Posts Tagged ‘OASIS’

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.

Physicians and Care Plan Oversight (CPO) and Certification/Recertification

Tuesday, May 15th, 2012

Care Plan Oversight is physician supervision of patients under either the home health or hospice CMS benefit. CMS does not provide this reimbursement for these services if a patient resides in a nursing facility or skilled nursing facility.

Physicians should be made aware of this reimbursable service. They must review the Plan of Care and be made aware of the reimbursement for the process.

Understand the Difference between CPO and Certification/Recertification

G0180 – Certification of a home health patient.

G0179 – Recertification of a home health patient

G0181 – Home Health Care Plan Oversight

G0182 – Hospice Care Plan Oversight

Care Plan Oversight reimbursement allows physicians to bill CMS for the time physicians oversee the home health plan of care. The physician may bill for 30 minutes of time each month as long as they log the care delivered and it is allowable care for CPO. Remember: the face to face encounter must be included as part of the certification form itself, or as a signed addendum to it, and must include the certifying physician’s distillation of the patient’s clinical condition and needs for home care. It must also attest to homebound status and medical necessity.

Certification billing requirements include:

  • The physician signing the Plan of Care is the physician who may bill for CPO
  • Date of Service: Date the physician signs the POC
  • List home health agency provider number
  • List physician NPI number
  • List the care provided that meets the required services for payment

 

Recertification billing requirements:

  • Must be billed by the physician who recertified the patient
  • Used after a patient has received 60 days of covered skilled intermittent Medicare services
  • Date of service: Date the physician signed the POC
  • List agency provider number
  • List physician NPI number

 

What is CPO?

 

CPO is physician supervision and oversight of patients under either home health G0181 or the CMS hospice benefit G0182. The home health services may include:

    Developing an individualized plan of care

    Telephone calls with other health care physicians involved with the care

    Revising a plan of care

    Activities involving coordinating of care

    Documentation of planning

    Medical Decision Making

    Review of treatment plans, and analysis of labs, tests, and data analytics

    Team conferences

The beneficiary must require complex and/or interdisciplinary care. The physician may not have a significant financial or contractual interest in the home health agency. The physician may not be the medical director or employee of the hospice, and does not provide service under arrangement with the hospice.

Documentation must be completed by the physician and not the home health agency.

Non – Countable Services

 

  • Initial interpretation of a lab during a face to face encounter
  • Informal calls with office personnel
  • Telephone calls to patients, family, even if medication adjustment occurs
  • Travel time
  • Time preparing claims

 

Billing/Filing the Claim

Medical records for the dates must document the 30 or more allowable minutes for care planning activities for each patient. Dates of services must be the first and last date during which documented planning services were provided. No other services,  but from the CPO may be on the claim.

Agencies should spend the time to educate physicians to this reimbursement possibility. Have a simple fact sheet available with the steps to complete the process identified but do not complete the form for the physician. Offer a sample log to physicians so they may see what can be billed. Provide  the link to the CMS site so the physicians  may read the complete process outlined by CMS.

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/downloads//R999CP.pdf

OBQM/Chart Audits and the New Survey Protocols: Tweaking and Streamlining Process for Real Improvement

Tuesday, October 25th, 2011

From Outcome-Based Quality Improvement (OBQI) refresher training to Total Quality Management Agency Programs, the home health agency of today needs to define the level of programs needed to operationally and financially drive  success. The home health agency needs OASIS stop, logic, and congruence edits to prompt clinicians and flag incongruence between M questions. But, that is just the start. The OASIS integrated assessment sets the stage for the plan of care created. From the plan comes the visits and they must support that plan and drive to expected outcomes.

Perhaps your firm would benefit from a third party quality clinical chart audit. Your Professional Advisory Committee, Board of Directors, and you may well see the merit of an independent view of clinical processes and care. Noting strengths and determining opportunities for improvement before a survey makes sense. Are you spending too much time and money internally for chart reviews? What does happen after those reviews? Do you educate personnel? How do you know if that education was successful?

