Archive for the ‘Affordable Care Act (ACA)’ Category

The Role of Compliance : Home Health and Hospital Readmissions

Tuesday, January 8th, 2013

This is THE topic one sees everywhere; trade journals, conferences, CMS, MLN, State Alerts, Home Health Associations. This topic is no longer just an operational and financial issue. Boards of Directors are looking to the Corporate Compliance Department and stating hospital readmissions should be part of the Corporate Compliance Plan.

More and more, leaders are demanding that the Corporate Compliance Officer be involved in evaluating the underlying causes for readmission and discerning the readmission issues.

Hospitals have put in place operational and financial impact reviews of readmissions into their facility within 30 days of discharge. The Affordable Care Act has required a number of measures be instituted to reduce hospital readmissions. Among these measures is the Hospital Readmission Reductions Program (HRRP) that regulates adjustment for payment to facilities with excess readmissions within 30 days of discharge.

Hospitals recognize that evaluation of the issue requires review of three phases of operation; admission/inpatient care, discharge/transition planning, and post-discharge care. The hospital compliance officer is beginning to look at each phase of care. They are beginning to have active involvement on the “Safety and Quality of Post Acute Care” Committees. These committees are looking at which agencies have the most readmissions and which physicians are involved. What diagnoses are seen most frequently and which medications are seen most frequently? Which agencies have overall compliance issues?

Smart Home Health Providers are viewing this as an opportunity. Not only can the agencies market their hospital readmission prevention programs; i.e. falls risk, heart failure, and medication reconciliation, but now is the time to market the home health agency corporate compliance program and theirleaders involvement in this program.

Hospitals usually do not envision compliance programs in home health agencies, even though they are strongly encouraged, they are not mandated by the OIG as

they are in the acute care setting. Positioning the home health agency as compliant, meeting the OIG required elements and also focusing on HIPAA, strongly states the agency parallels the hospital’s focus on compliance. It also non -verbally speaks to the agency’s root cause analysis approach to seeking solutions to problems. Since audit and prevention are required elements of a compliance program, the home health compliance officer can relay the home health agency’s approach to reduce hospital readmissions and discuss data infomatics leading to present programs and review of hospital readmission.

It is this type of collaboration that positions a home health agency as a future partner in new programs; i.e. ACOs, Patient Centered Medical Homes, and other Transitional Care Initiatives.

Summary of the CMS Released 2013 Final Rule

Tuesday, November 27th, 2012

Market Basket and Payment Rate Update

On November 2, 2012, CMS released the Medicare Home Health Final Rule for the Home Health Prospective Payment System 2013. The proposal includes the 2013 Market Basket Index (MBI) update of 2.3%, the required 1 point reduction under the Obama Affordable Care Act, and the reduction in rates of 1.32%, which is approximately a $10M decrease to payments for the home health 60 day episodes for 2013. The main change, per NAHC, from the July 5th proposed rule adjustment is an adjustment of the MBI from 2.5 to 2.3% occurring as a result of more current data. Proposed payment base episode rates are set at $2137.73 from a current $2138.52.

Though a small increase, the gain is that it is not the decrease CMS had proposed if  a full creep adjustment had been incorporated. The base rates are adjusted up by 3% for service to patients in rural areas.

 

LUPA RATES

For agencies submitting the required quality data, the LUPA rates are :

HH Aide $  51.79

MSS       $ 183.31

OT          $ 125.88

PT           $ 125.03

SLP        $  135.86

SN          $  114.35

 

For those agencies that have not submitted quality data, their rates will be reduced by 2 percentage points.

 

The outlier eligibility standards are changed from 2012. The Fixed Dollar Loss Ratio is lowered from 0.67 to 0.45. This will increase the number of episodes that will qualify for outlier payment.

 

Sequestration

Home Health agencies should expect payments subjected to a 2% sequestration, as part of the deficit reduction law. Though this is not a rate change, in and of itself, it will be a withhold of 2% from the claims payment. This is another  home health  reduction. Be prepared for expected significant changes for 2014 when CMS rebases the HHPPS rates as required under the Affordable Care Act.

 

Therapy

CMS finalized three revisions regarding qualified therapists completing a functional reassessment of the patient at the 14th and 20th visit and every 30 days.

 

First: CMS states that if a qualified therapist misses a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, NOT the visit after the qualified therapist completed the late reassessment.

 

Second: CMS states that in cases where there is multiple therapy disciplines involved, if the required reassessment by the qualified therapist was missed for any of the therapy disciplines, therapy coverage would cease for only the therapy discipline involved.

 

Third: CMS states that in cases where the patient is receiving more than one type of therapy, qualified therapist must complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and they must complete the 19th visit reassessment during the 17th, 18th, or 19th visit. CMS also states that in instances where the beneficiary receives more than one therapy type, if the frequency of a particular discipline does not make it feasible for the reassessment to occur during the specified times without providing an extra unnecessary visit or would delay a needed visit, then it is acceptable for the qualified therapist from each discipline to provide all of the therapy and functionally reassess the beneficiary during the visit associated with the discipline that is scheduled to occur closest to the 14th Medicare covered therapy visit, but no later than the 13th Medicare covered visit. Likewise for the 20th Medicare covered therapy visit but no later than the 19th covered therapy visit.

