Home Care Alliance Signs onto CMS Letter to House and Senate Leadership

The Alliance signed onto an advocacy letter written by the National Association for Home Care and Hospice (NAHC) to House and Senate leadership asking for their support in suspending the implementation of CMS’s final for the Home Health Prospective Payment System (HHPPS).

This week, the Alliance signed onto an advocacy letter written by the National Association for Home Care and Hospice (NAHC) to House and Senate leadership asking for their support in suspending the implementation of CMS’s final for the Home Health Prospective Payment System (HHPPS). As a reminder, CMS’s final rule if implemented would reduce Medicare payments for home health services by $635 million in 2023 and trigger an estimated $18 billion in payment reductions over the next decade.

The Alliance joined 49 other home care associations across the nation in signing this letter. The letter highlights the immense impact that the final rule would have on the agency across the country, noting that “the impact of those payment cuts would exacerbate the ongoing dismantling of this essential benefit that serves over 3 million of the most vulnerable Medicare beneficiaries, providing them with exceptional care quality in their own homes, preventing high-cost hospitalizations, and offering an alternative to life-changing institutional care while saving Medicare billions in spending every year.

NAHC is currently working with key sponsors and co-sponsors of the CMS bill (S.4605/H.R.8581)that was introduced in August, to re-write the bill in response to CMS’s final ruling. The exact details of the revision of the bill have not yet been determined, but once they are the Alliance will re-engage with the Massachusetts delegation to update them on the changes and to garner their support for the new version of the bill. We will also be asking our members to once again reach out to their member of Congress to support the new version of the bill.

The Rundown – October 2022

Federal Recap

Jake Krilovich flew down to D.C. to meet with members of the Massachusetts delegation to gain their support for The Preserving Access to Home Health Act of 2022, which would delay CMS’s from implementing their proposed 7.69% payment cut, and an additional $2 billion in “clawback” cuts to home healthcare services. We are happy to report that Congressman McGovern will be signing onto the bill, marking the first member of the Massachusetts delegation to co-sponsor the bill. We want to thank everyone who took the time to reach out to their Member of Congress asking for their support of this important bill.

In superficial news, House Speaker Nancy Pelosi said in early September that the House would work to introduce and pass a bill that would place new restrictions on lawmakers stock trading abilities. To absolutely no one’s shock the bill that was introduced received weak support from legislators on both sides of the aisle, killing any prospect of a stock trading bill in the near future. Who would have thought that lawmakers who currently subjected too little to zero oversight/penalties for the stocks they purchase, would be open to more regulations on their actions. Both Republicans and Democrats have been under constant scrutiny over the last couple years for their sometimes-blatant conflict of interest when it comes to buying stocks. As an example, 4 legislators  sold stocks in early 2020 after private briefings on the risks of a coronavirus outbreak in the United States. An analysis by The New York Times showed that from 2019 to 2021, 97 representatives and senators or their immediate family members reported trades of stocks, bonds or other financial assets that could have been influenced by committees they were serving on. Abigail Spanberger (D-VA-7), leading proponent of banning trading by members of Congress called out party leadership for not supporting a stock trading bill more aggressively. Rep. Spanberger called the delay an example of why her party needed new leaders in Congress, branding it “a failure of House leadership.”

I’m livin’ life, do or die, what can I say I’m 23 now, but will I live to [own a home]? The way things is going, I don’t know”– Coolio (RIP the legend). The Biden administration and legislators have been closing following the Federal Reserve’s (Fed) continuous interest rate hikes, which they say is to combat rising inflation. The Fed raised the federal funds rate again in September by .75 percentage points, bringing the benchmark rate to a range between 3% and 3.25% for the first time since 2008. The increase interest rates have caused the housing and stock market to plummet over the last month, with the S&P tumbling down 9.3% in September and average mortgage rate to sky-rocket over 6%, the highest since 2008. Increased interest and mortgage rates have made the prospect of younger people owning homes a pipe dream with no immediate hope around the corner.

Finally, just before the end of school bell was about to ring, legislators quietly (maybe too quiet) struck an agreement on short-term spending measure before a midnight deadline to avoid a government shutdown. Only 10 Republicans voted in favor of the bill along with all Democratic members of the House. The Senate had approved the measure a day earlier, on September 29. The agreement funds the government through December 16th, when Congress would be hoping to pass an omnibus bill to fund the government for fiscal year 2023. The stopgap measure includes $12.3 billion in emergency economic and military aid for Ukraine, $1 billion in heating assistance for low-income families through the Low-Income Home Energy Assistance Program, $20 million for the water crisis in Jackson, Mississippi, billions in disaster aid, and over $112 million for federal court security.

