Tag: Medicare

Timeline Updated for Dual-Eligible Care Demonstration

MassHealth and CMS have agreed to a new implementation timeline for the statewide demonstration to better integrate and coordinate health care services for dually eligible individuals between the ages of 21 and 64.

Obviously, the deadline for selectionselection of ICO’s, or Integrated Care Organizations, has come and gone, but the “readiness review” for those ICO’s has been extended. Previously, the demo was set to begin enrollment on April 1st, but it now appears that the state and CMS have agreed to have the first self-selected enrollments to become effective on July 1st.

See the updated timeline below and visit the state’s demonstration webpage for more info:

ICO Selection Announcement

November 2, 2012
Readiness Review

Nov. 2012 – March/April 2013
3-Way Contracts

March/April 2013
Learning Collaboratives

March 2013 – Ongoing
Implementation Activities

 
       Stakeholder Workgroups: Quality, Notices, Outreach, Admin. Simplification

Dec. 2012 – Ongoing
     Implementation Council

Feb. 2012 – Ongoing
     Ombudsperson

May 2013 – Ongoing
Public Awareness Campaign

April 2013 – Ongoing
Member Outreach Activities

(Members can begin to select ICOs for effective date July 1, 2013)

May 2013 – Ongoing
Self-Selected Enrollments Begin

July 1, 2013
Auto-assignments Effective

(Members notified at least 60 days prior to the effective date)

Oct. 1, 2013; Jan. 1, 2014

Planned Revisions to Home Health Beneficiary Notice-Open for Public Comment

Presently home health agencies (HHAs) are required to use the Home Health Advance Beneficiary Notice (HHABN), CMS-R-296 to provide beneficiaries with change of care notification consistent with HHA Conditions of Participation (COPs) in addition to its liability notice function. Option Box 1 addresses liability, Option Box 2 addresses change of care for agency reasons, and Option Box 3 addresses change of care due to provider orders.

In CMS’ effort to “streamline, reduce, and simplify notices to Medicare beneficiaries,” HHABN Option Box 1, the liability notice portion, will be replaced by the existing Advanced Beneficiary Notice of Noncoverage (ABN) which is approved by Office of Management and Budget (OMB) for conveying information on beneficiary liability. CMS will introduce the “Home Health Change of Care Notice” (HHCCN) as a separate, distinct document to give change of care notice in compliance with HHA conditions of participation. The HHCCN will replace both Option Box 2 and Option Box 3 formats of the HHABN. The single page format of the HHCCN is designed to specify whether the change of care is due to agency reasons or provider orders. Form Number: CMS–10280 (OCN: 0938–New) To obtain copies of the supporting statement and any related forms for the proposed paperwork collections referenced above, go to CMS’ Web Site address at http://www.cms.hhs.gov/, or Email your request, including your address, phone number, OMB number, and CMS document identifier, to Paperwork@cms.hhs.gov, or call the Reports Clearance Office on (410) 786-1326.

The full notice and details for submitting public comments on the proposed changes can be accessed in the Federal Register.  Comments are due by February 11, 2013

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CMS Updates Policy Requirements for Medical Record Corrections

CMS released Transmittal 442, Change Request (CR) 8105 on December 7th. It provides instructions to Medicare contractors regarding amended, corrected, and delayed entries in medical records. This updates the CMS Medicare Program Integrity Manual, Section 3.3.2.5 effective January 8, 2013.

According to this Change Request, the MACs, CERT, Recovery Auditors, and ZPICs are instructed NOT to consider entries that don’t comply with recordkeeping principles, even if exclusion of an entry will result in a claim denial.

In the manual update, “providers are encouraged to enter all relevant documents and entries into the medical record at the time they are rendering the service.” However, the policy goes on to acknowledge that there may be occasions when documentation was not completed or completed properly and may need to be amended. Medicare contractors are told that they are to consider all submitted entries that comply with the widely accepted Recordkeeping Principles, but NOT consider any entries that do not comply with the principles.

Recordkeeping principles for record amendments apply to both paper and electronic medical records. These principles include:

  • Clearly and permanently identify any amendment, correction or delayed entry as such; 
  • Clearly indicate the date and author of any amendment, correction or delayed entry; 
  • Not delete but instead clearly identify all original content.

When correcting a paper medical record, the “principles are generally accomplished by using a single line strike through so that the original content is still readable. Further, the author of the alteration must sign and date the revision. Similarly, amendments or delayed entries to paper records must be clearly signed and dated upon entry into the record.”

CMS acknowledges that although “record keeping within an EHR deserves special considerations” the same principles apply. EHR corrections or delayed entries must:

  • Distinctly identify any amendment, correction or delayed entry, and;
  • Provide a reliable means to clearly identify the original content, the modified content, and the date and authorship of each modification of the record.

The manual update also states “If the MACs, CERT or Recovery Auditors identify medical documentation with potentially fraudulent entries, the reviewers shall refer the cases to the ZPIC and may consider referring to the RO and State Agency”.

