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CMS Issues Proposed Rule to Revamp Meaningful Use in 2019


CMS Issues Proposed Rule to Revamp Meaningful Use in 2019

CMS Makes Good On Their Promise To Overhaul The Meaningful Use Program

CMS signaled its intent to fulfill their promise to overhaul the Meaningful Use program with the 2019 IPPS proposed rule.  The rule proposes to change the name to the “Promoting Interoperability” program and institute changes that CMS says would decrease cost and provider time burden.  The rule proposes to include requirements for providers to use the 2015 Edition certified EHR technology in 2019 to qualify for incentive payments.  Significantly, the 2015 Edition of Health IT Certification Criteria requires certified EHRs to demonstrate the ability to provide a patient-facing app access to the Common Clinical Data Set via the use of an API. For more information on this topic or on our USA based Document review and Coding Services or Revenue Cycle Management, please call Select Data at 1.800.332.0555.
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians Click here to read more.

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CoP Compliance – You Can’t Do It Without Your Clinicians!

Clinical Documentation Improvement, Clinical Practices, Coding, Compliance, Conditions of Participation (CoPs), HIPPA, Uncategorized

CoP Compliance: You Can't Do It Without Your Clinicians!

CMS expects Conditions of Participation (CoPs) 100% Compliance on January 13th.

"January Funk" Shortly after ringing in the new year, people have been known to get the blues. Winters are cold, days are short, there’s not another holiday for months, and many people fall into what some call “The January Funk.” If you work in an industry that involves a lot of regulatory involvement, like healthcare, you may fall into a “January headache.” In healthcare, guidance, policy, and regulations are often updated, and new programs are launched at the beginning of the calendar year. For home health providers, saying “goodbye” to 2017 means saying “hello” to updated Conditions of Participation (CoPs) from CMS in 2018. After researching hundreds of pages of documentation, your head may be spinning as you lament over where to start. After all, just working in the home health business can keep your mind busy 24/7, never mind having more heaved onto your plate. With the new CoPs implementation quickly approaching, we’re in the warm up phase right now. If it hasn’t happened yet, it’s time for you to gather your team and start your pep talk. The success of any home health agency depends on teamwork. That’s now a new concept. Now is the time that your clinicians need to start wrapping their heads around how their life is going to be changing because of the updated regulations. Do you already have a plan in place for communicating to patients with limited English language skills? Do your clinicians know what the Patient’s Rights are? Since clinicians are just weeks away from having to give a verbal explanation of the Patient’s Rights to the patients, it’s time to start rehearsing. Clinician competency will be a key to your success, or the lack thereof will be the torpedo that sinks your battleship. Call your team together and let’s get the planning started. First, your team needs to know that these changes are coming, and that they are nothing to be afraid of. It seems that in healthcare when new policies (or regulatory changes) come around there is the feeling of impending doom. “What do we have to do now?” I recommend that you do an overview with your clinicians and let them know what exactly are the conditions of participation and why they are being updated. It’s time to discuss the paradigm shifts regarding CMS’s approach to patient care. It also may take a certain degree of convincing to get your long time veteran clinicians to buy into the idea of patient centered healthcare that is driven by the patient’s strengths and preferences. If your staff doesn’t buy into this new philosophy, there’s little chance that your patients are going to be convinced to shift their thinking. Eliminate Potential Anxiety For Your Clinicians After you get past the “why”, it’s time to get your paper out and start sketching out the “how.” Your clinicians need to clearly understand what part of their routine must change. What signatures do they need to get and when? What’s the phone number for the interpreter’s line? Are you going to publish your agency’s literature in different languages? How do you explain a patient’s right to people with different educational backgrounds and different cognitive ability? Your clinicians are much more likely to be compliant with the updated Conditions of Participation if you help eliminate some of the potential anxiety that accompanies change. Start talking about these things now. It’s not fair to throw clinicians into a new situation without the proper preparation. We’ve all been there, and we all know that it stinks to be there. Start coaching them now so they’re set up for success. Develop tools to get the job done right. Are there different fields that need to be custom added to your EMR so that the additional required information will have a home? If that’s not possible, you should work with your team to develop check lists (or worksheets) so that they are reminded of everything they need to ask or say during that home visit. Look at the tools you have now and decide what changes need to be made. When clinicians are forced to “do things on the fly” without the proper tools, they often find themselves jotting down random information in a disorganized and in a “non-HIPAA compliant” manner. Eventually, when this all of this becomes more familiar, your clinicians will probably develop their own system. While they’re just becoming accustomed to these new requirements, make sure they have the tools to be organized and efficient. Five-Day Window Coordination is a huge factor in the new Conditions of Participation. For coordination to be successful, good communication is a must. Unfortunately, communication is where many teams take shortcuts. The Clinical Manager role that is defined in the CoPs is immense. An agency’s Clinical Manager is only going to be successful if your team has a great communication plan. Communication about a patient’s care plan will be ongoing but it will be especially hectic at the time of admission. The communication plan among clinicians of different disciplines, multiple doctors’ offices, and the administrative staff, must be well thought out, organized and adhered to. Figure out how you’re going to manage all the information in the beginning five-day window, or your Clinical Manager may end up climbing out of the office window to escape. Practice, Practice, Practice! Finally, it’s time for your team to start practicing. There’s nothing that prevents you from implementing some of these changes before the beginning of the year. CMS expects you to be compliant with the updated Conditions of Participation 100% of the time on January 13th. Don’t wait until early one January morning to try and throw these ideas together. You’re not making a quick regulatory snack. You’re creating a huge feast of regulatory changes. Some of us know from experience that you shouldn’t be making your grocery list the day before Thanksgiving as your in-laws are in route to your home. Don’t wait until the beginning of January to bring in donuts for your clinical team so that you can “brainstorm this new thing.” Your clinicians are a key to your Conditions of Participation compliance. Invest in them. Train them. Listen to them. Invite them to join in on important conversations. Their success will lead to good patient outcomes. Isn’t that why we’re doing this after all? For more information about the implementation of the new Conditions of Participation please view our webinar from October. For more information on this topic or on our USA based Document review and Coding Services or Revenue Cycle Management, please call Select Data at 1.800.332.0555.
Related Article - CoPs Breakdown On The QAPI Regulations
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians Click here to read more.