Look-Ahead

As I walk through the valley of the shadow of death, I take a look at my life and realize [just the campaigns are left]” – Coolio (couldn’t resist). October marks the final stretch of campaigning for the upcoming midterm elections in November. One more month of having to endure annoying campaign ads during commercials breaks of the Patriots games (is it just me? or is everyone else also getting ads for New Hampshire races). A year ago, experts widely predicting a red wave to crash the elections with Republicans winning both the House and Senate easily, but that is no longer the case. Recent polls have shown that Democrats have scraped their way back in both the House and Senate races. Polls show that Republicans are only slightly favored to take back the House while in a shocking turn of events Democrats are slightly favored to hold control of the Senate (Herschel Walker has some explaining to do to his party). But if 2016 taught us anything it’s that we need to take all polls with a grain of salt. These are only projections; at the end of the day no one really knows what will happen on election day.

We are continuing to focus our attention on CMS’s annual proposed rule for Medicare home health services, that included a proposed 7.69% permanent cut, and an additional $2 billion in “clawback” cuts for CY2023. While we are excited that Congressman McGovern signed on, we need to keep the momentum going. HCA will continue to work with members of the delegation in hopes to get more members to sign on with Congressman McGovern. We need your help to get this bill over the finish line. Power comes in numbers. We are asking everyone to continue to reach out to their member of Congress to urge them to support this bill. Please use this action alert to write to your member of Congress urging them to support the Preserving Access to Home Health Act of 2022.

Lastly, Jerome Powell, Chair of the Fed, signaled the Feds plan to lift interest rates by another 1.25 percentage points before years end, which would bring the federal funds rate to 4.25-4.5% just in time for holiday shopping. Considering the Fed only has two meetings left, that could mean another 75-basis point hike in November followed by a half-point increase in December. Looking even farther into the future, the Fed is bracing to lift rates to 4.5-4.75 percent by next year. Six officials, however, see rates soaring to 4.75-5.0 percent in 2023, which would be the highest since 2007 if it comes to fruition. On Monday the United Nations warned that the Fed and other central banks risk pushing the global economy into recession followed by prolonged stagnation if they keep raising interest rates. The agency estimated that a percentage point rise in the Fed’s key interest rate lowers economic output in other rich countries by 0.5%, and economic output in poor countries by 0.8% over the subsequent three years.

State Recap

Extra! Extra! Read all about it! The Home Care Alliance was quoted in two recent articles that were published by State House News and the Commonwealth about the Enough Pay to Stay legislative add-on rates and the Home Care Alliances fight for better base rates through the upcoming rate review for home health aides. The Home Care Alliance is working tirelessly to grow awareness for the need for a proper rate review and for base rates to be increased to a level that can sustain the industry that allows for providers to meet growing demand for services.

Like the Red Sox, things in Massachusetts State House were mostly quiet in September. State legislators continue their never-ending negotiations on a final economic development bill. the $4 billion package includes amongst other provisions, $1 billion in tax rebates and reforms. Senate budget chief Michael Rodrigues told 1420 WBSM this week. “I do expect we will [be] able to pass an economic development bill in the neighborhood of maybe $2.5 billion,” Rodrigues said, forecasting a bottom line lower than the combined surplus and American Rescue Plan Act spending in the original bill.

Governor Baker has spent the last month on a press tour as he plans to leave office when his current term ends. This past week Baker made his final annual address to the Providers’ Council, highlighting all he has done over the last 8 years. Baker highlighted  the saga he went through as a candidate for governor and then as governor to increase Chapter 257 provider rates. “Chapter 257 was enacted in 2008 and it’s just a bunch of letters and numbers. But it was supposed to be a framework and that framework was supposed to ensure that human service organizations were adequately funded from that point forward. It didn’t get funded in 2009. It didn’t get funded in 2010 — by the way, those of you who have really long memories, when I ran for governor in 2010 I said we would fund Chapter 257,” Baker said. “It didn’t get funded in ’10, it didn’t get funded in ’11, it didn’t get funded in ’12, it didn’t get funded in ’13 and, in fact, by the time we were all running for office in 2014, the provider community was spending precious resources on a lawsuit to force the commonwealth to implement its own statute and live up to the requirements and the commitments that were made in Chapter 257.” By May of 2015, Baker said his administration had struck an agreement with providers that laid out the state’s commitments very specifically. “And that agreement has paid off,” Baker said, adding that his administration has overseen $813 million in incremental rate increase for human service providers through Chapter 257 since 2015.

