Members Flock to HCA’s Quality Improvement Meeting

Lots of member interest in HCA’s July QI meeting to discuss medical record audits and upcoming proposed rule changes.

With the sundry of regulation changes in the home health industry over the past few months, the July 24th Quality Improvement (QI) meeting had over 45 members participating in-person and by phone. The numerous medical record audits plaguing the industry dominated the meeting’s discussion.

Multiple agencies have received letters from C2C Innovation Solutions informing them that some claims under appeal have been selected for potential reopening as part of the Medicare Appeals Demonstration. The C2C auditors are conducting the analysis of claims previously adjudicated unfavorably by the Qualified Independent Contractor (QIC), that are currently pending at the Office of Medicare Hearings and Appeals (OMHA) and may be resolved favorably by the QIC.

Other audits that agencies are experiencing are new Targeted Probe and Educate (TPE) audits. These medical record requests are for 5-7 visits and lengths of stay greater than 90 days. No agency is in the third round of the Face-to Face TPE.

One agency reported at the meeting that they are facing three audits simultaneously; a hospice General Inpatient care (GIP) Targeted Probe from NGS, a home health PERM request for Face-to-Face (awaiting ALJ) and eight GIP Post Payment Review by Noridian.

During the meeting there was a lot of member engagement related the 2020 Proposed Rule; the proposal to require OASIS for all payors and the 8% behavioral adjustment. Agencies also discussed strategies for management with PDGM and the process for completing OASIS B-1 for January 1st episodes. PDGM will be a standing QI agenda item.

The HCA is planning to host a PDGM Networking Meeting to help our members with the transition to this new payment model. We are hoping to begin the meetings in September and have a guest speakers and consultants to assist with planning for this historic payment change. Stay tune for further details.

Don’t forget to check out our PDGM Bootcamp on September 24th!

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 by Friday, February 8th at 5:00 p.m. ET

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