Archive for September, 2012

Some Important Sites for Providers of Home Health Services

Friday, September 21st, 2012

In this day when the only constant is change, here are a few important sites to add to your list.

MLN Matters Articles Index thru August 2012

An excellent site housing national articles designed to inform providers about the latest changes in the industry.

It includes links to MLN related information and over 50 products relating to DME, EHR, Education and Management, Medicare Payment Policy, Provider Compliance, and Provider Specific Information.

www.CMS.gov/outreachandeducation

Patient Centered Medical Home Model

CMS is still testing the patient centered medical home model in the multi-player Advanced Primary Care Practice Demonstration and the Federally Qualified Health Centers Advanced Primary Care Practice Demonstration.

CMS continues to test the PCMH model under the Innovation Center created by Section 3021 of the Affordable Care Act allowing CMS the opportunity to test a variety of models and expand implementation throughout the country.

http://innovations.cms.gov/

The Innovation Center

The Center was created by Section 3021 of the Affordable Care Act allowing the opportunity to test a variety of models and expand implementation throughout the country, the goal is to increase quality and reduce health care expenditures through innovation.

http://innovations.cms.gov/

Survey Guidelines

www.cms/surveycertificationinfo.gov/downloads

Preventing Billing Errors

To increase Understanding of billing requirements and to avoid common billing errors, visit

www.cms.gov/outreachandeducation

Claims Processing

To review expectations for proper claims processing, go to

www.cms/outreachandeducation

The Official Medicare Claims Processing Manual Chapter 22- Remittance Advice

http://www.cms.gov/manuals/downloadsclm104c22.pdf

Understanding the Remittance Advice:

A Guide for Medicare Providers, Physicians, Suppliers, and Billers

http://www.cms.gov/inproductsdownloads/RA_Guide_Full_2_22_06.pdf

Therapy Claims-Based Data Collection Strategy

Proposed rule CMS 1590-P was released as a proposal to collect more date on patient function as it relates to Speech/ language, occupational, and physical therapy services delivered. The Middle Class Tax Relief and Jobs creation Act (MCTRJCA) requires CMS to begin this data collection January 1, 2013.

Update on ACOs

We have written several blogs and ezines regarding the new Chronic Care Management Models, including Accountable Care Organizations. Health and Human Services Secretary announced that as of mid summer there are 89 new ACOs in 40 states serving 1.2 million people. As we have discussed in prior ezinesin both 2011 and 2012. ACOs may be formed by health care groups (not home health agencies) such as hospitals and physician groups. New applications continue to be accepted and there is expectation of the formation of many more of the alternative

care models. Go to:

http://www.hhs.gov/news

Remember, the CMS website has had new updates re Open Door Forum Discussions and MLN educational updates as well as content re ICD-10. Visit often as regulations are changing and being updated routinely.

Billing Compliance and Proposed Survey Sanction: Two Looming Issues for the Home Health Industry

Thursday, September 13th, 2012

Issue One: Looking at Statistical  Data

Every time an OASIS is submitted to the state, portions of it may be parsed out to state, regional, and Federal groups such as the HEAT, MAC review groups, and Federal special projects in the DOJ and FBI. That means that when a review letter arrives, it may already be too late. Since we are aware that Predictive Analytics are employed, correct complete data must be submitted.

Predictive Analytics

In home health care, predictive models are being used to exploit patterns found in historical and transactional data to identify risks and opportunities. The present Models capture relationships among many factors to allow assessment of risk or potential risk associated with a particular set of conditions. The relationships should guide clinicians in their care plan decisions as well as care delivery. There are thousands upon thousands of potential OASIS and coding combinations. Because of the patient profiles and patterns retained over the years, comparisons can be made readily. Add HHRGs and service information to the OASIS and diagnostic data and CMS can gather very significant data regarding your agency’s care delivery and outcomes. MANY analytic filters are utilized to screen the data.  The initial round of filters are termed MUEs (Medically Unbelievable Edits). These edits are the first predictors of fraud and can alert the Z-PICs of agencies that should be monitored. Auditors may monitor an agency for years, gathering data, analyzing data and patterns, andreviewing payments. The agency profile is completed.