Last month I reported that the MBTA shut down the orange and green line for a full month, and that I was highly skeptical that it would re-open in a month like they promised. Well I was wrong….. but not fully. Both the orange and green line re-opened a month after closure as promised, but with limited service. And by limited, I really mean limited. As someone who takes the orange line to work. Missing your train means the difference between being on time and being 20 minutes late to work. MBTA is still suffering from massive labor shortage which has caused them to reduce services. MBTA also has not thrown out the possibility of closing other lines for further repairs.  So technically things are better with the T, but I think that just goes to show how bad things have been recently.

A report released on in September by the Massachusetts Health Policy Commission (HPC), an independent state agency charged with monitoring health care spending growth in Massachusetts, showed a surprising drop in health care spending in Massachusetts in 2020 for the first time since implementation of a landmark cost control law in 2012. HPC report shows that from 2019 to 2020, statewide total health care spending per capita fell 2.4 percent, bucking seven straight years of annual growth, while total health care spending per capita also decreased nationally in 2020, but at a smaller drop of 0.3 percent compared to the 2.4 percent drop in Massachusetts. HPC officials contend that this downward trend is only an anomaly and that they do not view the shift as meaningful progress toward containing prices. The spending growth that dominated recent years is “likely to continue” on an upward trajectory in 2021 and beyond, HPC analysts wrote in their report.

Look-Ahead

Just like I reported in my piece last month, everyone will be focusing on the upcoming elections in November. Everyone will be watching the race between Democrat Maura Healey and Republican Geoff Diehl for Governor.

Healey, 51, currently serves as attorney general, a position she’s held since 2014. If elected Healey would be the first woman elected governor in the state’s history. Diehl, 53, is a former state House Representative, who unsuccessfully challenged Senator Elizabeth Warren for her Senate seat in 2018. Originally from Texas, Diehl has the backing of the state Republican party along with Trump’s. Diehl is considered a more moderate alternative for Republican voters in the primary.

With everyone focusing on the upcoming election and the state legislator currently in informal session, I do not expect much action to happen at the state house in October. At most we would see movement on the economic development bill and possibly (I can only hope) the announcement of when sports betting will becoming legal in Massachusetts.  It’s been two months sense a Governor Baker signed a bill allowing for sports better and regulators are yet to come up with a timeline for when legal wagering might start in Massachusetts. In the meantime, everyone will just have to survive on fantasy sports and survival pools.

HCA will continue to closely track bill that are important to our industry, including the Licensure bill (H.4471) and a rate setting bill (S.774). While the chances are low, HCA has been meeting with legislators and their staff to urge them to take up and pass these bills during informal session. We will provide updates on the bills as needed.

Urge Congress to Support the Preserving Access to Home Health Act of 2022

CMS released their annual proposed rule for Medicare home health services, which includes a proposed reduction to payment rates, and an additional $2 billion in “clawback” cuts to home healthcare services for CY2023.

Please use the action alert below to write to your member of Congress urging them to support The Preserving Access to Home Health Act of 2022.

In June, the Centers for Medicare & Medicaid Services (CMS) released their annual proposed rule for Medicare home health services, which includes a proposed 7.69% reduction to payment rates, and an additional $2 billion in “clawback” cuts to home healthcare services for CY2023. With home care providers already facing an unprecedented workforce shortage, leading many to turn away patients due to lack of staff, inflation, and exceedingly high gasoline prices, now is not the time to cut payment rates.

In response, lawmakers moved quickly to prevent this proposed rate cut that would have a devastating effect on the industry. In August, bipartisan lawmakers introduced The Preserving Access to Home Health Act of 2022 (S.4605/H.R.8581). would delay the 7.69% payment cut proposed for 2023, which would total $1.33 billion in 2023 alone. The bill would also block additional cuts of more than $2 billion as soon as 2024 due to an unjustified “clawback” of payments for critical home healthcare services delivered to seniors and people with disabilities during the pandemic. If the rule were to move forward, up to 45% of providers in Massachusetts will have an overall margin below zero. The Preserving Access to Home Health Act would reduce that impact to just 26% of HHAs, saving countless of agencies across the state.

