HHAs Must Ensure Physician Enrollment in Medicare

 CMS Releases:  Ordering and Referring Physician Final Rule

On Tuesday, CMS posted for public inspection the final rule “Medicare and Medicaid Programs: Changes in Provider and Supplier Enrollment, Ordering and Referring, and Documentation Requirements; and Changes in Provider Agreement” This document was published in the Federal Register on 04/27/2012.

This rule requires enrollment of physicians ordering home health and other services to be enrolled in the Provider Enrollment, Chain, and Ownership System (PECOS). Work is underway to transition all physicians enrolled in other systems, such as the Legacy system, to PECOS. This process is being expedited by CMS through physician Medicare re-validation.

Home health agencies should  begin checking every physicians Medicare enrollment status in the Ordering and Referring Physician report. Through this report CMS has made available the National Provider Identifier (NPI) and the name (last name, first name) of all physicians and non physician practitioners who are of a type/specialty that is eligible to order and refer in the Medicare program and who have current enrollment records in Medicare (i.e., they have enrollment records in PECOS that contain an NPI).
A new file will be made available periodically that will replace the posted file; at any given time, only the most recent file will be available. It can also be used to search for a particular physician or non physician practitioner by NPI number or by name.
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FYI: “Home Health Prospective Payment System” Fact Sheet Revised

The Medicare Learning Network has recently released the revised Home Health Prospective Payment System” fact sheet and is now available in downloadable format. It includes the following information: background, consolidated billing requirements, criteria that must be met to qualify for home health services, coverage of home health services, elements of the HH PPS, updates to the HH PPS, and healthcare quality. This can be used as a handy tool for new employees to home health care!

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How does Massachusetts Compare to National Results from HHCAHPS?

Results from the CMS national survey, Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey, that asks patients about their experiences with Medicare-certified home health agencies, are now available on Quality Care Finder website.

Massachusetts scored better or the same compared to national results for 4 out of 5 survey items. “Percent of patients who reported that their home health team gave care in a professional way” was the survey result where Massachusetts scored 1% less than the national level. See how specific agencies in your local area compare to the state and national results.

HHCAHPS will be updated every four months with new survey data and will complement the clinical measures available on the “Home Health Compare” website. This survey collects feedback on topics that patients have identified as important to them in determining which home health agencies provide high-quality care. Ratings include an overall rating of home health care and a patient’s willingness to recommend the agency to someone else.

For more information on the survey, visit https://homehealthcahps.org.

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New Web Resource Available on Dual Eligible Demonstration Projects

Massachusetts is leading the charge with a plan to integrate care for dually eligible individuals and most other states have plans to improve care for that population under an Affordable Care Act Program.

A new web resource has been made available from the National Senior Citizens Law Center (NSCLC) that is a one-stop shop for all information about all the states involved in creating a new service delivery plan for the dually eligible.

The new website is dualdemoadvocacy.org and it consists of recommended background reading, state profiles, and advocacy tools. All of these resources are meant to promote the position of NSCLC, but they are general views that are in the best interests of the individual receiving services. Additionally, those views are in line with preventing unnecessary hospital admissions and keeping people in the community whenever possible.

The site also allows people to comment on NSCLC’s specific recommendations.

The Home Care Alliance is continuing its advocacy on the Massachusetts proposal and will provide more information as it becomes available.

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CMS Announces New Accountable Care Organizations in Massachusetts

Two out of the first 27 accountable care organizations (ACO’s) in CMS’ new Shared Savings Program reside in Massachusetts and will be online with its counterparts from across the country this month.

According to a press release by CMS, “The selected organizations have agreed to be responsible for improving care for nearly 375,000 beneficiaries in eighteen states through better coordination among providers.”

The CMS statement continues that all ACOs that succeed in providing high quality care may share in the savings to Medicare, as long as their performance reduces the cost of care and is sufficiently rated on 33 quality measures. The quality measures relate to, among other things, care coordination and patient safety, use of appropriate preventive health services, improved care for at-risk populations, and the patient experience of care.