This data and these pre-probe edits allow Z-PICs to have plenty of time to analyze data and monitor agency behaviors so that when they send a letter, they have already completed their initial audit and arrived at a solid conclusion. 

Since experts state that 75-85% of all agencies are acutely unaware of business operations data and do not have necessary compliance rules built into or a part of their billing practices to protect them from wrongful claim submission, agencies are at risk. Who is auditing your clinical records and care, the ICD-9 coding, and the claim submission? Who is monitoring your data? Do you have clinical and operational benchmarks? In 2009, billing errors were found to have doubled. Be proactive now, because if your compliance rules and program are weak, you could be hearing from the Z-PICs soon.

Issue Two: Look at Clinical Data

CMS has proposed strong regulations establishing hefty intermediate sanctions to be imposed on home health agencies not in compliance with CoPs. Agencies must read the survey regulations carefully, implement precise policies and procedures, and audit utilization of those policies and procedures to be certain they meet processes as intended by the agency compliance program.

Proposed provisions include:

Monetary sanctions of $8500.00-$10,000.00 for condition level deficiencies that place a patient in immediate jeopardy.

Fines of $8500.00 per day for repeat deficiencies

Fines of $2500.00-$5000.00 per day for other deficiencies not placing a patient in jeopardy.

The monetary sanctions can be applied for the number of days the agency is out of compliance and they can be increased or decreased after the application of the penalty. The sanctions may be per day or per instance. They could not be applied simultaneously for the same deficiency. Please go to the CMS website to review the proposed rule.

Monetary sanctions are not the only sanctions that CMS may impose. CMS can chooses to terminate a provider agreement.  If an agency is unable or unwilling to correct deficiencies. Additional alternative or additional sanctions include suspension of payments for new admissions and new episodes of care, temporary management of care, mandated directed inservices and training, as well as the  emporary management of deficient agencies including making personnel changes and providing necessary interventions to assist the agency back into compliance.

The proposed rules would place much more pressure on a home health agency requiring  excellent documentation of care following a careplan that is consistent with  the needs identified in the patient clinical assessment. If outcomes are not achieved because needs were not appropriately identified, visits were missed, or care was not appropriately delivered, or a patient was placed in danger, an agency could face sanctions.

Agencies are expected to audit care, audit data, audit employee performance and be attuned to levels of care delivered to the patients of the agency. Agencies must clearly accept responsibility for care delivery and the outcomes derived from that care. It is clear from the proposed rule that

If the proposed survey sanctions are passed, agencies must be concerned they have excellent processes in place such as a “built-in, self regulating quality assessment and performance improvement system to provide proper care, prevent poor outcomes, control patient injury, enhance quality, promote safety, and avoid risks to patients on a sustainable basis that indicates the ability to meet theCoPs and to ensure patient health and safety ( Fed Register Vol 77 #135, Friday, 7/13/2012 Proposed  Rules, p 41582 col 3). or the financial consequences could be devastating.

Home Health Agencies: Start Preparing to Work with the Patient- Centered Medical Model

Thursday, September 6th, 2012

There is a fundamental need for health care reform in the US states. CMS, under the Affordable Care Act (ACA) plans to expand patient access to care while reengineering the delivery system to provide lower cost higher quality care. For years, there has been growing evidence of fragmented care, and lack of coordination in both primary and preventive care with rising costs.

CMS, through MLN, has offered numerous articles regarding innovative programs and practices for health care providers. Dollars have been made available to provide care under programs considered innovative, offering coordinated care no matter the level of care. Besides the Accountable Care Organization(ACO),  the Patient-Centered Medical Model (PCMM) has received endorsement snd support by a broad coalition of health care providers, including major health care plans, Fortune 500 companies, the AMA, and numerous specialty societies. Currently, there are over 25 multi-health plan/societal provider pilots underway in a dozen states. CMS is pushing for over 500 physician practices to practice PCMM and there are over 20 bills in 20 states promoting PCMM.