Patients currently face extensive access challenges and the CMS proposed rule will only exasperate the problem. Home health leaders have consistently outlined concerns related to CMS’ methodology in proposing these payment adjustments while also highlighting significant increases in labor and supply costs across the home health community.

Please use the action alert below to write to your member of Congress urging them to support The Preserving Access to Home Health Act of 2022 (S.4605/H.R.8581).

Alliance Comments to CMS on CY2022 Home Health Rule

To ensure that home health agencies in Massachusetts can provide high-quality care to older adults, the Home Care Alliance of Massachusetts has submitted comments to the federal government regarding the proposed rule for next year’s Medicare home health rates. Our comments to the Centers for Medicare and Medicaid Services (CMS) address several sections of the proposed rule, including:

  • CMS’s flawed reasoning behind the -4.36% “behavioral adjustment” to the rates;
  • Concerns about a budget neutrality adjustment based on 2020 data skewed by COVID;
  • A market basket adjustment that does not account for ongoing costs related to COVID;
  • Protections for counties with large wage index reductions;
  • Modifications to the Value Based Purchasing model before it is implemented nationwide;
  • Greater flexibility around the five-day deadline to submit the new Notice of Admission;
  • Greater flexibility to allow therapist to conduct initial assessments; and
  • Expanded allowances for virtual aide supervisions.

NGS Resumes Home Health Medical Record Review

NGS will resume medical record review after suspension from Public Health Emergency

National Government Services (NGS) recently contacted Alliance staff to review details for the resumption of medical record reviews. This follows the suspension of the Targeted Probe and Educate (TPE) audit because of the Public Health Emergency. We expect that this review will start this week. All the Medicare Administrative Contractors (MACs) will publish information indicating that medical reviews will resume.

NGS has shared some details with Alliance staff about this resumption, which are summarized below; however, the details are not yet posted on their website.

    • NGS will resume post-payment medical reviews. This is different than the TPE program. CMS has not provided any direction to the MACs thus far regarding the resumption of TPE.
    • The post-payment reviews are service-specific (as opposed to provider-specific) and will be a random sample. A service-specific review is one where the MAC is focused on the claim and not the provider.
    • CMS has given a resumption date of August 17, 2020. It is anticipated that providers will begin receiving Additional Documentation Requests (ADRs) once NGS posts more information on their website. NGS indicated it will post a brief description of the service-specific audits on its website and ADRs will be sent approximately 2-3 days after this posting.
    • The timeframe from which NGS will pull claims is January 2019 through February 29, 2020
    • The maximum number of claims to be pulled per provider is 20. There is no minimum. This is less than the total number under the TPE program, and a provider may or may not receive ADRs for a full 20 claims. It is anticipated that the majority of hospice and home health providers will not have this many claims pulled. Any providers having difficulty responding to the ADRs on time should contact NGS and they may be able to work with the provider if the provider makes them aware of the situation.
    • Providers should not wait to receive an ADR request in the mail, but should check the status of their claims processing and identify any with the S B6001 status. These are claims that have had an ADR generated.
    • NGS has 60 days to review the provider’s response to the post-payment ADR. Though providers have 45 days to respond to the ADR, a 30-day response is strongly recommended to ensure that the response is received and recorded by the 45th day.
    • A results letter will be sent after each claim is reviewed.
    • A provider may request education and the NGS may suggest education. Providers are not required to participate in education, although the Alliance strongly recommends it.
    • The error rate (payment error rate or claim error rate) is not as important with a service-specific post-payment review as it is with TPE, since there are no “rounds” in post-payment review as there are with TPE. The MACs are not setting error rate thresholds upon which further NGS action is predicated. As with all medical reviews, if NGS identifies a concern, i.e. a quality concern or indication of potential fraud or abuse, NGS will refer to the appropriate entity (i.e., the appropriate QIO or the division of CMS).
    • NGS will continue to make phone calls to providers for missing documentation or questions about documentation submitted.

It is still possible that providers will receive some other ADRs as part of other review programs such as CERT. CMS contractors, including Unified Program Integrity Contractors, may conduct targeted prepayment and post-payment reviews when there is evidence of potential fraud or gaming. CMS has not yet indicated if the results of the post-payment reviews that are resuming this month would be used for future TPE audits.

