Tag: Medicare

Home Care Alliance, National Organizations Make Statements on Supreme Court Decision

In light of the Supreme Court’s decision to uphold the Affordable Care Act, the Home Care Alliance of Massachusetts and other organizations representing health care providers and consumers had this to say:

“Today’s decision of the US Supreme Court has established the Affordable Care Act as the law. With their ruling, the Supreme Court has removed enormous uncertainty – particularly in states other than Massachusetts and for those involved in ACA funded demonstrations – as to whether to move forward. They now can, and we think they must.  While some parts of the law will impact Massachusetts far less directly than other states, there is evidence that our state has already benefited by some provisions. Most notably, 62,000 seniors and people with disabilities in Massachusetts have seen significant savings on their prescription drugs because the law was upheld.

All providers, including home health care, were subject to Medicare rate reductions in the ACA in order to expand coverage and pay for reform demonstrations.  These cuts have not been easy to absorb. With this ruling, we must now get to work to deliver on the promise in our state not just of universal access to insurance, but to a better coordinated, and ultimately more cost effective delivery system.”

-Patricia Kelleher, HCA Executive Director

Statement from the National Association for Home Care & Hospice (NAHC):

“NAHC has long supported reforms that increase access to health care for all in the United States and supports health delivery reforms and the expansion of Medicaid eligibility. The ACA rightly shifts the focus of care from inpatient services and institutional care to the community setting, which home health agencies and hospices have effectively served for decades.

NAHC believes that the Affordable Care Act can and should be improved. Accordingly, NAHC will continue to work with both Democrats and Republicans to improve the legislation. NAHC will ask that its implementation date be delayed for two years so that states have the time to prepare for implementation, including the creation of exchanges. This delay will also save approximately $200 billion, which can be applied to deficit reduction, extending the SGR “doc fix” and avoiding the need for any further cuts to Medicare. NAHC will continue to argue that home health care has been cut disproportionately and will oppose the imposition of copayments or additional cuts. NAHC believes that a good case can be made for expanding the scope of Medicare home health services to reduce hospitalization costs and improve services for the 5 percent of Americans who are responsible for 50 percent of total U.S. health care costs.”

-Val Halamandaris, NAHC President

Here are other statements from the following organizations:

And statements from political leaders:

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CMS’ Hospice Quality Reporting Data Training Webinars Available

Video files and Q&A from the CMS Hospice Quality Reporting Data Collection Training webinars conducted in April are now available. There are two zip files located under Related Links on the Hospice Quality Reporting Spotlight Section webpage. One zip file contains four versions of the structural measure training videos and the other zip file contains four versions of the NQF #0209 measure training videos. There are four versions of each section of the training so hospices may choose to view either captioned or uncaptioned versions using either MP4 or Windows Media Video. The Q&A are located in the Downloads section on the same page.

CMS Releases Updated Information about PECOS

Are your ordering/referring  physicians enrolled in PECOS?

On June 20th CMS released a revised MLN Matters article with updated information regarding PECOS and Phase 2 of the Ordering/Referring Physician Requirements.

During Phase 2, Medicare will deny Part A HHA claims that fail the ordering/referring provider edits. CMS has not announced a date when the edits for Phase 2 will become active. CMS will give the provider community at least 60 days notice prior to turning on these edits. Physicians and others who are eligible to order and refer items or services need to establish their Medicare enrollment record (PECOS).

It is possible that it could take 45-60 days, sometimes longer, for Medicare enrollment contractors to process enrollment applications. All enrollment applications, including those submitted over the web, require verification of the information reported. Sometimes, Medicare enrollment contractors may request additional information in order to process the enrollment application.

Waiting too late to begin this process could mean that physicians’ enrollment applications will not be able to be processed prior to the implementation date of Phase 2 of the ordering/referring provider edits. In Phase 2, if the Ordering/Referring Provider does not pass the edits, the claim will be denied.This means that the billing provider will not be paid for the items or services that were furnished based on the order or referral. For more information Click Here

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New Code to Report Date of Death on Medicare Claims

October is months away but be prepared…Effective Oct.1, 2012 Medicare-certified agencies will use occurrence code 55 to indicate a date of death on claims.

The new occurrence code will be used in conjunction with all discharge status codes indicating the patient has expired – 20 (expired), 40 (expired at home), 41 (expired in a medical facility), or 42 (expired – place unknown)

Please note that hospices are not to use discharge status code 20 per Section 30.3 of Chapter 11 of the Medicare Claims Processing Manual. Additional information on the use of code 55 can be found in the MLN Matters and in the Change Request (CR) 7792

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Dual Eligible Services Demo RFR Now Available

The state’s Executive Office of Health and Human Services (EOHHS) has released the Request for Responses relative to the demonstration project to integrate care for dually eligible individuals.

The RFR is a solicitation for potential Integrated Care Organizations, or ICO’s, that will manage the integration of services and payment for dual eligibles aged 21-64. The Home Care Alliance is holding a special event for all agencies interested in this initiative. Please see the event in our Calendar section titled “Building Partnerships with Managed Care Plans for Dual Eligible Care” where special guest speakers will educate attendees on the demonstration and how agencies can play a key role. Potential ICO’s have also been invited for discussion and networking.

