Therapy Changes Clarified in PPS Rule

As part of the Home Health PPS Update for Calendar year 2012, CMS also made some minor technical changes to the therapy assessment language found in the prior PPS update for 2011.

Currently the regulation reads that the qualified therapist from each discipline must provide the therapy service and functionally reassess the patient…during the visit which would occur close to but before the 19th visit per the plan of care.  The regulation will now read “…during the visit which would occur close to but no later than the 19th visit per the plan of care.

Additionally, CMS clarified when occupational therapy is considered a “dependent” service and when it is considered a “qualifying” service.

It is a dependent service when the beneficiary initially qualifies for the home health benefit beginning the first episode of care.  That is, the beneficiary’s eligibility for the home health benefit is established by virtue of a need for intermittent skilled nursing, speech language pathology or physical therapy. Then they are entitled to SN, PT, ST, HHA, MSW and OT.

When occupational therapy is the sole skilled service being provided in subsequent episodes after the benefit has been established it is considered a “qualifying service.”

Advocacy Alert: Oppose Co-Pays for Home Health

The debt ceiling negotiations are accelerating in Washington and a deficit reduction deal could be imminent.  Clearly, from news reports, we know that  Medicare cuts are under serious consideration, including the imposition of a home health co-payment.

The Medicare Payment Advisory Commission (MedPAC), the National Commission on Fiscal Responsibility and Reform, and the Congressional Budget Office have all supported a copayment as a deficit reduction measures.   Also on the table, as reported in today’s Boston Globe, a substantial cut to medical education funding for Massachusetts teaching hospitals.   Given the clear evidence that imposing copayments can lead to delaying accesses to needed services (adding costs longer term), home health must send a message to their Senators and Representative urging them to oppose a home health co-pays in deficit reduction negotiations.

Given that these decisions may be made as early as next week, we are asking that you contact our federal officials, especially Senators Kerry and Brown today.

You may send a message using the NAHC Legislative Action Network (NAHC LAN). To oppose home health co-pays and payment cuts, click here. The sample messages found on the NAHC LAN should be personalized to provide members of Congress with your background and the potential impact payment cuts and co-pays would have on senior and disabled Medicare beneficiaries and their families in your state and district.

We suggest also weighing in by phone.  When calling, ask to speak to the staffer who handles Medicare issues.  You may obtain contact information for your Senators and Representative here:  Contact Your Elected Officials.  For a sample phone message, click here.

Return to www.thinkhomecare.org.

 

CMS Proposes Medicare Home Health Payment Changes for 2012

The Centers for Medicare and Medicaid Services (CMS) have issued a proposed rule regarding payment changes as well as revisions to the physician face-to-face and therapy assessment rules.

Below is a summary of the most noteworthy aspects of the proposed rule provided by the National Association for Home Care & Hospice (NAHC):

1.       Proposed 2012 payment base episode rates are reduced to $2112.37 from the current $2192.07. This is a reduction of approximately 3.56%.

2.       The rate changes are due to a proposed 2.5% market basket index inflation update, a 1 point reduction in the MBI under the health care reform law, and a 5.06% case mix creep adjustment.

3.       The increase in the case mix creep adjustment is due to the evaluation of 2009 coding weight changes. CMS found that ¾ of the coding increases was a result of increases in therapy visits above the 14 and 20 visit thresholds.

4.       The 3.56% rate reduction will impact individual providers unevenly. CMS proposes to make significant changes in coding weights by eliminating hypertension as a factor in the calculation, reducing the weights on therapy episodes, and increasing weights on non-therapy episodes. Providers with high volumes of therapy cases could see greater net rate reductions. A provider-specific analysis using the provider’s particular case mix is the only reliable way to assess impact.

5.       CMS proposes to change the face-to-face rule and allow one physician to do the encounter and report the information to another physician who completes the certification and plan of treatment documentation. This should help in circumstances where a patient is under the care of a hospitalist who transfers the patient to a community physician.

6.       CMS proposes to clarify the therapy assessment standard where more than one discipline is involved.

The proposed rule on rates is in line with what had been expected. Nevertheless, that does not turn a lemon into lemonade. The change on the face-to-face rule is appreciated, but will only make a slight improvement as the documentation requirements remain a problem.

