Tag: Medicare

Care Transitions Program Part of Partnership for Patients

Centers for Medicare and Medicaid Services Administrator Dr. Don Berwick and US Health and Human Services Secretary Kathleen Sebelius announced a massive initiative and federal funding opportunity dubbed the “Partnership for Patients.”

This billion dollar commitment from the federal government will be split between two goals:

  • Keep patients from getting injured or sicker. By the end of 2013, preventable hospital-acquired conditions would decrease by 40% compared to 2010.
  • Help patients heal without complication. By the end of 2013, preventable complications during a transition from one care setting to another would be decreased so that all hospital readmissions would be reduced by 20% compared to 2010.

Home health agencies will be most interested in the Community-Based Care Transitions Program, which will spread $500 million in funding to community-based organizations partnering with eligible hospitals for care transition services that include timely, culturally, and linguistically-competent post-discharge education, medication review and management, and patient-centered self-management support within 24 hours of discharge.

Recently, the solicitation and application have been released after months of waiting and the Home Care Alliance is continuing to encourage eligible agencies that qualify as Community-Based Organizations (CBO’s) to partner with hospitals, ASAP’s, and other providers to submit an application.

Here is the list of pertinent documents for this program:

Agencies that have any questions regarding this program can contact the Home Care Alliance.

Return to www.thinkhomecare.org.

The Case Against a Medicare Home Health Copayment

At our recent meeting with representatives from our state’s  Congressional delegation, Rey Spadoni, President/CEO of the VNA of Boston made some important remarks on the perils presented to home care patients should the MEDPAC proposal – presented to Congress in March –  for a per episode copayment to be enacted on home health services.  Calling copayments “short-sighted” and “ineffective,  Rey has this to say about the reaction from his staff in the field:

When our nurses, who care for patients in the poorest neighborhoods of Boston, hear about this suggestion… they roll their eyes and tell us that most… most… of their patients will not pay them. They will prioritize paying for their prescriptions, their rent and food before they will pay for home care services. For most of our patients, age 80 and above, they are already spending 30% of their limited incomes on uncovered medical care.

The battle to stop a home care copayment  has been successfully fought by this industry before. But this year, it feels a little different. MEDPAC’s copayment call has been embraced by the Congressional Budget Office; and with talk of major Medicare reform on at least the Tea Party’s agenda, copayments in the name of more “personal responsibility” for health care purchasing may have a new and receptive audience.

Although the President resisted the recommendation in his budget proposal, it is clear that this possible wave of change will need “all hands on deck” to stop.

Return to www.thinkhomecare.org.

CMS Clarifies use of HHABN for Face-to-Face Requirement

On the CMS Home Health, Hospice & DME Open Door Forum held today, March 2nd.,  staff from CMS discussed the use of the HHABN when discharging a patient because there was no F2F encounter within the required time frame.  This is a clarification of an earlier policy which said that the HHABN was not to be used in this situation.

Option BOX 2 can be used because the agency is ending services for administrative reasons such as lack of a F2F encounter.  It is a change of care notice only and there is no beneficiary liability for the care provided. Further written clarification from CMS will be forthcoming.

Physician Face to Face Encounter Update

The Home Care Alliance wrote an article in the Massachusetts Medical Society’s newsletter in an effort to further educate physicians on the CMS face-to-face encounter requirement. The article was written at the beginning of the year and published in the February edition of “Vital Signs,” the MMS newsletter, although much has happened since then.

With one month left until the April 1st enforcement deadline, the Alliance continues to provide updates as they become available. To that end, some new important Q&A’s have been posted on the CMS website, which are available here.

A few of the new Q&A’s are listed below:

Return to www.thinkhomecare.org.

Regulatory Review

Expedited Review Process:

Masspro completed a series of workshops to discuss the “expedited review process,” used by home health agencies to notify Medicare beneficiaries that their Medicare services are ending. There are two separate forms and slightly different rules depending on Medicare “fee-for-service” (Notice of Medicare provider Non-Coverage) or Medicare Advantage (Notice of Medicare non-Coverage).  These forms are to be used when all Medicare services are ending for medical reasons.  If care is ending for a technical reason such as homebound, then the beneficiary is given a HHABN.  This is a recent clarification from Quest to Masspro our local QIO.

Quest is the part of the Quality Net system that QIO’s use to communicate with CMS.  QIO’s can ask Quest questions that require clarification by CMS and then publish the answers.

Is it appropriate for the HHA to issue a Notice of Medicare Provider Non-Coverage in these types of cases, and for the QIO to review?