The Massachusetts ACO’s include Jordan Community ACO and Physicians of Cape Cod AC. CMS provides summaries of each ACO and the Massachusetts initiatives are described here:

  • The Jordan Community ACO is a not-for-profit organization based in Plymouth, Massachusetts and founded in 2012. The Jordan Community ACO consists of more than 100 physicians from Plymouth Bay Medical Associates, Jordan Physician Associates, and a number of specialty physicians from Jordan Hospital. Together, the Jordan Community ACO physicians coordinate the healthcare of more than 6,000 Medicare beneficiaries in Plymouth and Barnstable Counties. This approach ensures that patients receive the right care from the right provider at the right time, making it possible to identify and address problems early, before hospital care becomes necessary.
  • Physicians of Cape Cod ACO has been coordinating care for beneficiaries through a managed care program for 10 years, and intends to bring the expertise developed in that program to the ACO model for fee-for-service beneficiaries. It is expected to serve approximately 5,000 beneficiaries living in Cape Cod, Massachusetts.

Five of the 27 ACO’s are also participating in the Advance Payment ACO program, although none of them are in Massachusetts. One project is located in northern New Hampshire and called the North Country ACO. These 27 ACO’s join the 32 “Pioneer ACO’s” that have 5 projects in Massachusetts.

CMS revealed they are reviewing 150 additional applications for the Medicare Shared Savings Program, of which more than 50 are aiming to be in the Advance Payment Model.

More information is available in CMS’ announcement.

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HCA Encourages Participation in New Direct Service Worker Survey

Organizations receiving Medicaid funding to deliver services under the state’s Home Care Program should be receiving a survey that is part of a study on Direct Service Workers funded by CMS. The Home Care Alliance encourages agencies to complete the survey that will help guide policies towards workforce improvement initiatives.

The Centers for Medicare and Medicaid Services has asked Massachusetts’ Executive Office of Health and Human Services and Executive Office of Elder Affairs to gather and report basic information about the volume, stability, wages, and compensation of the direct service workforce (DSW).

This information will allow state and federal policymakers to:

► Identify and set priorities for long-term support and services reform and systems change.
► Inform policy development regarding direct service workforce improvement initiatives.
► Promote integrated planning and coordinated approaches for long-term supports and services.
► Create a baseline against which the progress of workforce improvement initiatives can be measured.
► Compare workforce outcomes for various programs and populations to better evaluate the impact of policy initiatives.
► Compare state progress with the progress of other states and with overall national performance (where data from other states are available).

According to a cover letter that accompanies the survey, the information in the survey will help agencies and organizations compare themselves to others in Massachusetts and elsewhere in the country.

The survey itself is available online and includes instructions and a summary of purpose. Any questions related to the survey should go to the Direct Service Workforce Resource Center, available toll-free at 1-877-822-2647.

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HCA Goes to Washington

The Home Care Alliance and member agencies will join other associations and agencies from across the country for the annual NAHC March on Washington.

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The annual conference provides a chance to lobby members of Congress on issues of concern and thank those who have supported our causes. For those who are not traveling to Washington DC, the Alliance has made materials available (see below) to use as a guide for a “virtual lobby day” on March 27th when HCA and members visit with the state’s congressional delegation.

Pre-written advocacy messages are available to send off on the virtual lobby day under “Federal/National Issues” on the Alliance’s Legislative Action Center and click any messages that are of concern or interest. The messages will automatically be sent to the correct member of Congress once the online form is filled out asking for contact information. There is also an option to “compose your own message” near the top of that webpage.

If HCA members and advocates choose to contact their

federal representatives by phone, the Alliance has assembled the following materials and fact sheets on some of home care’s priorities, but we invite you to share your own issues and concerns as well.

Finally, be sure to follow the Alliance’s activity in DC, including photos and updates, on Twitter.

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Community-Based Care Transitions Program Announces New Participating Sites

A second round of participating sites were announced by CMS for the Community Based Care Transitions Program (CCTP) and two teams of providers are in Massachusetts.

Covering the central and western part of the state, the accepted projects are from Elder Services of Berkshire County, which includes Berkshire VNA as a partner, and Elder Services of Worcester, which includes a partnership with Metrowest Home Care & Hospice. A summary of the Berkshire County project has not been posted, but the Worcester/Metro West project summary was posted and notes the prior care transitions experience of Metrowest Home Care & Hospice. That project draws on the home care agency’s experience by including a transition RN, telephonic support above what the Coleman care transition model calls for, and also a palliative care component is implemented when necessary.