CMS also posted the proposed rule on the Medicaid face-to-face encounter requirements. The proposal aligns the Medicaid time frames with the Medicare time frames while providing some flexibility to states to determine other aspects such as the content and form of documentation. The proposal also reaffirms CMS’s position that a homebound requirement in Medicaid home health is not permitted and that services can be provided outside the home. Finally, the proposal offers clarifications on the coverage of medical supplies and equipment.

Another summary is available in a press release issued by CMS with a few more specifics on payment. The Home Care Alliance is working on a specific analysis regarding the payment changes based on the northeast’s wage index and will have that available soon.

See links to the specific proposed rules in the Federal Register below:

 

Return to www.thinkhomecare.org.

Health Care Cost Trends Hearings and Panels This Week

The state’s Division of Health Care Finance & Policy (DHCFP) is holding a series of presentations, speeches and panel discussions this week in regards to health care cost trends reports and cost containment efforts currently underway.

The full agenda for the week features a range of health care experts and stakeholders, including government officials, and there will also be limited room for public comment. This is another opportunity for those interested to hear the state’s work in highlighting cost disparities as well as an attempted move for the state towards global payments and health care cost control.

The hearings are being held from Monday, June 27, 2011 through Thursday, June 30, 2011 at Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129.

Return to www.thinkhomecare.org.

Monday, June 27, 2011 through Thursday, June 30, 2011

Bunker Hill Community College, 250 New Rutherford Avenue, Boston, MA 02129

Geriatric Medication Management Course

Many older home care patients have one or more chronic illnesses and take numerous medications complicating the task of medication management. If you’re a frontline nurse manager, clinical director, QI/QA officer or certified clinical case manager, this online course can help you find practical ways to monitor a patient’s medication regimen.

This 4 unit, self-paced course:

  • Incorporates real-time data to assess your team’s performance and measure improvement; You can also compare your progress with others taking the course.
  • Describes the impact of medication-related problems in older adults
  • Simplifies the 3-step medication reconciliation process with practical tools
  • Walks you through the SBAR technique so you can effectively communicate with physicians
  • Enables you to apply each lesson with your team members; 81% of previous participants said their staff’s geriatric medication management clinical skills improved as a result

 

About the Course

  •     CHAMP launches new site Designed for frontline nurse managers, clinical directors, QI/QA officers, and clinical case managers
  •     10 CE hours for registered nurses and certified clinical case managers

Tuition

Early Bird Special (20% discount now through 6/30/11):

$149 $119 per participant
$109 $87 per participant for members of one of the following state associations:

• California Association for Health Services at Home

• Georgia Association for Home Health Agencies

• Home Care Alliance of Massachusetts

• HomeCare Association of Arkansas

• Home Care Association of Florida

• Home Care Association of New Hampshire

• Home Care Association of New York State

• Home Care Association of Washington

• MHA: An Association of Montana Health Care Providers

• New Mexico Association for Home and Hospice Care

• Pennsylvania Home Care Association

• Rhode Island Partnership for Home Care, Inc.

 

Click this link, Geriatric Medication Management Course, for more information and to register.

Return to www.thinkhomecare.org

MA Congressional Delegation Weighs in on Physician Face-to-Face Requirement

The Massachusetts Congressional Delegation has stepped up again, this time sending a letter to CMS Administrator Dr. Donald Berwick with concern over the physician face-to-face requirement.

Every member of the delegation – Senators Kerry and Brown, as well as US Reps Markey, Frank, Neal, Olver, McGovern, Tierney, Capuano, Lynch,  Tsongas and Keating – signed onto the letter noting that the Massachusetts health care community has made considerable efforts to comply with the rule, but the paperwork burden and duplicative nature of the requirement are proving problematic and that CMS should consider changes.

The letter itself is available here and the Home Care Alliance greatly appreciates the work and support from the Congressional Delegation.

Return to www.thinkhomecare.org.