For those interested in viewing the  solicitation and corresponding materials, the instructions are below:

1)  In your browser, enter the URL for the Commonwealth’s procurement web page: www.comm-pass.com.

2)  Near the bottom of the page, click on the hyperlink that reads: “Search for Solicitations.”

3)  When the Search page comes up, scroll down to the section that says “Search by Specific Criteria” and in the document number box, enter the following: 12CBEHSDUALSICORFR.

4)  The Search result will appear as a hyperlink at the top of the new page. It should read: “There is 1 solicitation(s) found that match your search criteria.”  Click on this sentence and it will take you to the Comm-PASS listing for this solicitation.

5)  Click on “view” (the eyeglasses on the right) and you will get the summary page for the Request for Responses for Integrated Care Organizations.

6)   Click on the blue folder-type tab called “Specifications” and you will see the RFR documents and appendices that have been posted for this topic. In addition, the required forms that Respondents to the RFR will need to provide are available under the “Forms and Terms” tab.  To view the documents, click on the eyeglasses to the right of the title of each document,  .

The documents will also be posted shortly on our duals demonstration website, www.mass.gov/masshealth/duals, under “Information for Organizations Interested in Serving as ICOs.”

Responses to the RFR will be due to MassHealth by 4:00 PM (EDT), July 30, 2012.

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Guest Post: Fraud and Abuse Tied to MD Face-to-Face Encounters

The following is a guest blog post on fraud and abuse issues by Robert W. Markette, Jr., CHC, Of Counsel for
Benesch Friedlander Coplan & Aronoff LLP. Mr. Markette’s primary areas of practice are health law and litigation and his wide range of health care clients includes home health, hospice and private duty providers.

Mr. Markette is also responsible for assisting the Home Care Alliance with its “Keeping it Legal in Home Care” resources on patient choice.

To view the entire article, click the link after the introduction:

As home health and hospice care continue to become more and more competitive and reimbursement continues to decline, referral sources are discovering new ways to leverage this for their own benefit. Two new examples include physicians requesting “administrative fees” to complete face to face paperwork and referral sources seeking “donations” from providers to defray the cost of capital equipment and other improvements. Providers need to understand the risks in these arrangements in order to avoid entering into arrangements that place them in violation of the Anti-Kickback Statute and/or the Stark Law.

The entire article from Mr. Markette is available here.

 

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Avoid Denied Claims-Follow Medicare’s Provider Enrollment Guidelines.

As reported in the HCA’s Update last week, CMS published in the Federal Register  “Medicare and Medicaid Programs: Changes in Provider and Supplier Enrollment, Ordering and Referring, and Documentation Requirements; and Changes in Provider Agreement.”

This final rule finalizes several provisions of the Affordable Care Act implemented in the May 5, 2010 interim final rule with comment period. It requires all providers of medical or other items or services and suppliers that qualify for a National Provider Identifier (NPI) to include their NPI on all applications to enroll in the Medicare and Medicaid programs and on all claims for payment submitted under the Medicare and Medicaid programs. In addition, it requires physicians and other professionals who are permitted to order and certify covered items and services for Medicare beneficiaries to be enrolled in Medicare.

To receive payment for home health services, any Medicare-enrolled Home Health Agency must file claims containing the name and National Provider Identifier (NPI) of the physician who ordered the service.

The ordering physician must be enrolled in PECOS. The NPI used must be for an individual physician (cannot be a group or organizational NPI) and the individual physician must be of a specialist type that is eligible to order; Doctors of Medicine or Osteopathy, Doctors of Podiatric Medicine

Failure to meet the requirements mentioned above will result in denied claims once the automatic edits are activated.  The Medicare Learning Network’s “Medicare Enrollment Guidelines for Ordering/Referring Providers” is an excellent fact sheet if you need more information

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Challenged with Teaching New Staff OASIS

When home care agencies hire clinicians with little to no home care experience it certainly is a challenge to orient new staff to all the home care policies, procedures, regulations and OASIS. A tremendous amount of time and resources are needed for the opportunity to education the clinician. CMS created four training videos that are related to OASIS-C and process measure items. These videos may be a good resource for home care orientation.

They are available on YouTube as follows:

The Process Based Quality Improvement (PBQI) process.

Accurately Responding to Process Items: Intervention Synopsis (M2400)

Accurately Responding to Process Items: Plan of Care Synopsis (M2250)

Accurately Responding to Process Items: Fall Risk Assessment (M1910)

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Keeping It Legal, Part 2: Patient Choice

Building on a previous document called “Keeping It Legal” that focuses on what providers need to know when referring patients to home health care, the Home Care Alliance is releasing a series of documents on other legal issues related to the industry.

This new document in the series focuses on “Patient Choice” and what rights a patient has under the Medicare and Medicaid programs.

See the article: Respecting Patient Choice and the Rights of Medicare Patients

Drafted by Robert Markette, Jr., CHC – Of Counsel for Benesch Friedlander Coplan & Aronoff LLP, the Home Care Alliance is pleased to make this series of resource documents available. Agencies are encouraged to pass these documents along to partnering providers and pertinent agency staff to ensure that they are aware of the rules and regulations.

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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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