If you have any questions, please contact Colleen Bayard at cbayard@thinkhomecare.org.

Colleen’s Corner: Targeted Probe and Educate (TPE)

Did you know that National Government Service (NGS) is focusing one of the home health Targeted Probe and Educate on therapy utilization?

Therapy TPE Audits Lead to Home Health Denials

Did you know that National Government Service (NGS) is focusing one of the home health Targeted Probe and Educate on therapy utilization?

NGS is auditing home health rehab service concentrating on medical necessity, the timeliness of the 30-day reassessments that is performed in conjunction with an ordered therapy service, and the required reassessment content by each rehab discipline. For many of the denials, the reasons stem from the therapist not comparing the present assessment results to prior assessment measurements and failing to document the effectiveness of therapy, or lack thereof, as required by regulation.

It may be beneficial to review with your therapy staff the key components to the therapy reassessment documentation as outlined by CMS.

  • Each rehab discipline must document measurement results of functional reassessment compared to prior measurements
  • Each must also document why therapy should be continued or, if applicable, discontinued
    • Document therapist’s determination of effectiveness of therapy
    • Why therapy is beneficial?
    • Why does the patient need more?
  • Remember the re-assessment is only one component of the home visit; there must be evidence of an ordered intervention as well.
    • Document treatment performed the day of re-assessment
    • Re-assessment without care plan interventions is a not covered service

Be Aware…

If measurement results do not reveal progress toward goals and/or do not indicate that therapy has been effective — then, to continue therapy — there must be consultation with the physician and documentation showing why the therapist and physician determined therapy should be continued.

Don’t forget to confirm continuation of the therapy with the verbal order!

I hope to hear from folks who are experiencing any of these issues with the therapy TPE.

Haunted by TPE? Don’t Let It Frighten You!

Many home health care agencies have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE). Here are answers to many common questions.

Many home health care agencies (HHAs) have contacted me over the past few weeks with questions about the Targeted Probe and Educate (TPE), so I thought I would review the rules because I am sure others have the same questions. NGS has contacted HCA to let us know that there are new TPE audits in Massachusetts: high therapy utilization, long lengths of stay, documentation supporting homebound for Heart Failure, COPD, Diabetes and Dementia, and medical necessity.

How Will the HHA Be Notified:  Agencies will receive a letter from NGS stating the focus of the targeted probe. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records. If you are currently in a TPE audit you will not be chosen for another. If for some reason you receive another TPE please contact Colleen Bayard because agencies should only be under one targeted probe and educate for home health at a time.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: Agencies will be notified of one-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

HHAs are Experiencing New Round of Targeted Probe and Educate

National Government Service (NGS) announces two new rounds of Targeted Probe and Educate (TPE) for home health agencies

Last month, the National Government Service (NGS) notified the Home Care Alliance of Massachusetts about two new rounds of Targeted Probe and Educate (TPE):

High therapy utilization. NGS will be reviewing documentation to ensure all CMS requirements have been met on therapy assessments and 30-day reassessments, as well as, medical necessity.

Documentation supporting homebound criteria. The second edit is specific to four diagnoses: Heart Failure, COPD, Dementia, and Diabetes and if the documentation confirms homebound status.

Many HHAs have contacted me over the past few weeks with questions about the TPE, so I thought I would review the rules because I am sure others have the same questions.

How Will the HHA be Notified: You will receive a letter from NGS stating the focus of the targeted probe: high therapy or homebound for one of the four diagnoses listed above. Expect to receive between 20–40 ADRs, although every agency targeted so far has received a request for the 40 records.

Additional Documentation Request: The Medicare system will generate ADRs and you have a total of 45 days to respond with the requested medical records. Note: It is best to send in at least 30 -35 days, as NGS considers their time to acknowledge receipt of the documentation into their system as part of the 45-day timeframe. If your ADR is one day late it is considered “no response” and counts as an error.

Calculation: NGS calculates the Percent Error Rate (PER) by taking the dollars Medicare would have paid the HHA versus the dollars denied obtaining a percentage. The PER must be 15 percent or below for the HHA to be released from the next round of TPE.

Results Letter: At the conclusion of a round of review, you will receive a letter outlining the TPE process, the reason for denials including the Medicare regulations, denial rates (PER), release or retention from medical review and offer for one-on-one education information.