CMS continues to accept applications for the CCTP with dates for review listed below. The Home Care Alliance has resources available for any  home care agencies interested in applying or for entities looking to include agencies as partners. Those interested can contact James Fuccione at HCA.

  • March 27, 2012– Applications must be received by March 6th to be considered for this review
  • April 10 – Applications must be received by March 20th to be considered for this review
  • April 26 – Applications must be received by April 5th to be considered for this review
  • May 10 – Applications must be received by April 19th to be considered for this review
  • May 30 – Applications must be received by May 9th to be considered for this review
  • June 11 – Applications must be received by May 21st to be considered for this review
  • June 28 – Applications must be received by June 7th to be considered for this review

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Comments Due on Dual Eligible Services Proposal

MassHealth’s final proposal for a State Demonstration to Integrate Care for Dual Eligible Individuals was submitted to CMS on February 16, 2012.  The final Demonstration Proposal and accompanying documents are listed on the demonstration’s webpage.

CMS is seeking public comment through a 30-day notice period.  During this time interested individuals or groups may submit comments to help inform CMS’ review of the proposal.   To be assured consideration, please submit comments by 5 p.m. EST, March 19. You may submit comments on this proposal to MedicareMedicaidCoordination@cms.hhs.gov.

The Home Care Alliance has offered formal suggestions prior to MassHealth’s submission of the proposal to CMS and will be submitting comments at this stage as well.  Any members interested in commenting can contact James Fuccione at the Alliance for guidance.

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President Obama Releases Budget with Copays and Payment Impact for Home Care

President Barack Obama released his proposal for the Fiscal Year 2013 Federal Budget with a scaled back version of copayments for home health care as well as payment adjustments for all post-acute providers.

According to the President’s proposal, a home health copayment of $100 per home health episode would be established and would be applicable for episodes with five or more visits not preceded by a hospital or other inpatient post-acute care stay. This, the budget narrative continues, would ap­ply to new beneficiaries beginning in 2017. The President’s budget notes that this is consistent with a MedPAC recom­mendation to establish a per episode copayment, although MedPAC had recommended a more severe copayment of $150 per episode.

MedPAC’s recommnedation cited by the President’s budget team noted that “beneficiaries without a prior hospitalization account for a rising share of epi­sodes” and that “adding beneficiary cost sharing for home health care could be an additional mea­sure to encourage appropriate use of home health services.” This proposal is estimated to save approximately $350 million over 10 years.

According to the National Association for Home Care & Hospice (NAHC), the President’s Budget also includes a reduced Market Basket Index (inflation) update from 2014 to 2021. The proposed update reductions of 1.1 percentage points each year affect all post-acute providers. These reductions, NAHC states, would be in addition to the 2014 home health rate rebasing and the productivity adjustments starting in 2015. The President estimates this measure will save $63 billion over ten years taking into account the other adjustments for all post acute providers.

Additionally, the Independent Payment Advisory Board (IPAB), which was initially established in the Affordable Care Act, will be strengthened under the President’s budget proposal. The group is charged with keeping Medicare solvent by enacting cost-saving measures if Medicare spending exceeds certain levels. The President’s proposal essentially lowers those spending triggers.

The budget blueprint touts some of the fraud and abuse crackdown and prevention achievements the administration has made and advances suggestions for furthering that effort:

  • Cre­ate new initiatives to reduce improper payments in Medicare;
  • Dedicate penalties for failure to use electronic health records toward deficit reduction;
  • Update Medicare payments to more appropriately account for utilization of advanced imaging;
  • Re­quire prior authorization for advanced imaging;
  • Direct States to track high prescribers and utiliz­ers of prescription drugs in Medicaid to identify aberrant billing and prescribing patterns; and af­firm Medicaid’s position as a payer of last resort by removing exceptions to the requirement that State Medicaid agencies reject medical claims when another entity is legally liable to pay the claim.
  • Alleviate State program integrity reporting requirements by consolidating redundant error rate measure­ment programs to create a streamlined audit program with meaningful outcomes, while main­taining the Federal and State’s government abil­ity to identify and address improper Medicaid payments.

Finally, the President’s budget makes a commitment to follow through on the Department of Labor’s proposed rule on removing the so-called “companionship exemption” for allowing overtime and minimum wage protections.

For more information, view the President’s budget proposal here.

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