 

Thus, the revised rule states that if, in multiple therapy visit cases, the required reassessment was missed for any of the therapy disciplines, therapy coverage would cease only for that particular therapy. Therefore, as long as the required therapy assessments are completed timely for the remaining therapy disciplines, therapy services would continue to be covered for those therapy disciplines, unlike presently.

 

Face to Face

CMS finalized adjustments allowing non-physician practitioners in an inpatient setting to perform the encounter and inform the inpatient physician who can then become the certifying physician.

 

M1024

M1024, effective January 1, 2013, is to only be used for acute fracture codes for case mix points. Patient resolved conditions are not to be coded in home health. Citing Attachment D, CMS has clarified the only codes not allowed in homecare are acute fractures. These, then will be the only resolved codes allowed in M1024. Neoplasms, diabetes codes, neuro codes, and skin will no longer garner case mix points if placed in M1024, although CMS has stated an agency may continue to place resolved conditions in M1024 to present a more complete picture of the patient.

 

The final rule can be found at

http://www.ofr.gov/inspection.aspx

The Affordable Care Act: At Risk Physician and SNF Reimbursement and Home Health Care

Monday, November 26th, 2012

In several prior ezines, we have discussed the Affordable Care Act (ACA) and its far reaching provisions, including the fact that it is transforming hospital provider incentives to a system based on value rather than volume of beds filled. We have discussed the ACA mandated Accountable Care Organizations and the impact of the ACA face to face requirements and the Care Transition Program impact on home health.

The ACA also mandated the new Medicare Demonstration Project using bundled payments for care inclusive of acute care, post acute care, and physician care. Under the project, participating health care organizations receive a portion of a single fee paid for the episode of care. This project began January 1, 2012 and is scheduled to be completed December 31, 2016. It is expected to impact Home Health in the years to come.

Home Health agencies should be aware that the ACA has also mandated that SNFs must implement compliance programs by March 3, 2013 and must also have full quality improvement plans in place no later than December 31, 2012. Several HH agency leaders recently shared that referring SNFs have begun asking about collaborative efforts between the SNF and the home health agency regarding a quality transitional plan format. This would aid patients with a smoother adjustment to home with a focus on a  well understood medication regime. Some SNFs are asking the HH agency to provide privacy and security policies as well as copies of their compliance initiatives as all levels of care begin seeking evidence of compliance, care, and outcomes, seeking those agencies with whom they wish to form a collaborative effort as the healthcare landscape begins to change.

Physicians who voluntarily agreed under the Physician Quality Reporting Initiative to report on certain quality measures have seen the program become permanent. The ACA has now required an appeals process and extended the incentive payments through 2014. Beginning in 2015, physicians will suffer a 1.5 % payment penalty for improperly submitted data for 2013.

Effective 2013, the Independent Payment Advisory Board (IPAB) will go into effect.  This controversial 15 member board will have broad power to make specific recommendations to reduce spending in healthcare. If Congress fails to act the IPAB recommendations can automatically become law. The ACA mandates the IPAB begin their research and investigation in 2013 with the first required recommendations due in 2015. Note: There have been several attempts to repeal this board with other appeals pending.

Hospitals penalized for patients readmitted within 30 days. Physicians and hospitals are feeling the financial sting of penalties imposed with patient readmissions within 30 days. Barnes-Jewish, in St Louis, considered a flagship for quality care, has “one of the highest readmission rates in the United States” for patients suffering from heart attack, heart failure, or pneumonia, states the St Louis Post Dispatch, August 17, 2012. Penalties for last year amount to over $2.2 million. The hospital will be seeking improved patient discharge processes to their medical homes, stated the hospital’s medical director.

Home health agencies must prepare now to provide value in the above areas with hospitals, SNFs, and physicians.  Patient Heart Failure and Heart Attack Programs that can demonstrate value will be essential. Hospitals and physicians will not be able to afford to refer to home health agencies that cannot demonstrate viable outcomes in needed areas. Quality Quality Quality is the word so frequently heard now in healthcare discussions. Aggressive upfront care instituted within 24 hours of hospital discharge is beginning to show results. Waiting for 48 hours to see a patient freshly discharged from an acute care setting may soon be a thing of the past for home health agencies. Agencies should be preparing now for the changes coming to healthcare. They should consider the following:

  • Establish meaningful cardiac and respiratory programs with supportive data displaying the benefit of an alliance with the HH agency to reduce hospital readmissions
  • Establish specific Medication review and education protocols since medication mismanagement accounts for a growing number of readmissions
  • Establish a bonafide Falls risk program with data analysis showing how the program was instituted coupled with any prompts and cues utilized.
  • Establish a clear program educating patients as to when they should call the home health agency, when to escalate the issue to the physician and finally, when to dial 911.
  • Establish an annual OASIS Assessment review to be certain all clinicians are aware of OASIS Guidelines and Conventions identifying how to answer the OASIS properly.

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.

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?