Education: One-on-one education between NGS medical reviewers and the provider. It is very important to accept the education from NGS at the end of the audit; accepting the education demonstrates that you are trying to improve documentation and will help with the second round of TPE.

If you have any questions or concerns about TPE, it would be great to hear from you. Good Luck!

CMS Proposes Changes to HH Quality Reporting Program

Proposed Changes Could Result in Another Revision to OASIS in 2021! How will this impact you? HCA is looking for your input.

CMS is proposing several changes to the Home Health Quality Reporting Program (HHQRP) in the CY 2020 Home Health Proposed Rule.

The Rule proposes to eliminate one measure (OASIS Item M1242, Frequency of Pain Interfering with Patient’s Activity of Movement), add two new measures, and add several new Standardized Patient Assessment Data Elements (SPADEs) to the Outcome and Assessment Information Set (OASIS) in CY 2021. The revised OASIS for 2021 will be very different from the current OASIS data items collected by your clinical staff.

As required by the IMPACT Act, the proposed two new measures are:

    1. Transfer of Health Information to the Provider-Post-Acute Care (PAC)
    2. Transfer of Health Information to the Patient-Post-Acute Care (PAC)

These measures are designed to improve patient safety by ensuring that the patient’s medication list is accurate and complete at the time of transfer or discharge. These proposed measures also supposed to fulfill CMS’s strategic initiatives to promote effective communication and coordination of care, specifically in the Meaningful Use Initiative area of transfer of health information and operability.

In addition, CMS is proposing to adopt several standardized patient assessments (SPADEs) to the OASIS data set. CMS plans to implement three assessment screens for mental status, confusion/delirium, and mood. The special service, treatments, and intervention assessment require the agency to identify the services and treatment the patient is receiving and if they are taking any high-risk drugs. The assessment item for medical conditions and comorbidities checks for pain during specific activities and checks for hearing and vision impairments. Click click here to see the proposed Item Mockup for the “Transfer of Health” and the “SPADE”

According to the National Association of Home Care & Hospice (NAHC), the organization sees two possible approaches in addressing the proposed changes to the HH QRP.

    1. Recommend that CMS stagger the implementation of the assessment items over several HHQRP years. However, this would result in more iterations of the OASIS assessment tool, and any changes to the assessment tool carry its own burdens and costs; or
    2. Support the new assessment items with the condition that CMS issues a draft version of the revised OASIS data set no less than six months before the implementation date.

Please let the Alliance know how these changes will impact you.

Return to www.thinkhomecare.org.

Members Flock to HCA’s Quality Improvement Meeting

Lots of member interest in HCA’s July QI meeting to discuss medical record audits and upcoming proposed rule changes.

With the sundry of regulation changes in the home health industry over the past few months, the July 24th Quality Improvement (QI) meeting had over 45 members participating in-person and by phone. The numerous medical record audits plaguing the industry dominated the meeting’s discussion.

Multiple agencies have received letters from C2C Innovation Solutions informing them that some claims under appeal have been selected for potential reopening as part of the Medicare Appeals Demonstration. The C2C auditors are conducting the analysis of claims previously adjudicated unfavorably by the Qualified Independent Contractor (QIC), that are currently pending at the Office of Medicare Hearings and Appeals (OMHA) and may be resolved favorably by the QIC.

Other audits that agencies are experiencing are new Targeted Probe and Educate (TPE) audits. These medical record requests are for 5-7 visits and lengths of stay greater than 90 days. No agency is in the third round of the Face-to Face TPE.

One agency reported at the meeting that they are facing three audits simultaneously; a hospice General Inpatient care (GIP) Targeted Probe from NGS, a home health PERM request for Face-to-Face (awaiting ALJ) and eight GIP Post Payment Review by Noridian.

During the meeting there was a lot of member engagement related the 2020 Proposed Rule; the proposal to require OASIS for all payors and the 8% behavioral adjustment. Agencies also discussed strategies for management with PDGM and the process for completing OASIS B-1 for January 1st episodes. PDGM will be a standing QI agenda item.

The HCA is planning to host a PDGM Networking Meeting to help our members with the transition to this new payment model. We are hoping to begin the meetings in September and have a guest speakers and consultants to assist with planning for this historic payment change. Stay tune for further details.

Don’t forget to check out our PDGM Bootcamp on September 24th!

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