Tag: Medicare

CMS Announces Proposed Home Health PPS Update for 2016; Massachusetts Included in Value-Based Pilot

Massachusetts is one of nine states randomly assigned to pilot the Home Health Value-Based Purchasing (VBP) model, which is included in the calendar year 2016 Medicare Home Health PPS Rule released by CMS.

VBP will test whether incentives for better care can improve outcomes in the delivery of home health services.  The model will apply a payment reduction or increase to current Medicare-certified home health agency payments, depending on quality performance, for ALL agencies delivering services within the nine selected states.  Payment adjustments will be applied on an annual basis, beginning at five percent and increasing to eight percent in later years of the initiative.

According to CMS, the model is designed so there is no selection bias, participant states are representative of home health agencies nationally, and there is sufficient participation to generate meaningful results among all Medicare-certified home health agencies nationally.

The proposed rule implements the third year of the four year phase-in of the rebasing adjustments to the HH PPS required by the Affordable Care Act.  The CY 2016 downward adjustment to the national standard episode rate is $80.95.  CMS also proposes to recalibrate the HH PPS case-mix weights for CY 2016, which would be the second year of recalibration and identical to CY 2015.

In addition, the proposed rule includes a decrease to the national, standardized 60-day episode payment amount by 1.72 percent in each of CY 2016 and CY 2017 to account for nominal case-mix coding intensity growth unrelated to changes in patient acuity between CY 2012 and CY 2014.  CMS will also be updating the HH PPS payment rates by the home health payment update percentage, 2.3 percent in CY 2016.

For the Home Health Quality Reporting Program, in keeping with the requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (the IMPACT Act), CMS is proposing one standardized cross-setting measure for CY 2016 under the skin integrity and changes to skin integrity domain.  Measures for the IMPACT Act’s other domains will be addressed through future rule-making, although CMS is seeking feedback on four future, cross-setting measure constructs to potentially meet requirements of the IMPACT Act.

In order for home health agencies to avoid a two percent reduction in their annual HH payment update percentage, the rule further proposes to require all home health agencies to submit both admission and discharge OASIS assessments for a minimum of 70 percent of all patients with episodes of care occurring during the reporting period starting July 1, 2015.  CMS proposes to incrementally increase this compliance threshold by ten percent in each of the subsequent periods (July 1, 2016 and July 1, 2017) to reach 90 percent.

CMS has prepared a fact sheet about the proposed rule and a press release about the Home Health Value-Based Purchasing model.  The proposed rule will be officially published in the Federal Register on July 10, 2015. CMS will accept comments on the proposed rule, including comments about the Home Health Value-Based Purchasing model, until September 4, 2015.

The Alliance will closely examine the Value-Based Purchasing proposal — as well as all other aspects of the proposed rule — and will present a briefing for members within the next weeks.

We will work with the state associations in the other states chosen for the pilot to advocate for any needed changes to the program to protect agency cash flow and operational integrity.  We will also develop educational sessions for our members over the next months.  Stay tuned!

Return to www.thinkhomecare.org.

Fallon Total Care Dropping Out of ‘One Care’ Program

The state’s Executive Office of Health and Human Services (EOHHS) announced that one of the three health plans managing health care for dually eligible ages 21 to 64 through the One Care Demonstration Program will be dropping out.

As of September 30, 2015, Fallon Total Care will be parting ways with the capitated financial alignment program, which will leave Commonwealth Care Alliance and Network Health as the remaining plans. Fallon Total Care provides One Care coverage in Hampden, Hampshire, and Worcester counties to approximately 5,475 individuals and represented the second largest enrollment of the three plans. Commonwealth Care Alliance, as of the May 2015 enrollment report, was handling 10,305 dually eligible individuals.

“MassHealth assures members who are currently enrolled with Fallon Total Care (FTC) that we will work hard to ensure as smooth a transition as possible, working with current members, FTC, the other One Care plans, our partners at CMS, advocates, and the One Care Implementation Council,” stated MassHealth in a brief statement. “One Care members will not lose their MassHealth or Medicare, and all members will have continuous access to health care services, supportive services, and medications.”

MassHealth also promised further updates on the transition and did not share any reasoning for Fallon Total Care departing the One Care Program.

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One Care Program Provides Update, Amends Financial Protections for Plans

The One Care initiative provided stakeholders with an update on enrollment population as well as the financial methodology governing the program and survey results illustrating enrollee opinions and satisfaction with services and the care team.

One Care, which coordinates Medicare and MassHealth services for dually eligible individuals between 21 and 64 years old, reported that the program has spent 14 percent – or $19.4million – on home and community-based services, including home health. This number reflects the life of the program thus far since it launched in October 2013. Pharmacy services represents the largest piece of the spending pie at 25 percent ($34.36 million).

