Tag: Medicare

Are You Prepared for the May1st PECOS Edit?

Effective May 1st, CMS will deny home health claims where the physician on the claim does not have an enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS).

CMS released MLN Matters-SE1305, on March 1st, detailing information regarding this new “phase 2” edit.  Phase 2 is part of CMS’s implementation of Section 6450 of the Affordable Care Act, which requires physicians or other eligible professionals to be enrolled in the Medicare Program to order or refer items or services for Medicare beneficiaries, even if those physicians do not directly bill Medicare for any services.

Home Health claims will be denied with one of two reason codes, according to the March 1st MLN Matters article:

  • 37236: The statement “from” date is on or after May 1, the type of bill is “32” or “33” and the attending physician’s national provider identifier (NPI) is not present in PECOS. The claim could also be denied if the NPI is present in PECOS but the name given on the claim doesn’t match the one on the physician’s enrollment record.
  • 37237: Same as above, but this denial reason code will be assigned only when the type of bill frequency code is “7,” which indicates an adjustment, or “F-P.”

Check your referring physicians’ status in PECOS; agencies may be forced to hold billing the claim for physicians who are not enrolled.

Return to www.thinkhomecare.org.

Invitation to Comment on QIO Changes

CMS’s Center for Clinical Standards and Quality (CCSQ) is inviting providers to offer input on plans for redesigning the Quality Improvement Organization (QIO) Program. By law, the mission of the QIO Program is to improve the effectiveness, efficiency, economy, and quality of services delivered to Medicare beneficiaries. QIOs convene providers, practitioners, and patients to build and share knowledge, spread best practices, and achieve wide-scale improvements in patient care, increases in population health, and decreases in health care costs.

CMS has just released the slides from the January 24th Special Open Door Forum, Future Development of the QIO: Getting Your Feedback.  This invitation to provide comments on the future development of the QIO is an excellent opportunity for home health agencies to request the support and resources they deserve in the QIO program. Home health has been left out of the last two Scope of Work (SOW) plans, which focused on hospital and skilled nursing facilities. The 8th SOW was the last time the QIO focused on home health.

Home health agencies should write to CMS and advise them of ways that QIOs can provide home care with guidance and tools to effectively care for the millions of Medicare beneficiaries they serve, help them learn to comply with their treatment regimens, trouble shoot  potential complications, and avoid costly emergent care and institutional services, as well as expand their involvement in preventative services,

Please share your comments and ideas on the role Quality Improvement Organizations can play in home health.  Submit your comments to OCSQBox@cms.hhs.gov by Friday, February 8th at 5:00 p.m. ET

Return to www.thinkhomecare.org

NAHC Holding Virtual Lobby Day on Feb 6

The National Association for Home Care & Hospice (NAHC) is holding a virtual lobby day for its members on Wednesday, February 6 to continue the mission to keep issues important to home health on the minds of elected leaders. Virtual lobby days are essentially using phone calls and emails to advocate for important issues without traveling to the nation’s capital.

The virtual lobby day is centered around potential co-pays to Medicare home health services, which remain on the table as deficit talks continue. There have been a range of proposals since recent federal budget deficit talks began. They include a uniform 20 percent copay for all Medicare services, which NAHC estimates would amount to as much as $600 to access a Medicare episode of home health services. Other proposals include one by the Medicare Payment Advisory Commission (MedPAC) of $150 per Medicare episode and another from President Obama in a past year’s budget blueprint that was $100 per episode, but not preceded by a hospital or nursing home stay and beginning in 2017 for newly eligible Medicare beneficiaries.

NAHC members can help fight these proposals by sending a message using the NAHC Legislative Action Network (LAN). Click here for a sample message opposing home health copays and payment cuts. The message will be more impactful if you personalize it with your background and experience and describe the harm that copays and payment cuts will cause patients and providers in your state and district. For hospice messages, click here and here.

You may also deliver the message by phone. You may obtain contact information here: Contact Your Elected Officials. When calling, ask the receptionist to connect you with the staffer who handles health care issues. For talking points on home health copays, go here; for payment cuts, go here. For hospice, go here and here.

For those who are not members of NAHC, you can still contact your US Senators and Representatives through their respective websites. If you need assistance finding who represents you, go to www.wheredoivotema.com.

NAHC also hosts a facebook page called “No Sick Tax” that is meant to bring advocates and home care agencies together around the issue of fighting copays.

Return to www.thinkhomecare.org.

New Edits on Hospice Claims

Recently, CMS released Change Request (CR) 8142 – Hospice Monthly Billing Requirement, effective date of change- July 1, 2013. The CR instructs Medicare contractors to implement a system edit to return hospice claims to the provider when there is more than one hospice claim per month per beneficiary. The only exception to this requirement is in the case of the beneficiary being discharged or revoking the benefit and then later re-electing the benefit during the same month.

