Tag: Federal Regulations

HCAs Home Health & Hospice Emergency Prep Workbook Now Available

HCA’s new Home Health Care & Hospice Emergency Preparedness Workbook, co-published with RBC Limited, is now available!

The workbook incorporates all of the Emergency Preparedness requirements in the proposed new regulations recently developed by CMS, and includes a number of sample policies and tools to make compliance easier.

Barbara Citarella of RBC Limited will conduct a series of two webinars on August 27 and September 3 to discuss the proposed regulations and orient home health and hospice providers to the new manual.

You can purchase the Workbook and register for the webinars here.

Webinars will be held on the following dates:

Part I August 27, 2014
10:00 – 11:30 AM

Part II September 3, 2014
10:00 – 11:30 AM

Return to www.thinkhomecare.org.

ODF for Home Health and Hospice, March 5th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday,, March 5, 2014 at 2:00 PM

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 71246014

Proposed Agenda

1. Opening Remarks

2. Announcements & Updates

  • Hospice and Part D
  • Hospice Claims Reporting
  • Hospice & CAHS
  • Hospice Quality Update
  • FY2015 and FY2016 reporting cycles
  • Hospice CAHPS survey
  • HH CAHPS
  • Home Health Quality Update

For details visit the ODF Website

Return to www.thinkhomecare.org.

National Association Provides Update on Rebasing, SGR

The National Association for Home Care & Hospice (NAHC) held a conference call revealing a frantic final week of advocacy activity before Congress takes its holiday recess until the New Year.

The major part of that activity for home health agencies centered around the attempt to delay the impacts of Medicare “rebasing” cuts through an amendment to the Medicare Sustainable Growth Rate (SGR) fix – also known as the physician fix.

Senator Debbie Stabenow (D-MI) offered an amendment on behalf of home care that would delay the cuts for one full year and give the industry the chance to lobby CMS to change their methodology with more updated and accurate data. Unfortunately, part of the compromise of the short -term physician fix was that it was a “clean” bill, which means no outside amendments. According to NAHC, even the hospital industry had amendments that were proposed and then withdrawn because of that agreement between Democrats and Republicans.

The short-term SGR fix will last for three months and must be offset by $7 billion. The good news there is that none of the offset is coming from the home health industry. Some of the hit is being hit is being absorbed by cuts to Long Term Care Hospitals and Disproportionate Share Hospital rates, but copays and additional reductions for home care  were avoided.

The light at the end of the tunnel comes from the fact that the Senate is working on a permanent SGR fix and the Stabenow amendment will still be in play for that effort. In addition, NAHC was successful in getting language from the FITT Act into the Senate’s proposal. The FITT Act essentially establishes a national pilot program for home-based telemonitoring provided by home health agencies. It will not be straight reimbursement, but is meant to be a shared savings approach where the providers and Medicare will share in any efficiencies gained. Moreover, if the program is successful, NAHC indicated that the program could be expanded by Medicare without going back to Congress for approval since it is a pilot and not a demonstration.

In terms of hospice care, NAHC also reported that another amendment would allow physician’s assistants to serve as the attending physician for hospice patients.

All of these wheels will be in motion in the New Year, but the main idea is that Democrats and Republicans compromised on a two-year deal that keeps the federal government running and it was done without implementing co-payments for home care. The 2% sequester cuts are extended for an additional two years, but those are not “new” cuts and are simply to make the budget scoring work. By the time the extended years are reached, the sequester could potentially be a thing of the past.

The Home Care Alliance thanks agencies for sending nearly 200 messages to the Massachusetts Congressional Delegation in two days. That education and advocacy will be critical as we move forward to fight rebasing in the New Year. Of course, further information will be provided as it becomes available.

 

Return to www.thinkhomecare.org.

 

Advocacy Alert: Contact Congress Re: Amendment Delaying Rebasing Cuts

Congress is working in the final days before the holiday recess on a long-term Medicare Sustainable Growth Rate (SGR) process and an amendment to that process could delay the impending rebasing cut to home health care.

The Alliance is asking that agencies and advocates contact their Member of Congress TODAY to educate them about the amendment and what it means for Medicare home health agencies. U.S. Capitol Building

Senator Debbie Stabenow (D-MI) has offered an amendment that essentially delays the effects of rebasing so that CMS can hopefully adjust their methodology with updated and more accurate data. Educating the Massachusetts Congressional Delegation is crucial to getting support for the amendment as there is so much happening in the final two days of activity.