The program has also conducted a round of enrollee surveys that found the following:

  • Over 80% of enrollees had met with their PCP; most are satisfied with the PCP
  • Over 70% had met with their Care Coordinator; 90% are satisfied
  • There was confusion about the role of the LTS Coordinator
  • When asked if they needed/wanted LTS Coordinator, many said no, or not sure;
  • Only 39% said they needed/wanted an LTS Coordinator;
  • Less than 45% had met with an LTS Coordinator

One Care administrators worked with CMS to update the financial methodology that was intended to protect the three plans (Commonwealth Care Alliance, Fallon Total Care, Network Health) and that info, along with the broader report to stakeholders, is available in a PowerPoint presentation.

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Special Open Door Forum on F2F Template; Alliance Seeks F2F Data

CMS hosted a Special Open Door Forum call yesterday to provide an opportunity for physicians/practitioners, home health agencies and/or all other interested parties to provide feedback on both a paper clinical template and an electronic clinical template for face to face documentation.

Many questions were raised and often the presenters were unable to answer the audience’s questions; the presenters stated they would provide answers during at the April call. The PowerPoint presentation (see slide 5) raised many more questions on which physicians could actually certify homecare; the hospitalist or the community physician. Again the presenters were unable to clarify the regulation for the audience. The presenters were actually debating among themselves whether a discharge planner or physician’s staff could assist completing the documentation for the face to face. A caller confirmed that this was acceptable and CMS had already addressed this issue in the CMS Face to Face Questions, question number 8.

CMS is seeking public comment on this voluntary paper clinical template. Feedback and questions can be sent to: HomeHealthTemplate@cms.hhs.gov.

Additional Special Open Door Forum calls on the templates will be held on April 8 and May 6, 2015, both at 1:00 PM Eastern Time.

In the Alliance’s continued advocacy on the Physician Face-to-Face Requirement, agencies that have ongoing appeals of claims denied for “invalid” F2F documentation are encouraged to send the number of denials, amount of money tied up in those claims, and the status of the appeals to James Fuccione at HCA.

We will share these data by congressional district with the Massachusetts federal delegation so that they can follow up with CMS. Months after a letter was sent from US Senators from the New England region on the same subject, CMS has failed to respond and the Alliance wants to make sure this issue gets the attention it deserves.

Please send this information, along with any questions, to James Fuccione at the Alliance.

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Industry Newsletter Publishes HCA-Issued Notices on Face-to-Face Rule

Home Health Line, a widely-distributed industry newsletter, has published notices to hospitals and physicians on Face-to-Face Requirement changes created by the Home Care Alliance of MA as a resource for home health agencies across the country.

The notices on the rule changes as of January 1, 2015 were distributed in a previous blog post and were created by HCA staff to help educate partners in the hospital and physician community about their responsibilities to ensure Medicare beneficiaries receive the necessary home health services.

The notices are also posted below and Home Health Line notes in a disclaimer that “The Home Care Alliance of Massachusetts created such a note to clear up confusion about face-to-face requirements, although it believes agencies and physicians still need more guidance from CMS.”

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Federal Lawsuit on Face-to-Face Rule Moving Forward

In a major win for home health agencies across the country, a federal district court determined that they will hear a legal challenge presented by the National Association for Home Care & Hospice (NAHC) to the validity of the physician narrative portion of the face-to-face requirement.

According to NAHC, the court issued an order denying Medicare’s effort to have the lawsuit dismissed by the court. The face-to-face requirement (F2F) was troublesome and frustrating from the outset as CMS released no standardized form for providers to follow and provider education was insufficient at best. It took constant advocacy and education on the state and local levels and strong lobbying on the federal level from state and national home care associations and agencies to even call attention to the problem.

The physician narrative where physicians must write a detailed account of patient eligibility for home health care services proved to be the paramount concern. Although the new final rule effective 1/1/2015 removes the narrative piece of the requirement, NAHC will continue to litigate the dispute to address the past claim denials and those denials that may still come involving home health services provided prior to January 1, 2015. If the lawsuit is successful, Medicare would be required to reopen and pay any claim previously denied for an insufficient narrative and stop any further claim reviews related to the narrative requirement.

NAHC and the Home Care Alliance continue to advise home health agencies to consider appealing any narrative-related claim denials while the lawsuit is progressing. Such action will preserve the opportunity to have the claims reviewed by Administrative Law Judges and also allow for easy identification of claims that may be subject to reopening if the lawsuit is successful.

The Alliance will also continue to provide education and updates on the new rule, including an upcoming webinar in early February. The Alliance helped lead the effort on a letter from New England Senators to CMS on F2F reviews and is out front with notices to physicians and hospitals on the recent rule changes.

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F2F Rule Change Guides Released by HCA

With misinformation and uncertainty swirling around the new Physician Face-to-Face Requirements (F2F), the Home Care Alliance has released notices for hospitals and physicians as a guide for both home health agencies and their partners to utilize in understanding the impending changes.