Clinical chart audits can assist you to remedy issues, provide education and training, and improve efficiencies. Clinical audits can assist to streamline processes, determine areas of risk, and assist to improve the bottom line.  Clinical audits can assist to identify quality customer service and improve patient care.

“Identifying ways that an outcome-based corporate culture fully extends to both internal and external customers is the responsibility of leadership. Developing and using simple tools can aid in the process. Once systems are implemented, maintaining a true commitment to TQM becomes a powerful challenge. But, to the persevering leader, the rewards of quality customer service can go hand in hand with a positive bottom line” (Carmichael, 2005)*

The new survey protocols mandate an outcome–oriented survey process, therefore, know that the surveyor will continue evaluating, per CMS, “the quality of care and services furnished by the agency as measured by indicators of medical, nursing, and rehabilitative care.” In addition, the new process will emphasize the clinical record of assessment and care, agency personnel interviews, and home visits. The new regulations provide clear guidance for expanding the survey, if needed.

Besides Process and Chart reviews, agencies should routinely use the Surveyor Worksheets to review agency data filed with the state, look at diagnoses and expected outcomes, monitor potentially avoidable event outcomes, and be certain there is adequate documentation for case mix indicators.

An evaluation of Level 1 indicators (see Select Data University April, 2011 article on New Survey Protocols, Survey Protocol Worksheets) includes standards under skilled nursing and therapies. If the agency is in compliance with Level 1 standards and no additional issues or concerns are identified, the survey is completed. If the expected outcomes are not met for one or more Level 1 standards, then the survey expands to become a partially extended survey.

At the very minimum, compliance with Level 2 standards is evaluated if deficiencies were identified with Level 1 standards. This is the partially extended survey. Be aware that surveyors may review additional non Level 1 or 2 standards under the same conditions during the partially extended survey at their discretion. (State Operations Manual, SOM, Appendix B). In an extended survey, all conditions will be reviewed. Appendix B and Survey Protocols provide specific recommendations for: citing condition-level deficiencies, extending the survey, and related conditions for further survey.

Now, more than ever, a thorough assessment must drive discipline specific care plans that drive the overall POC with every visit skilled and enhancing the process toward expected outcomes. Clinical record reviews, clinical interviews, and home visits drive the survey process. Documentation is essential. Good documentation starts with a thorough assessment. That assessment should be specific. Does your assessment tool set the stage for success? Is it detailed enough to gather data to allow the highest level of coding specificity? Does it cue the clinician with requests for detail to support a case mix diagnosis that may be assigned?

It is simple in the guidelines; a good POC starts with a solid clinically integrated OASIS assessment. That assessment drives the discipline specific care plan and those plans contribute to the overall POC. That POC has diagnoses present that require substantiation in the clinical record and the expertise of master coders. That very record supports the diagnoses sequences chosen. The visits can stand alone as to skill but reflect that they are a part of an individualized skilled plan of care.

Documentation takes time and thought. Clinicians are busy and require assistance and support. Consider a third party coding entity. Also consider an OASIS data collection service that was created by clinicians.  The system should be reflective of what you expect and of what your clinicians need.

The new survey protocols are data driven. Agency leaders need real data daily, weekly, monthly to monitor clinical performance and patient care outcomes.

The Surveyors have the data when they arrive. Do you?

*Carmichael, S (2005). Total quality management and outcomes based quality improvement: revisiting the basics. In Home Health Care Management and Practice (17)(2),119-124

Educational Videos: CVA Residual Effects

Monday, July 11th, 2011

Coding Compliance CVA Residual Effects

Coding CVA’s, meaning Cerebral Vascular Accident caused by a blood clot or a hemorrhage, or what the patient calls a stroke can be a challenge in home care.  Coding guild lines do not allow the acute code for the specific type of cerebrovascular event to be coded in M1020 or M1022.  These specific does are only allowed to be used in the inpatient settings.

Therefore, what is allowed to be coded in homecare is the Late Effects of Cerebrovascular Disease group of codes.  Late effects mean residual effect on sequelae of the initial acute cerebrovascular event.  These codes are found in the 438.0 to 439.9 category.  In the alphabetical index to Diseases they are found under the word Late Effects: subheading cerebrovascular disease.

