case mix creep adjustment. CMS retained the 1.32% creep adjustment rather than increasing it to the potential 2.18% level to account for the full coding weight change through 2010. The main change from the July 5 proposed rule is a reduction of the MBI from 2.5 to 2.3%. The change was due to the use of updated, more recent data.

The rule also includes a most of the proposed policy clarifications regarding the face-to-face rule, Hospice quality data indicators, surveys scheduling, and the imposition of intermediate sanctions for CoP noncompliance. CMS estimates that the net impact on HHAs is a $10 million overall reduction in payments in 2013. This is a smaller negative impact than the proposed rule. While the base rates would increase, the impact of the wage index changes lowers total expenditures. Continue reading “NAHC’s Preliminary Summary of PPS Rule”

Medicare Home Health Final Rule Issued

The Centers of Medicare and Medicaid (CMS) issued the Home Health Final Rule on Friday, November 2nd.  The Rule updates the HH PPS rates, including the national standardized 60-day episode rates, the national per-visit rates, the low-utilization payment amount (LUPA), the non-routine medical supplies conversion factor, and outlier payments. These rates will be effective January 1, 2013. This Rule also establishes requirements for the Home Health and Hospice quality reporting programs, important policy changes on CoP Non-compliance Sanctions, and improvements on Face to Face Encounter and Therapy Assessment Rules.

Return to www.thinkhomecare.org.

How Home Care Helps During Disasters

ABC News has some tremendous footage of home care agencies, the National Guard, and other first responders doing what they do best: caring for their clients, no matter the circumstances.

Our thoughts and prayers go to all those affected by Hurricane Sandy.