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Therapy Questions and Answers – Revised December 2012

On December 14th CMS released revised Therapy Q&As that reflect the changes for the therapy reassessment requirement from the Final Rule 2013. The provisions in this final rule are effective for episodes ending on or after January 1, 2013, unless otherwise specified in the final rule. For episodes that begin in CY 2012 and end in CY 2013, the therapy provisions of this final rule do not apply. The therapy provisions of this final rule are applicable to episodes that begin on or after January 1, 2013.

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CMS Releases New MLN Article

On November 26th, CMS released the Medicare Learning Network  Article- (SE1237) Importance of Preparing/Maintaining Legible Medical Records. This article highlights the importance of legible documentation in avoiding claim denials. The key points highlighted:

  1. General Principles of Medical Record Documentation
  2. Medicare Signature requirements
  3. Amendments, Corrections and Delayed Entries

If you are looking for more facts on amendments, corrections and delayed entries see the Medicare Program Integrity Manual Section 3.3.2.5. The MLN article, Complying with Medicare Signature Requirements, provides a question and answer format for information on signature regulations

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Hospice WebEx Training on Data Submission — Taken Offline

CMS put out notification last week that the WebEx training related to the Hospice Quality Reporting Program (HQRP) was available online.  It was available for a BRIEF time on Wednesday night and Thursday; the WebEx training is temporarily unavailable due to technical issues.  Only the Technical User Guide is available on the website. The contractor is working to correct the issues and will get the training and manual back up as quickly as possible.  The HCA will keep you updated.

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Hospice Quality Reporting WebEx Now Available

Looking for more information about the new requirements for Hospice Quality Reporting?

The CMS WebEx training module on data submission for the Hospice Quality Reporting Program is now available online.  It will remain available until April 2013. The training will help hospices prepare for web-based data entry and submission of quality data affecting the FY 2014 reimbursement rates.

To meet the hospice quality reporting requirements in order to qualify for full payment of Medicare rates in FY 2014, hospices must submit two measures: the Structural/QAPI measure and the NQF #0209 measure. Reporting of the structural measure may begin Jan. 1, 2013, and must be completed by Jan. 31, 2013, while reporting of data on the pain measure (NQF 0209) must be completed by April 1, 2013.

For more information visit Spotlight and Announcements on the Hospice Quality Reporting website.

State Reveals ICOs in Dual Eligible Care Demonstration

More than a month passed their anticipated announcement date of September 21st, the state’s Executive Office of Health and Human Services (EOHHS) named the Integrated Care Organizations, or ICO’s, that will be managing and directing both payment and care for the demonstration to integrate services for dual eligibles.

The six organizations are Blue Cross and Blue Shield of Massachusetts HMO Blue Inc. (BCBSMA), Boston Medical Center HealthNet Plan (BMCHP), Commonwealth Care Alliance (CCA), Fallon Total Care, LLC (FTC), Neighborhood Health Plan (NHP), Network Health, LLC. Only Network Health was picked to serve every county in the state and will be the only ICO in Nantucket and Martha’s Vineyard.

Aside from Network Health, all other ICO’s are listed in as few as three counties and as many as eleven.

These organizations were selected for full (F) or partial (P) Massachusetts counties as follows:

BCBSMA BMCHP CCA FTC NHP Network Health
Barnstable F F F F
Berkshire F F
Bristol F F F F
Dukes F
Essex F F F F F
Franklin F F F F
Hampden F F F F F
Hampshire F F F F F
Middlesex F F F F F F
Nantucket F
Norfolk F F F F F
Plymouth F F P F F
Suffolk F F F F F F
Worcester F F F F

These organizations will now be engaged in a “readiness review” over the next two months. As part of the review, EOHHS and CMS will require that the organizations demonstrate full readiness and meet operational requirements.  An ICO will not be able to accept enrollments without successfully completing the joint Readiness Review, negotiating and executing a three-way contract, and receiving any necessary state and federal approvals.

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Medicare Home Health Final Rule Issued

The Centers of Medicare and Medicaid (CMS) issued the Home Health Final Rule on Friday, November 2nd.  The Rule updates the HH PPS rates, including the national standardized 60-day episode rates, the national per-visit rates, the low-utilization payment amount (LUPA), the non-routine medical supplies conversion factor, and outlier payments. These rates will be effective January 1, 2013. This Rule also establishes requirements for the Home Health and Hospice quality reporting programs, important policy changes on CoP Non-compliance Sanctions, and improvements on Face to Face Encounter and Therapy Assessment Rules.

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NHIC Ask the Contractor Nov. 15

NHIC Corp., the regional Medicare Administrative Contractor, will host a Hospice & Home Health Ask the Contractor Teleconference (ACT) on November 15, 2012, at 10:00 a.m.  This Ask-the-Contractor Teleconference is an opportunity to speak directly with the contractor.  NHIC staff representing a variety of functions will be available to answer questions. NHIC usually will provide some updates to the home health and hospice community but the majority of this call is dedicated to providers as a question and answer open forum.

Registration is required on NHIC’s Education Programs webpage

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