In home health, the nurse and therapist are adhering and treating the lingering deficits that the CVA has caused.  Rehabilitation has started in the acute hospital and progressed in the inpatient rehabilitation.  Now, that the patient is home, further therapy helps to regain function in the variable of home setting, as long as the patient remains homebound.  Otherwise, therapy would continue in an outpatient clinic or office.

To code these late effects of cerebrovascular disease, the coder needs to identify what these lingering residual effects are.  It is very important that the clinician completing the OASIS and initial assessment state clearly what these residual effects from the stroke are.  Different late effects have a different code. There are 29 different codes to pick from, so concise information is needed.  Please never document CVA or late effects of CVA without following these words with the specific affects the patient presents.

It is acceptable to list more than 1 deficit, especially if multiple therapies are ordered.  It is also necessary to indicate, if there is hemiplegia or monoplegia, what side of the body is affected. The coding guidelines want to know if the dominant side is affected or the non-dominant side and if it is upper or lower limbs for monoplegia.  Documenting left or right hemiplegia from a CVA does not help the coder if it is not known if the patient is right or left handed.

To recap: never document CVA or late effects of a CVA on the diagnosis list without also coding what the specific residual effects are.  These residual effects will be a focus of care for the clinician and therapist as seen by the orders and goals on the Plan-of-Care.

Psychiatric Nursing in Home Health

Wednesday, May 25th, 2011

During these past few weeks, we have seen an increase in questions regarding psychiatric nursing services. More agencies are considering new programs. One agency has shared that Palmetto is no longer asking to see resumes of psychiatric nurses, but agencies must verify with EVERY MAC before beginning a psych program.


The CMS Publication 100-2, Chapter 7, §40.1.2.14, simply says, “Psychiatrically trained nurses are nurses who have special training and/or experience beyond the standard curriculum required for a registered nurse.”  MACs can establish the special training and experience required.  A home health agency should contact its MAC and look at the MAC website for any special qualifications needed.

Introduction

CMS has recognized psychiatric home care as a reimbursable service since 1979, but nationwide, proportionately fewer home health agencies actually provide this service. The exact number of agencies that include psychiatric home care is unknown. There has been a reluctance of agencies to implement psych programs and there are many reasons for these decisions.

First of all, the skills of a psychiatric nurse are required and this specialist is usually more difficult to find. Second, the psychiatric patient is frequently more disorganized and needy than other patients causing the case management responsibilities to become time consuming and complex. Third, this patient is frequently homebound questionable.

CMS Publication 100-2, Chapter 7, §430.1.1, states that a patient with a psychiatric problem may be considered homebound if “the illness … is of such a nature that it would not be considered safe to leave home unattended, even if he or she does not have any physical limitations.”  The homebound status of patients with psychiatric needs require well written, clearly stated clinical visit notes, because there may not be physical impairments, and homebound status must be clearly delineated. Any patient in a certified home health program may leave their home for specific reasons, as identified in Chapter 7 of the Medicare Provider Benefits Manual. Homebound status for a patient suffering from a mental health issue may be just as painful and debilitating, but may not manifest itself with physical symptoms or behaviors.

Homebound status (for a patient suffering from a mental illness) may need to be evaluated as a clinician would evaluate a patient suffering from dementia or Alzheimer’s diseases That patient may have few or no physical limitations and yet would be deemed unsafe to leave his/her home unattended. The patient, in this example, could be considered homebound.

However, if the patient with a psychiatric condition leaves home regularly for reasons other than to visit the physician, he/she may not be considered homebound; the same as any other home health patient in the certified agency.  An example may be that of patient with a mental health issue attending partial hospitalization.

Partial Hospitalization

In 1999, CMS, then known as HCFA, stated that a patient in a partial psychiatric hospitalization program does not qualify for psychiatric home care services.  The partial hospitalization program should be able to provide necessary psychiatric services. The homecare services must be psych-related. If they are not focused on a psychiatric issue, the home health agency must evaluate the patient’s needs, just as it would normally do with any other patient, and evaluate whether home care services are in keeping with medical necessity and homebound status.