 

Secretary Bigby Addresses Alliance Annual Meeting

Massachusetts Secretary Judy Ann Bigby reviewed the Patrick Administration’s plans for reform of the health care delivery system in Massachusetts.  In her remarks, Secretary Bigby was clear that just as was the case with universal access, Massachusetts may well move before most other states or the federal government on issues such as global payment and integrated care organizations.  Secretary Bigby was clear that the building blocks for the ICOs – as she called then – would be primary care advanced medical home practices.  “I see a strong role for home based care in areas such as complex care management,” she said.  “Working out your role directly with doctors will be key.”

The state currently has out a Request for Information on the formation of ICOs/ACOs  – comments are due by July 13th.   At the meeting Secretary Bigby indicated an interest in ideas as to how the state policy makers  could support a role for high quality,  cost effective home care in redesigned systems. Among the ideas put forth at the meeting:  test episodic – rather than fee for service –  payment  for MassHealth home health care and do some modeling of what a home -based chronic care bundled payment would like.

Do you have ideas for Secretary Bigby – related to home care under health care reform?  Send them along for inclusion in either the Alliance’s ACO comments or in Annual Meeting follow-up with the Secretary.

Please Circulate Physician Survey on Face to Face Requirement

The National Association for Home Care and Hospice is seeking help from home health agencies in getting physicians to complete a very important short survey that will help inform federal government policymakers about important issues related to CMS’ face-to-face encounter requirement. NAHC is meeting with CMS leadership in the coming weeks to discuss the impact of the face-to-face requirement, and in order to effectively stress the home care industry’s position on this issue, they need substantive data from physicians. P

The 10-question survey is only for physicians and will take less than 5 minutes of a physician’s time to complete. The deadline to submit the survey is Friday, June 24 at the close of business!  To ensure the accuracy and confidentiality of this survey, NAHC has partnered with an independent research company which will collect all responses and keep them completely anonymous. It is very important for the credibility of this survey that physicians be informed that the benefit to them for participating in this survey is to make sure their opinion is heard, whatever that opinion may be.

Click here to download the survey information for physicians.

Click here to down load a page explaining the survey in more detail.

State Seeks Comments on Accountable Care Organizations Through New RFI

The state’s Executive Office of Health and Human Services has released a Request for Information regarding the formation of Accountable Care Organizations (ACO’s) and are seeking comments from “all interested partComm-PASS logoies.”

The RFI includes an introductory letter from Health and Human Services Secretary Dr. JudyAnn Bigby and a thorough explanation of the state’s intentions for the transition to a new payment system. A response template is included in “Attachment A” of the document and comments should be submitted electronically through the Commonwealth Procurement Access and Solicitation System (Comm-PASS). Instructions are available in the RFI and the Home Care Alliance encourages home care agencies to submit comments as they see fit.

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Introducing the New Alliance Career Center

We’re very excited to announce the launch of the new Alliance Career Center, catered specifically to employers and job seekers in Massachusetts’s home care community.

The Career Center replaces our old Job Board. The new module includes a vastly-improved interface for employers with the ability to “feature” your most important listings and to search resumes of job seekers. Job seekers also have the ability to post their resumes online and receive notification of new openings.

In short, it’s a full-function, pro-actively marketed Career Center that gives a much better value to employers and job seekers alike. Features include:

For Employers

  • Create a FREE Employer Profile
  • Reach a targeted audience of local home care professionals
  • Find the most qualified candidates
  • Take advantage of affordable pricing less than half the cost of other job websites
  • Manage applications through your website or the Alliance Career Center
 For Job Seekers

  • Create a FREE Job Seeker Profile
  • Access exclusive job opportunities from top employers
  • Find local and regional home care jobs
  • Get notified immediately of new openings
  • Quickly apply for open positions online
  • Post your resume anonymously

Job listings are competitively priced and begin at just $175 for a 30 day job.  Employers may further reduce their costs by purchasing packages of five or ten jobs, or by becoming members of the Alliance.  Posting your resume is completely free of charge.

To get started…

Create a FREE Employer or Job Seeker profile and start posting your resume and open positions today!

Return to www.thinkhomecare.org.