More information and a prepared email message is available on HCA’s Legislative Action Network and it only takes a minute to log on and add your voice to this critical push to delay a damaging 3.5% cut per year over the next four years.

We also urge members to call the offices of your Congressional representatives directly using the message below as a guide. Simply call the main switchboard at (202) 224-3121, request a transfer to the office of your Congressional representative, and ask to speak to the individual from that office that is responsible for health policy.Here is the text of the message to Congress if you choose to call:

The U.S. Centers for Medicare and Medicaid Services (CMS) has finalized a rule imposing unprecedented Medicare home health reductions under a process called “rebasing.” All told, the impact on providers will be a $200 million cut in each of the next four years.

We are asking for your support in backing an amendment from Senator Debbie Stabenow as well as any corresponding effort in the House to amend the Medicare Sustainable Growth Rate (SGR) process.

These are the largest cuts to home health in decades, and they will cause many agencies to close their doors, especially if these cuts are compounded by Medicare reductions via the continuing budget resolution. Such cuts are counter-productive at a time when health reform relies on cost-effective care at home to serve vulnerable citizens.

CMS’s rebasing cuts were finalized on November 22 and go into effect on January 1. This leaves little time to delay these disastrous cuts and compel CMS to conduct a more fair, accurate and thorough analysis of its fiscal assumptions.

The data is clear. Many Medicare-certified home care providers are already operating in the red across all sources of payment. These new cuts – scheduled to be compounded for each of the next four years – will cripple the industry and create barriers to care. Yet, despite similar trends across the country, CMS concludes that draconian rebasing reductions are needed to eliminate positive margins in home health. CMS’s math simply does not add up.

Many in Congress agree. A bipartisan letter sent to CMS raised strong concerns, stating that the rebasing methodology relies on “incomplete data and analysis that results in the under-counting of home health agencies’ costs per episode of care, and an inappropriately high rebasing adjustment.”

Home care providers nationwide thank you and your colleagues in Congress for your strong stance on rebasing and we ask for your continued active engagement supporting Senator Stabenow and others to delay rebasing and initiate a more rational approach from CMS.

Thank you.

Return to www.thinkhomecare.org

Stage 2 EMR Adoption Deadline Pushed Back One Year

Several healthcare industry news outlets, including Modern Healthcare, are reporting that CMS is extending the deadline that providers are required to show Stage 2 “Meaningful Use” criteria  of electronic health records (EMR).

The overall deadline is delayed for one full year and, according to Modern Healthcare, Stage 2 of the CMS incentive program to encourage EMR adoption will be extended through 2016. Stage 3 won’t begin until at least fiscal year 2017 for hospitals and calendar year 2017 for physicians and other eligible professionals that have by then completed at least two years at Stage 2.

CMS and the Office of the National Coordinator for Health Information Technology at HHS say that the delay is intended help both federal entities focus on helping providers meet Stage 2’s demands for patient engagement, interoperability and information exchange, as well as use data collected during that phase to inform policy decisions for Stage 3.

The proposed rules relative to the requirements providers must meet for Stage 3, as well as the 2017 Edition of standards that health IT developers must build and test their systems to match, are expected to be released in the fall of 2014 .

The Modern Healthcare article noted that the program, created under the America Recovery and Reinvestment Act of 2009, has paid out about $17 billion since January 2011, according to the latest CMS data.

Return to www.thinkhomecare.org.

CMS Presents Jimmo v. Sebelius Manual Update

CMS is conducting a call on program manual updates related to the Jimmo v.Sebelius law suit on the CMS MLN Connects,  Thursday, December 19th at  2-3pm ET.  The program title is Program Manual Updates to Clarify SNF, IRF, HH, and OPT Coverage Pursuant to Jimmo v. Sebelius

To Register: Visit MLN Connects™ Upcoming Calls. Space may be limited, register early.

Agenda

  • Clarification of Medicare’s longstanding policy on coverage for skilled services
  • No “Improvement Standard” is to be applied in determining Medicare coverage for maintenance claims that require skilled care
  • Enhanced guidance on appropriate documentation

On January 24, 2013, the U. S. District Court for the District of Vermont approved a settlement agreement in the case of Jimmo v. Sebelius, involving skilled care for the inpatient rehabilitation facility (IRF), skilled nursing facility (SNF), home health (HH), and outpatient therapy (OPT) benefits. “Nothing in this Settlement Agreement modifies, contracts, or expands the existing eligibility requirements for receiving Medicare coverage.”