What is Psychiatric Home Health Nursing?

What is unique about psychiatric home care? Although psychiatric home care is bound by the same CMS regulations that define other types of home care, these regulations are largely non-specific for the psychiatric patient. This means the clinician must be specific as to symptoms and document those plans and interventions, as well as work closely with the physician.

On the surface, psychiatric care appears to be very eclectic, but there is much depth of choice for intervention strategy. Although psychiatric nurses may draw upon crisis intervention techniques as noted by Duffy, Miller, and Parlocha (1993) and Beck’s or Montgomery-Asburg Depression Inventories, Young Mania Scale, Sheehan Anxiety Scale along with Cognitive Restructuring therapy, there are a number of other psychiatric intervention models that can be very useful: psycho-education, interpersonal reflective, supportive, individual, and/or brief therapy, as well as behavior therapy, relaxation, contract, and reward provisions.

The psychiatric nursing home care plan must be intermittent. This short term program frequently focuses on improved problem-solving, stronger ego boundaries, and enhanced self-concept. This is important with patients of all ages, but the need is seen often with elder patients who are suffering significant losses in life.

With patients suffering from depression, the psych nurse frequently seeks ways to displace internalized anger outwardly. Activities designed by an occupational therapist can augment the skills of the psych nurse. An increasing number of home health agency psych programs are adding this discipline because of the physical activities that can be beneficial.

Stress management and education of stress strategies are commonly taught. Many patients have weak or fragile coping mechanisms that require reinforcement or a new approach.

Forming linkages between the patient and needed community services is a vital component of the role of the psychiatric home care nurse. This type of nursing brings an existential/spiritual concern and dimension to patient care. The clinician frequently provides support to a patient with low self esteem and a belief that the community has prejudged them. The clinician can assist the patient to cope with behaviors and approaches patients with an attitude of respect, reinforcing or assisting to rebuild worth and dignity.

Demoralized individuals are frequently seen in this program. Patients may lack energy, frequently because of losses; losses of friends, of family, of job, of status, of money, of respect, and others. This patient frequently requires a nurse whose plan with the patient requires assessment of the patient, their role within the family, the family support system, teaching use of psychotherapeutic techniques to facilitate change, medication management, and supervising their care in a supportive fashion that sustains physical, emotional, and spiritual life,

Relationship Building and Trust

The clinician will build relationships established on trust, caring, compassion, empathy, education, and hopefulness. The RN will use verbal and non-verbal communication techniques to convey interest in the patient, to assess what the patient wants to accomplish, to assist with care planning and goal achievement, and to clarify the boundaries of the relationship, and lastly to affirm the patient has value and worth.

Medication Management

Medication management is frequently a need for patients and is one of the main reasons for hospitalization. CMS identifies a significant portion of hospitalizations are due to poor medication management. Some patients do not understand the reasons they has been prescribed certain medication. Sometimes, patients do not like the side effects and feel those effects are nearly as bad as the psychiatric condition. Some patients cannot afford their meds and still others do not wish to take their meds as they provide a constant reminder of a condition many wish could be forgotten. One patient once shared, “I look in the mirror, put the pill in my mouth, bring the glass to my lips, and know I am ill.” Unless this issue is addressed, the chance that this patient will become medication non compliant is great.

Medication management intervention must be individual. Certain patients may require a contract by which they contractually agree to take their medications as prescribed. It is this tangible “document” that assists with compliance reinforcement. Teaching about major effects of the medications can be an empowering experience. For those patients whose cognitive impairment is apparent, modified pictorial teaching tools may be necessary. Role-playing, coaching, and teaching can be a part of  an empowering strategy.

Summary

Patients with stressors, depression, and cognitive impairments can frequently benefit by a psychiatric nurse. The program must be comprehensive aiding the patient through stabilization, caring, and reinforcement of strengths. A therapeutic relationship built upon trust can provide acceptance to teaching and compliance with medication. Leaving the patient more calm, organized, stronger, and knowledgeable can assist the individual to improve links with family, friends, and the community and be more compliant with their medication regime.

The psychiatric program can be a strong support to total quality care and improved outcomes.