Medicare contractors will also implement a system edit when the provider submits claims that span more than one calendar month.  Any hospice claim spanning multiple months will be returned to the provider for correction.

This is not new policy but is a new enforcement.  After July 1, 2013 claims not in compliance with the monthly billing requirement will be returned to providers.  A corresponding MedLearn Matters article is expected to be posted in the near future.

Return to www.thinkhomecare.org

.

CMS Clarifies Titling and Dating F2F

Good News for HHAs…

Face to Face (F2F) changes finalized in the 2013 Home Health PPS update Federal Register notice are effective for episodes ending on or after 1/1/2013.  In this notice the Centers for Medicare & Medicaid Services (CMS) wrote: “We are finalizing regulatory text changes as proposed. The regulation text will be changed to not be prescriptive as to what entity needs to date and title the face-to-face documentation, but will still require the same content and the certifying physician’s signature.”

The National Association for Home Care & Hospice (NAHC) in an effort to clarify the intent of changes related to titling and dating F2F encounter documentation, asked the CMS to confirm whether home health agencies are now permitted to title and date F2F encounters, and to clarify what “date” the change is referring to.

In the response received by NAHC, CMS wrote: “the new regulations are not prescriptive as to what entity may date/title the encounter documentation.” CMS further qualified this statement saying “to comply with documentation requirements, the face-to-face encounter document has to have two dates: the date of the encounter and the date of the documentation. Our new regulations are not prescriptive as to who can title or date the form, but the form must be signed by the physician. As such, the HHA may add the title and the date of the documentation if this was not done by the physician.”

CMS also reported to NAHC that, “if the physician does not date next to his/her signature, then it would be acceptable for the HHA to date the documentation and consider it the “date of documentation.” This date does not need to be the date that the physician affixed his/her signature in cases where the physician did not date the form at the time of signing.”

This change in the regulation will ease the burden for home health agencies for all the times when they needed to return the F2F document back to the physician  because of a missing date.  In the near future, CMS plans to update its Manuals and F2F Questions and Answers to address the F2F regulatory and policy changes detailed in the 2013 Home Health PPS update Federal Register notice.

Return to www.thinkhomecare.org

Judge Approves ‘Improvement Standard’ Settlement

On January 24, 2013, the Chief Judge of Vermont’s U.S. District Court gave her approval  during a scheduled fairness hearing for an ‘improvement standard’ settlement (Jimmo v. Sebelius).  This settlement could lead to more long-term care in the home health setting and open the benefit to patients who were previously denied coverage.

According to The Center for Medicare Advocacy, that helped litigate the case on behalf of beneficiaries, “With the settlement now officially approved, the Centers for Medicare & Medicaid Services (CMS) is tasked with revising its Medicare Benefit Policy Manual and numerous other policies, guidelines and instructions to ensure that Medicare coverage is available for skilled maintenance services in the home health, nursing home and outpatients settings. CMS must also develop and implement a nationwide education campaign for all who make Medicare determinations to ensure that beneficiaries with chronic conditions are not denied coverage for critical services because their underlying conditions will not improve.”

It should be noted that the Settlement Agreement standards for Medicare coverage of skilled maintenance services applies immediately, The Center of Medicare Advocacy encourages people to appeal should they be denied Medicare coverage for skilled maintenance nursing or therapy because they are not improving.

For more information read, Judge Approves Settlement in Jimmo vs. Sebelius After Court Hearing

Return to www.thinkhomecare.org

January 31- Deadline for Submission of Structural Measure Data for Hospice

Reminder:   The deadline for attestation and submission of structural measure data for the Hospice Quality Reporting Program (HQRP) is Thursday, January 31, 2013.

Hospice providers that have not already created a user account and begun structural measure data entry should do so immediately. The link to the data entry site is available on the Data Submission portion of the HQRP website at the bottom of the webpage under “Related Links.” For step-by-step guidance on account creation, account activation, data entry and data submission, refer to the Technical User’s Guide for Hospice Quality Reporting Data Entry and Submission

For any questions about using the Hospice Quality Reporting Data Entry and Submission Site  contact the QIES Technical Support Office Help-desk by phone at 1-877-201-4721 or email at help@qtso.com

Technical Help-Desk hours are 8:00 a.m. through 8:00 p.m. ET.

Return to www.thinkhomecare.org

New Claims-based Measures for Hospitalization and ED Use

As reported in the Final Rule for CY 2013, there are significant changes in how the home health hospitalization rates are calculated. On January 17, 2013, the hospitalization measures based on these new calculations were posted on Home Health Compare.  Specifically, the Acute Care Hospitalization (ACH) and Emergency Department (ED) Use Without Hospitalization are now based on Medicare claims-based data rather than on OASIS-based data.