The goal of this settlement agreement is to ensure that claims are correctly adjudicated in accordance with existing Medicare policy, so that Medicare beneficiaries receive the full coverage to which they are entitled. The settlement agreement sets forth a series of specific steps for CMS to undertake, including issuing clarifications to existing program guidance and new educational material on this subject.

As part of the educational campaign, this MLN Connects™ Call will provide an overview of the clarifications to the Medicare program manuals. These clarifications reflect Medicare’s longstanding policy that when skilled services are required in order to provide reasonable and necessary care to prevent or slow further deterioration, coverage cannot be denied based on the absence of potential for improvement or restoration. In this context, coverage of skilled nursing and skilled therapy services “…does not turn on the presence or absence of a beneficiary’s potential for improvement, but rather on the beneficiary’s need for skilled care.” Portions of the revised manual provisions also include additional material on the role of appropriate documentation in facilitating accurate coverage determinations for claims involving skilled care. Target Audience
Skilled Nursing Facilities; Inpatient Rehabilitation Facilities; Home Health Agencies; and providers and suppliers of therapy services under the Outpatient Therapy Benefit

ODF on December 11th

Save the Date!

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, December 11, 2013 at 2:00 PM Eastern Time. If you wish to participate, dial 1-800-837-1935; Conference ID: 70980706.

Tentative Agenda:

I. Announcements & Updates

  • Ordering & Referring Physician
  • HHCAHPS
  • Home Health Rule Publication
  • Q Code Requirement

II. Open Q&A

III. Special Breakout Session with Q & A Hospice Item Set (HIS) and upcoming Training. Session starts promptly at 2:40 p.m.

Visit the Open Door  Forum Website for more information.

Return to www.thinkhomecare.org.

NB: The original post accidentally indicated that the forum was to be on December 11; the post has since been corrected.

CMS Posts Clarification of the Definition “Confined to Home”

On October 18th, Centers for Medicare & Medicaid Services (CMS) released Change Request 8444– Home Health Clarification of Benefit Policy Manual Language on Confined to Home.  This Change Request requires Medicare contractors to be aware of the clarification of the definition “confined to the home” as stated in the revised section 30.1.1 of Chapter 7 of the “Medicare Benefit Policy Manual”. In addition, CMS removed vague terms, such as “generally speaking”, to ensure the definition is clear and specific. CMS has also release a MLN Matters for provider reference. The implementation date for this clarification is November 19th, 2013

CMS is amending its policy manual as follows:

For purposes of the statute, an individual shall be considered “confined to the home” (homebound) if the following two criteria are met:

Criteria-One:

The patient must either:

Because of illness or injury, need the aid of supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person in order to leave their place of residence

OR

Have a condition such that leaving his or her home is medically contraindicated.

If the patient meets one of the Criteria-One conditions, then the patient must ALSO meet two additional requirements defined in Criteria-Two below.

Criteria-Two:

There must exist a normal inability to leave home;

AND

Leaving home must require a considerable and taxing effort.

 

Return to www.thinkhomecare.org.

CMS Issues HHA Reporting Requirements- CR-8441

HHA Reporting Requirements for the Certifying Physician and the Physician Who Signs POC

CMS has issued Change Request 8441 which instructs home health agencies to report the NPI and name of the physician who certifies the patient for home health services and to also report the NPI and name of the physician who signs the POC. CMS is instructing agencies that both the attending physician and the other physician fields should be completed even if the certifying physician is the same as the physician who signed the plan of care. The additional reporting requirements do not go into effect until July 1, 2014.

Return to www.thinkhomecare.org.

Alliance Submits Comments on PPS Rule

The Home Care Alliance of MA today submitted comments to CMS on the proposed rule setting Medicare home health rates for 2014. CMS has proposed cutting rates by 3.5% for each of the next four years.

Citing data concerns, inadequate allowances for increasing regulatory costs and operating margins, inequities in the proposed wage index, and an incomplete analysis of the impact on both agencies and Medicare patients of CMS’s proposal to cut rates for each of the next four years, the Alliance urges CMS to go back to the drawing board on 2014 rates.

The Alliance’s comments are available here.

Comments to CMS on the proposed rule are due TODAY at 5:00 p.m., and can be submitted online at www.regulations.gov.  Enter “RIN 0938-AR52” in the search box to find the proposed rule.