History of the PCMM

1. Since 2000, CMS has been monitoring several quality indicators and seen that states with higher spending per Medicare beneficiary tended to have lower ranking on 22 quality of care indicators.

2. The US population is projected to be 349M by 2035

902 million visits were made to physician offices in the US in 2007. 2/3 of the visits were in primary care, Peds, and Family Practice. The expected rise in care needed will be unsustainable unless new ways of delivering care are found.

3. In 2011, 10,000 individuals per day became eligible for Medicare with a dwindling supportive working population.

23% of all Medicare beneficiaries have 5 or more chronic conditions. The dollars spent account for ¾ of all Medicare spending which is for beneficiaries visiting 14 different physicians for 40 office visits annually. (Source: American College of Physicians 2007).

What is the Patient Centered Medical Model aka Patient Care Medical Home? 

The Patient Centered Medical Model is a care delivery model whereby patient treatment  is coordinated through the primary care physician and a guided care practitioner (an RN specially trained in this model by the John Hopkins certified program). The objective is to establish a centralized setting that will oversee office personnel that may include nutritionists and educators and encourages partnerships between physicians and their patients and families. This model monitors care delivered by Home health agencies, registries, inpatient and outpatient facilities, using information technology, health information sharing, and other means that allow a fully coordinated plan of care for the patient overseen by one notone, but numerous disjointed teams; primary care physician and the guided care practitioner, and other office personnel transforming patient care delivery. This model will no doubt be a part of local ACOs. This model requires certification and approval by CMS. Before long, it is expected state licensure will ensue.

This team may use traditional resources as well as performing a PCMM assessment, a care Gap analysis using education, collaborative meetings and retreats to design an over arching plan of care thatmonitors the diagnoses, care, progress and outcomes. This PCMM will coordinate participants in the plan of care seeking innovative proven programs delivered by quality proven health care organizations.

They will seek agencies with strong EMRs that will “speak” with their EMRs. They will seek efficiencies and innovations such as patient portals. Validated tools and evidenced-based processes will be required. Agencies should have successful validated programs available on line with the capability to have personal patient portals for messaging, lab values, communicating with the PCMM team and education modules.

The PCMM is based on four cornerstones: Provide primary care, is patient-centered, is a new model practice, and is a part of payment reform. This practice is based on 20 years of research demonstrating far better patient outcomes than traditional care.

 It is truly patient centered having a primary overseer of care to eliminate the multiple physician fragmented care model. Engagement of consumers at all levels of care is expected. The PCMM is expected to find innovative methods to achieve the communication goals.

This model is endorsed by the American Academy of Palliative Care, the American Academy of Neurology , the American Academy of Cardiology, the American College of Client Physicians, the American College of Osteopathic Family Physicians, the American Geriatrics Society, the AMA, the American Society of Addictive Medicine, the Infectious Disease Society of America, the Association of program Directors of Internal Medicine, andthe Society of Critical Care Medicine. Agencies should be certain that programs developed meet the appropriate society protocols or they will not be accepted by ACOs or the PCMMs.

PCMM Major Domains and Standards

Access and Communication

  1. Patient Tracking Capability
  2. Intense Case Management
  3. Patient Self-Management Support
  4. Electronic Prescribing and Pharmacologic Review
  5. Test Tracking
  6. Referral Tracking
  7. Performance Reporting and Improvement
  8. Advanced Electronic Communication

Each standard contains sub elements, 10 of which are considered a “must pass”

Initial Level 1 is least complex care, which has 49 points for sub elements

Level 2 is Moderate care with 50-74 points. 10/10 of the appropriate sub elements must be passed.

Level 3 is Complex care with 75 points and 10/10 appropriate elements that must be provided successfully.

This is a new day for home care when present care delivery methods are rapidly changing. Your home health agency should start researching now, seeking evidenced base processes with agency research practices established, having a robust EMR and communication system. Time is of the essence. Where will your agency be in 2-6 years from now?