WOW! It will be quite the year. Is your calendar marked? Are you planning? Will you be ready?
Home Health agencies are accustomed to change, but 2014 will be testing even the best of agency stamina. Hospices will see unprecedented new hospice reporting requirements. Below are certain regulatory dates and some suggested dates to begin to or continue preparation for certain changes scheduled:
- Saw the reduction of payments to home health agencies by 1.05% as the 2014 PPS Final Rule takes effect.
- Effects for Coding Case Mix began, as CMS removed 170 ICD-9CM Case Mix Codes including the infamous GERD. That code removal should have been no real surprise to anyone. GERD was much reviewed and critiqued by CMS. Most of the codes removed, however, had little impact upon home health.
- Changes to the Medicare Benefit Policy Manual (MBPM) as a result of Jimmo vs Sibelius take effect.
- MACs could now begin denying home health claims if physician NPI numbers were not on record in the PECOS system.
- Hospices could begin submitting data on two Hospice Quality Reporting Measures; the Pain Measure and the structural measure which were collected in 2013.
- Hospices could voluntarily report new medication claims data.
- Mid January meant Q3 2013 HH-CAHPS data was due.
- 1/31 Bundled Payment demos listed in CMS announcement. 90 of the 160 post- acute agencies listed were home health agencies. Keep a watch on this project as it could tell much about the future of home health payment.
- 1/31 CMS temporarily suspends enrollment of new home health agencies in Fort Lauderdale, Detroit, Dallas, and Houston. The moratorium was extended in Miami-Dade and Chicago metro areas. Experts will not be surprised if a later announcement includes Baton Rouge, Brooklyn, LA, and Tampa (HEAT locations under focus).
HHS announced a delay for third level appeal ALJ reviews by more than 2.5 years, meaning an appeal filed in January would not be heard before July 2016. Current backlog is 357,000 claims for the 65 ALJs with 15,000 hearing requests being filed weekly.
Agencies should pay attention to OASIS Q&As released1/21 by CMS. Neither an adaptive reader nor a magnifying lens is considered corrective lenses, so please stop losing the two case mix points for M1200 by answering incorrectly if your team fell into this category.. Those two items were not what CMS was considering when they stated “corrective lenses.”
FEBRUARY- CMS is expected to issue Surveyor instruction regarding when and how to impose sanctions under the most recent Guideline revisions.
Training will be provided by CMS regarding the new Hospice Item Set (HIS).
Agency leaders should consider evaluating current patient mix to determine financial impact of ICD-10 transition. Agency leaders should consider outside audit of Coding. Review individual coders as to indepth knowledge of Anatomy, Physiology, Diagnostics, Pathophysiology, and Pharmacology. Consider third party coding specialists as an option. Look at their coder requirements, supervision and audits of coders’ work product and ask if they have an outside independent audit completed on their coding overall?
Palmetto is probing certain HIPPS codes of 20 therapy visits or more. The HIPPS codes under review are 5BHK, 5CHK, and 5CGK. These patients would have fairly high to high clinical and functional severity scores. These HIPPS codes are usually reviewed by agency QI departments.
MARCH – The first week of the month is CMS ICD-10 CM testing week. This will be followed by a meeting of the ICD-9 Coordination and Maintenance Committee Meeting.
CMS is to deliver an address to Congress regarding ways they believe the home health payment system should be revised.
Agencies may wish to develop more extensive intake process, guideline, and tool for intake in relation to ICD-10.
Review OASIS C1 with personnel.
The last day of the month is the deadline for open enrollment for individuals through the health exchange.
Consider Preparation of Coding Corporate Compliance Plan
Prepare for Cash flow interruption with the advent of ICD-10 as CMS states they expect a minimum of 10% rejection of claims due to inaccurate or non- specific ICD-10 codes.
Identify when Software Vendors will have new HIS tool ready in April to view.
APRIL- Hospices must comply with reporting new claims data that includes listing injectable and non-injectable prescription drugs on claims on line-item basis.
April 1 is the deadline for submission to CMS of both hospice quality measures; pain and structure measures collected in CY2013.
Agencies should be educating clinicians as to use of new OASISC1 that will be implemented July 1, 2014.
If coding is being done in house, begin practicing ICD-10 coding.
Conduct ICD-10 documentation expectation training for clinicians. Coding audits of documentation should be well underway. Finalize any new forms needed for ICD-10. Test tools and processes.
Develop refined audit tools for parallel coding if coding is not being completed by a third party coding firm.
Monitor readiness of payors, vendors, and clearinghouses for ICD-10 readiness.
April 14, Hospices will be required to report data on number and length of visits for clinicians and hospice aides.
April 17, Deadline for submitting Q3 HH-CAHPs data
MAY – Evaluate the understanding of OASIS C1, new tools, and forms for ICD-10 including a more extensive Intake tool. More clinical and diagnostic information will be needed up front to code properly. Test new intake assessment tool as assistance to the field clinician and the ICD-10 Coding specialist. If coding is inhouse, parallel coding should be underway to reduce the 40-50% projected increase in time required to code using ICD-10. Review ICD-10 Corporate wide Coding Compliance Plan Hospices educate personnel on new HIS tool. Evaluate time and processes for implementation in July. CMS will be offering training on HIS (TBA).
JUNE- –Continue parallel Coding if coding is in house
Assess intake process and new forms, look at business ops processes, and relook at RCM process as they relate to ICD-10.
Audit ICD-9 and ICD-10 processes and forms
Hospices finalize implementation process of new HIS tool
Confirm all payors, vendors and clearinghouses are ready to process ICD-10 claims
Submit final test submission of claims to clearinghouse portal.
Finalize and then implement ICD-10 Corporate wide Compliance Plan.
Implementation of the Hospice Item Set (HIS)
OASIS C1 Grouper to be announced
Prepare for the 40-50% increase in coders needed to code ICD-10 if coding in house
Complete Coding Compliance Plan and present to personnel
For 60 day episodes, RAPS beginning August 3, 2014 will have ICD-9 CM codes, but the final claim, if the episode ends on or after 10/1/2014 will have ICD-10 CM codes.
Now, might be the best time to take a vacation.
You have prepared for ICD-10
You have prepared for OASIS C1
Take a final walk through processes
Final orientation of 40-50% increase in new coders hired to handle ICD-10 if you chose to code in house.
ICD-10 CM is in effect!
OASIS C1 is now in effect
Wage index for Hospice becomes effective
10/16 Deadline for submitting Q2 2014 data for HH-CAHPS
Resubmit rejected claims due to incorrect ICD-10 coding
Final 2014 PPS Rule due from CMS
Case Mix Grouper released
That review takes us to Thanksgiving and the holidays. We have survived the year!