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.

Colleen’s Corner: Quality Check

An Update on Quality Reporting Measures.

Did You Know?

The quality measure Improvement in Pain Interfering with Activity is being removed from Home Health Compare as of the April 2020 Compare Refresh. However, home health agencies are still collecting data for this measure through CY2020.

This quality measure will also be removed from the Quality of Patient Care Star Rating which will be calculated using seven measures beginning April 2020. Make sure to check how this will impact your agency’s star rating, so check out your Quality of Patient Care Star Rating Provider Preview Report in your agency’s CASPER Folders

The January 2020 Compare Refresh will be available this week, on January 23. CMS is no longer publicly reporting Emergency Department Use without Hospital Readmission During the First 30 Days of Home Health, and Rehospitalization during the First 30 Days of Home Health on Compare beginning with this January 2020 Refresh.

The OASIS Quarterly Q&As are scheduled to be posted on January 21, 2020.

Make your Star Ratings Rise to the Top

Provide focused education to your clinical staff with Blueprint for OASIS Accuracy training hosted by the Home Care Alliance on April 15-16, 2020 at the Sheraton Framingham Hotel & Conference Center, 1657 Worcester Rd, Framingham, MA.

Registration fills up fast so be sure to register early.

Click Here to Register

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!

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!

Let Our CoPs Manual Be Your Roadmap to Compliance

The Home Care Alliance of MA put together a COP Task Force consisting of an expert team of home health professionals. This task force developed guidelines to assist Home Health Agencies with the understanding on the new standards in order to stay in compliance.

Though the CoP Guide is available to Alliance members at no cost (log-in required), non-members may purchase an electronic version on our website. Upon purchase, you will receive an email with a link to download the PDF.

Return to www.thinkhomecare.org.

Talking Home Care Episode 4: NAHC’s Bill Dombi on HHGM and Federal Home Health Policy

Pat Kelleher talks with NAHC’s Bill Dombi about PDGM, reduced CMS spending, and more.

Bill Dombi
Bill Dombi, Interim President of NAHC

For the fourth episode of the Talking Home Care podcast, Pat Kelleher talks with Bill Dombi, interim president of the National Association for Home Care & Hospice (NAHC). Topics include:

  • Background on the the Home Health Grouper Model (HHGM) and an update on its status;
  • Discussion of the $950M/year reduction in overall home health spending, as estimated by CMS (and estimated to be much, much higher by NAHC);
  • An update on NAHC’s lobbying efforts, specifically its support of a letter sponsored by Senators Nelson and Rubio to oppose the new model;
  • How we need agencies to contact their representatives immediately (by the end of the Monday, September 25);
  • How cuts may affect the home health workforce; and
  • Holding the Trump Administration to its promise to reduce paperwork administrative overhead.

You may listen to the podcast by clicking the play button above, downloading it directly, or subscribing through iTunes or Google Play. (Length: 29’00”; Size: 14 MB).

Links/Action:

Talking Home Care LogoHost: Patricia Kelleher is the Executive Director of the Home Care Alliance of Massachusetts.

Guest: William Dombi was appointed as NAHC’s interim president this past August, and served as its vice president for law since 1987. He is also director of the Center for Health Care Law, a nonprofit, public interest law firm established by NAHC, and executive director of the Home Care and Hospice Financial Managers Association. Additionally, he is a member of the advisory board of Bloomberg BNA’s Medicare Report.


Don’t want to miss the next episode of Talking Home Care? Subscribe through iTunes, Google Play, or enter the following in your podcast app: https://thinkhomecare.wordpress.com/category/talking-home-care-podcast/feed/

Return to www.thinkhomecare.org.