Key points to note:

  • Claims-based measure is based on the Start of Care (SOC) date instead of the transfer/discharge date.
  • Numerator:  the number of home health stays for patients who have a Medicare claim for an admission to an acute care hospital or for an emergency department visit in the 60 days following the start of the home health stay.
  • Exclusions from the Measure Numerator
    • Planned hospitalizations are excluded from the acute care hospitalization claims-based measure numerator.
  • Observation stays that begin in a hospital emergency department but do not result in an inpatient stay within the 60 days after the start of home health care are counted in the ED Use without Hospitalization measure.
  • Observation stays that result in an inpatient stay within the 60 days after the start of home health care are counted in the Acute Care Hospitalization measure even if the patient is discharged from the home health agency.
  • Denominator:  the number of home health stays that began during the reporting period.
  • Exclusions from the Measure Denominator
    •  Home health stays for patients who are not continuously enrolled in fee-for-service Medicare during the 60 days following the start of home health stay. (Medicare lacks full information about the patients utilization of health care services and cannot determine if care was sought in an ED during the numerator window,  60 days time period)
    • LUPAs are excluded from claims-based measure
    • Home health stays in which the patient receives service from multiple agencies during the first 60 days are excluded from the denominator.
    • Home health stays for patients who are not continuously enrolled in fee-for-service Medicare for six months prior to the start of the home health stay. (This is excluded because Medicare lacks information about the patient’s health status that is needed for risk adjustment)
  • There is significant difference in the claims-data and the OASIS-data for the ACH measures so they are not comparable. To continue to track your ACH rate by OASIS-based data, this data will continue to be reported on the CASPER Reporting System.

For Specifications for Home Health Claims-Based Utilization Measures, Click Here

Return to www.thinkhomecare.org

Reminder- “Home Health and Hospice ODF” – Wednesday, January 9th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, January 9, 2013 at 2:00 PM Eastern Time (ET).

Proposed Agenda

1. Proposal to discontinue the Home Health Advance Beneficiary Notice (HHABN), Form CMS-R-296, and replace the HHABN with a new Home Health Change of Care Notice (HHCCN), Form CMS-10280, and the existing Advance Beneficiary Notice of Noncoverage (ABN), Form CMS-R-131.

2. HHCAPS

3. Home Health Study regarding Access to Care

4. Home Health & Hospice Quality Reporting Update

5. Retroactive Grouper Change for Basel Cell, Squamous Cell, and Unspecified Malignant Cancers for Home Health Services Rendered October 1, 2011 through December 31, 2012

6. Update to OASIS Web-Based Training at: http://surveyortraining.cms.hhs.gov , Addition of Module, OASIS C Online Training: Patient Tracking Domain

7. Flu Vaccination Announcement

8.  Open Q&A

———————————————————————

Dial: 1-800-837-1935 & Reference Conference ID: 78868196.

The audio recording of this call that can be accessed by dialing 1-855-859-2056 and entering the Conference ID beginning 2 hours after the call has ended. The recording expires after 2 business days

Encore: 1-855-859-2056; Conference ID: 78868196

Return to www.thinkhomecare.org.

Fiscal Cliff Deal Reached with No Home Care Cuts or Copays

In the waning hours of the federal legislative session, the Senate passed an agreement to avoid the fiscal cliff that was then approved by the House with none of the feared elements concerning home health care.

The bill extends tax rates for the vast majority of citizens along with a series of other tax-related extenders and unemployment benefits. It also includes a “doc fix” through New Year’s Eve 2013.

U.S. Capitol BuildingThe agreement was approved with bipartisan support and, according to the National Association for Home Care & Hospice (NAHC), there are no cuts to Medicare home health services or hospice care benefits, payments, or payment rates. No home health copays are in this bill and there are no Medicaid cuts affecting home care. Additionally, NAHC found that protection against the Medicare outpatient therapy cap is continued through December 31, 2013.

The “doc fix” is paid for primarily through cuts to hospitals with nearly $15 billion in a combination of coding adjustments and DSH payment reductions. ESRD payments are also affected by a reduction of $4.9 billion.

The CLASS program established to help finance long term care services through a voluntary insurance approach under the Affordable Care Act is repealed under the Senate bill. The repeal has no financial consequence as CMS earlier indicated that it would not implement the CLASS program due to its inability to assure financial viability.

NAHC also notes that a very important provision in the Senate bill is the establishment of a Long Term Care Commission that will be charged with the responsibility to develop a plan for meeting the needs of the growing population of Americans needing care in the home and in other settings. The Commission will have 15 members appointed by the President and Congressional leaders with representation of consumers, older adults, family caregivers, and care providers.

For more on the fiscal cliff and the health care-related implications, see stories below:

Return to www.thinkhomecare.org.