Answer:

It is not appropriate for HHAs to issue Notices of non-coverage for home-bound status; only when it is believed that the beneficiary no longer requires a skilled level of care

Face-to-Face:

CMS put out a transmittal a few weeks ago to define several dates that relate to the Face-to-face Requirement.

The effective date is January 1, 2011

The implementation date that CMS contractors must have their systems ready is March 10, 2011

The enforcement date is April 1, 2011. After this date, agencies will not be reimbursed if the F2F documentation is not present in the medical record.

Return to www.thinkhomecare.org.

More Face To Face Clarifications Issued

The following was issued by NAHC Regulatory Affairs

CMS issued an update to the Medicare Benefit Policy Manual, Pub 100-02 Chapter 7 via a Transmittal issued this afternoon at: http://www.cms.gov/transmittals/downloads/R139BP.pdf. Summarized below are new pieces of information (including exception in case of death of patient) and clarifications found in the Transmittal.

General Issues

  • The certifying physician must document that he or she or an allowed non-physician practitioner (NPP) had a face-to-face encounter with the patient.
  • Certain NPPs may perform the face-to-face encounter and inform the certifying physician regarding the clinical findings exhibited by the patient during the encounter. However, the certifying physician must document the encounter and sign the certification.
  • The documentation must include the date when the physician or allowed NPP saw the patient, and a brief narrative composed by the certifying physician who describes how the patient’s clinical condition as seen during that encounter supports the patient’s homebound status and need for skilled services on the certification or an addendum to the certification.
  • It is acceptable for the certifying physician to dictate the documentation content to one of the physician’s support personnel to type.
  • It is also acceptable for the documentation to be generated from a physician’s electronic health record.
  • It is unacceptable for the physician to verbally communicate the encounter to the HHA, where the HHA would then document the encounter as part of the certification for the physician to sign.

Exceptional Circumstances in Case of Death:

  • · When a home health patient dies shortly after admission, before the face-to-face encounter occurs, if the contractor determines a good faith effort existed on the part of the HHA to facilitate/coordinate the encounter and if all other certification requirements are met, the certification is deemed to be complete.

Hospitalist Role

  • A physician who attended to the patient in an acute or post-acute setting, but does not follow the patient in the community (such as a hospitalist) may certify the need for home health care based on his/her contact with the patient, and establish and sign the plan of care. The acute/post-acute physician would then transfer/hand off the patient’s care to a designated community-based physician who assumes care for the patient.
  • Or, A physician who attended to the patient in an acute or post-acute setting may certify the need for home health care based on his/her contact with the patient, initiate the orders for home health services, and transfer the patient to a designated community-based physician to review and sign off on the plan of care.

Return to www.thinkhomecare.org.

CMS Soliciting Input on Value-Based Purchasing for HHAs

The Centers for Medicare and Medicaid Services (CMS) will be hosting an “Open Door Forum“on designing a value-based purchasing program for home health agencies. The forum is intended to solicit input from all parties interested in implementing such a program.

CMS Special Open Door Forum

Designing A Home Health Value Based Purchasing Program

Thursday, February 24th from 1:30-3:00pm (Conference call only)

Value-based purchasing (VBP) is meant to link payment more directly to the quality of care provided and is along the same lines of other payment reform efforts seeking to reward providers for delivering high quality and efficient clinical care.

Section 3006 of the Affordable Care Act requires the Secretary of Health and Human Services to develop a plan to implement a value-based purchasing program for payments to home health agencies under the Medicare program.

CMS will be seeking stakeholder input on a number of topics defined in the statute including:

  • The ongoing development, selection, and modification process for measures of quality and efficiency;
  • The reporting, collection, and validation of quality data;
  • The structure of value-based payment adjustments, including the determination of thresholds or improvements in quality, the size of such payments, and the sources of funding for the value-based bonus payments;
  • Methods for the public disclosure of information on the performance of home health agencies;
  • and any other issues.

If you wish to participate on Feb 24th, dial 1-800-837-1935 – Conference ID 37941789.

More information on this and other CMS Open Door Forums is available here.

Return to www.thinkhomecare.org.

CMS Announces New Proposed Rule on Quality of Care Complaints

The Centers for Medicare and Medicaid Services released an announcement of a new proposed rule that would include home health and hospice agencies in the expanded list of providers required to give Medicare beneficiaries written notice of their right to file a quality of care complaint.

The written notice would consist of information on the beneficiary’s right to contact a Medicare Quality Improvement Organization (QIO) as well as how to contact their local QIO with quality of care concerns.