As reported in HCA newsletters and alerts, CMS hosted its first (and only) educational forum on the new changes to the Face-to-Face physician encounter requirement for Medicare home health coverage on December 16. Given the lateness of the guidance, the effective date of January 1, 2015, and the many still unanswered questions, the Home Care Alliance of MA, the National Association for Home Care and Hospice, and others have asked CMS to phase-in enforcement of the requirements to allow time for home health agencies, physicians and hospitals to be educated about the new rules. CMS has not yet responded to that request.

In an effort to counter some misinformation circulating that the F2F requirement has been repealed, the Alliance has released the notices for agencies to use with their individual partners in the provider community. The Alliance is also working with the MA Medical Society and the MA Hospital Association on efforts to educate physicians and hospitals about the changes. We have encouraged MMS and MHA to inform hospitals and doctors that:

•    the F2F encounter requirement is still in place for Medicare patients in need of home health services.
•    the F2F encounter still MUST be documented, signed and dated by an MD, along with the documentation of the patient’s need for skilled care, homebound status and plan of care.
•    home health agencies will work with our hospital and physician partners to understand the requirements once CMS clarifies the rule and begins educational sessions for all providers.
Clearly, there are still issues that need to be clarified around the hospitalist as the certifying physician.

HCA will continue to push for more guidance from CMS on this, as well as more physician and hospital education from CMS.

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New England’s Senators Urge Action on ‘Face-to-Face’ Concerns

US Senators representing the New England states have stepped in to send a letter to CMS regarding the onerous medical review process relative to the Physician Face-to-Face Requirement being undertaken by National Government Services (NGS), which is the Medicare Administrative Contractor (MAC) for the region.

The state home care associations in the region, including the Home Care Alliance, worked together to draft the letter, gather data, and mobilize agencies to ask that Senators sign on to the letter.

The letter to CMS Administrator Marilyn Tavenner convey that the reviews and unjustified claim denials could “jeopardize seniors’ access to home health care” and that any measures meant to attack fraud and abuse should be clear, consistent and not threaten a beneficiary’s ability to receive needed care. The letter also highlights that, in some cases during 2014, withheld and denied reimbursements have exceeded the cost of a two-week payroll for some agencies.

While acknowledging the CMS final rule that changes the Face-to-Face Rule’s narrative requirement, the letter urges the following:

  • Explain what additional steps CMS will take to better ensure the clarity of the F2F regulations to prevent any further inconsistent denial of claims across the country;
  • Describe how you will ensure that patient care will not be compromised while the appeals of F2F denials are being considered;
  • Provide us with a current list of the outcomes of Medicare home health F2F denials and appeals across the country; and
  • Consider the feasibility of working with home health agencies to reopen or settle claims related to F2F in a manner that is equally fair to both taxpayers and home health providers.  Such considerations could include analysis as to whether an agreement similar to the administrative agreement process recently offered by CMS to hospitals that have a high volume of backlogged claim denials would be appropriate for backlogged home health claims related to F2F.

Nine of the twelve US Senators representing the New England region signed on, including both Massachusetts Senators Elizabeth Warren and Ed Markey. The Alliance thanks them for their continuing support of home health care issues and particularly efforts to improve the Physician Face-to-Face Requirement.

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One Care Initiative Hosting Webinar on Independent LTS Coordinators

The One Care demonstration project that coordinates and combines services for dually eligible individuals in Massachusetts hosts periodic webinars to educate the One Care Plans as well as service providers to help the program be successful.

The latest in that series is a free webinar on the role of the Long Term Services and Supports Coordinator, which will take place on Thursday, September 18th from noon to 1:00pm. During this webinar, the One Care Learning Team will discuss making referrals to Independent Living and Long-Term Services (LTS) and Supports Coordinators, ways to explain this role to One Care enrollees, and the benefits of engaging LTS Coordinators on Interdisciplinary Care Teams. An overview of the vision of MassHealth for the role of LTS Coordinator will be outlined and highlighted with examples of how LTS Coordinators are working with enrollees and interdisciplinary care teams.

Check out this video for an overview of the Independent Living LTSS Coordinator role and meet two of the webinar presenters.

Previous webinars have been recorded and can be viewed here.

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CMS Establishing Star Rating System for Home Health Care

In an effort to be consistent with quality reporting measures for various health care providers, the Centers for Medicare and Medicaid Services (CMS) are reportedly beginning to bring home health care, hospitals and dialysis facilities into the five-star rating system used for other sectors.

Already, nursing homes, Medicare health plans with Part B coverage, Medicare Advantage plans, physician group practices, and accountable care organizations use the star rating system. According to Visiting Nurse Associations of America (VNAA), CMS hopes to transition home health care to the five star rating by the end of 2014, or at latest, the beginning of 2015. However, the Home Health Quality Improvement Campaign (HHQI) reports that hospitals will be the next provider group to get the star rating system and home health will come online in 2016.

Nursing homes are rated on staffing, health inspections and a set of 9 quality measures on the Nursing Home Compare website. Home health agencies and other providers each have their own range of quality criteria. Currently, there are no details on how CMS plans to determine the star ratings for home health agencies.

More information on this topic will be reported as it becomes available.

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