CMS will be accepting comments on this proposed rule until April 3 and links are available with more information on the rule itself and how to comment below.

 

Medicare proposes new rules for notifying beneficiaries of their right to lodge quality of care complaints

Providers Would Have to Give All Beneficiaries Written Notice of Their Rights

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule today that would require most Medicare-participating providers and suppliers to give Medicare beneficiaries written notice about their right to contact a Medicare Quality Improvement Organization (QIO) with concerns about the quality of care they receive under the Medicare program.

Under current rules, only beneficiaries admitted to hospitals as inpatients are required to receive information about contacting their state QIO regarding quality of care issues. Today’s proposed rule would require that in order to participate in the Medicare program, providers and suppliers would need to inform beneficiaries of their right to complain to a QIO about quality of care, as well as how to contact their local QIO. In all, the following care settings are impacted by this proposal:

  • Clinics, rehabilitation agencies, and public health agencies that provide outpatient physical therapy and speech-language-pathology services
  • Comprehensive outpatient rehabilitation facilities
  • Critical access hospitals
  • Home health agencies
  • Hospices
  • Hospitals
  • Long-term care facilities
  • Ambulatory Surgical Centers
  • Portable x-ray services
  • Rural health clinics and Federally Qualified Health Centers

“Today’s proposed rule would ensure that beneficiaries know they have a voice in the care they receive under the Medicare program,” said CMS Administrator Donald Berwick, M.D. “By requiring providers and suppliers to furnish QIO contact information to all beneficiaries, we are protecting beneficiaries’ rights to bring their worries about quality of care to a third party for review, which can lead to better care not only for the beneficiary, but for all patients in a given care setting.”

Since the 1970s, Medicare has contracted with private, mostly not-for-profit organizations such as QIOs to preserve beneficiaries’ access to high-quality, high-value healthcare.  QIOs are located in every state as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Each QIO is staffed by professionals, mostly doctors and other healthcare professionals, who are trained to review medical care and help beneficiaries with complaints about the quality of care they receive. These professionals also work directly with providers and facilities to make improvements in quality across all care settings.

One of the key tools QIOs use to improve quality of care is responding to complaints from Medicare beneficiaries regarding the care they receive from Medicare-participating providers and suppliers.  QIOs investigate these complaints, gather facts from all parties involved, and recommend action to help providers and suppliers improve quality of care.

“Medicare beneficiary complaints are an important source of information that QIOs use to improve the quality of care for all patients,” said Dr. Berwick. “Sometimes providers themselves are unaware of problems or the reasons for these problems until a beneficiary shows the courage to ‘speak up’ and report the issue to a QIO. By speaking up, beneficiaries can help other patients escape the same poor outcomes they have experienced.”

CMS will accept comments on the proposed rule until April 3, 2011 and will respond to comments in a final rule to be issued in the coming months. . To submit comments click here: http://www.regulations.gov/#!documentDetail;D=CMS_FRDOC_0001-0641

The proposed rule has been published today (2/2/11) at the Federal Register and can be found online at http://www.gpo.gov/fdsys/pkg/FR-2011-02-02/pdf/2011-2275.pdf

For more detailed information check out the CMS Overview webpage at http://www.cms.gov/qualityimprovementorgs It has more information about the QIO Program and how it works to improve care for Medicare beneficiaries and all Americans, including contact information for each of the 53 QIOs across the country.

Beneficiaries with questions or concerns about the quality of care they receive under Medicare can learn more about their rights by calling 1-800-MEDICARE or by reading Medicare’s fact sheet, “Quality of Care Concerns,” online at http://www.medicare.gov/Publications/Pubs/pdf/11362.pdf.

Return to www.thinkhomecare.org.

CMS Posts New Q&A guidance on Face-to-Face Encounters

As of this past week, the Centers for Medicare and Medicaid Services posted new Questions and Answers regarding the physician face-to-face encounter requirement.

The CMS site with all Q&A’s on the rule, which will be enforced beginning April 1, 2011, is available here, and some of the newest questions are listed below:

Return to www.thinkhomecare.org.

Face-to-Face Encounter Sample Document for Hospitals

The Massachusetts Hospital Association has released a helpful guide they are recommending providers use in constructing documentation for the face-to-face encounter rule, which is being implemented currently and will be enforced by the Centers for Medicare and Medicaid Services beginning in April.

The guide was formed by  New Jersey’s Hospital  and Home Care Associations and the Home Care Alliance recommends this to those providers looking for extra direction.

Previous newsfeed posts related to the physician face-to-face encounter rule are available here.

Return to www.thinkhomecare.org.