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New ICD-10 Code Updates: Ask the Right Questions to Get the Right Code

Clinical Documentation Improvement, Clinical Practices, Coding, Healthcare, ICD-10 CM, OASIS-C2, Uncategorized

New ICD-10 Code Updates: Ask the Right Questions to Get the Right Code

CMS releases updates to the ICD-10-CM coding manual

Every October, the CDC and CMS release updates to the ICD-10-CM coding manual. These updates include both codes in the tabular and alphabetical indexes as well as official guideline changes. The following is a summary of some of those changes that Home Health Agencies need to know about.
  • Non-pressure ulcers now have 3 new code subcategories to include those ulcers that are down to the muscle or bone but do not have necrosis and for those ulcers that have tendon/ligaments showing. The clinician should always document the severity of the non-pressure ulcer in terms of skin breakdown, fatty layer, muscle exposed, muscle exposed with necrosis, bone exposed, bone exposed with necrosis, or other appropriate descriptive terms (tendon/ligament, hard eschar, slough obscuring wound bed, etc.).
  • C Diff is now being captured as being recurrent or not stated as being recurrent. Recurrence is defined by complete resolution of C diff symptoms while on appropriate therapy, followed by subsequent return of diarrhea and other symptoms after treatment has been stopped. Recurrence usually occurs within one week after treatment stops but may happen up to 8 weeks later. The physician would need to confirm whether C diff is recurrent or not.
  • Types of myocardial infarctions now play a role in determining the appropriate ICD-10 code. Type 1 is the most common MI which is associated with ischemia and due to primary coronary even. Type 2 MI is due to imbalance in supply and demand of oxygen. Type 3, (which we wouldn’t see in home health), is sudden cardiac death, including cardiac arrest. Type 4 MIs are associated with percutaneous coronary intervention while type 5 MIs are associated with a CABG procedure.
  • Secondary pulmonary hypertension diagnosis code has been further detailed to describe what the condition is that is causing the secondary pulmonary hypertension, including left heart disease, lung disease, etc.
  • Lumbar stenosis should be classified with or without neurogenic claudication. Neurogenic claudication is leg pain with walking. The physician must confirm neurogenic claudication for it to be coded.
  • Bowel obstructions can now be captured as complete or incomplete/partial. Complete bowel obstructions would need surgery to correct while incomplete/partial bowel obstructions can be sent home for it to resolve. The coding specialists need to know whether a bowel obstruction is resolved upon discharge from the hospital. Resolved conditions cannot be coded in home health except for in OASIS items M1011 and M1017 when they reflect the patient’s recent history.
  • New coding guidelines state that if a patient’s visual category is not documented then coding specialists can only code unqualified visual loss. It would be beneficial to query the physician to determine patient’s visual category to be more specific with coding of low vision and blindness. Also, the laterality of the low vision and blindness is necessary in retrieving the most specific code.
Along with these changes come the need for increased specificity for diagnoses. To assign specified codes, coding specialists rely on clinicians and physicians to provide adequate detailed information about each diagnosis being listed on the plan of care. Without this important step, coding specialists are left to code only unspecified diagnoses, which could impact reimbursement, or cause a delay in coding as a query may be necessary. To reduce queries to your clinical leadership and clinicians, here are some tips on being proactive with detailed information:
  • Query the provider for specifics that are not included in the physician documentation prior to completing assessment.
  • Specify sites and laterality of wounds
  • Specify etiology of wounds (surgical, traumatic, diabetic, arterial, venous, etc)
  • Query the provider for late effects of CVA if there are none documented in clinical paperwork
  • List the type of MI the patient experienced
  • Always document patient’s smoking/tobacco use status (current or history of, and what product)
  • Don’t list diagnoses on the plan of care that are not actively being addressed or impacting the plan of care
  • If there are diagnoses listed on the plan of care that will likely impact it, but no direct interventions regarding those conditions are present, document how they will impact the POC
  • Document if patient’s substance disorders are in remission per physician documentation or query to determine this.
  • Document the specific type of heart failure a patient has been diagnosed with
  • Specify which type of diabetes a patient has been diagnosed with, and what, if any, manifestations are present.
For the coding specialists to capture more specific diagnoses based on the clinician’s documentation, clinicians should document in the clinical note that this specific information was provided by the physician. Clinicians can document specificity but unless there is verbiage stating that the condition is physician confirmed, the coding specialists cannot code that specific condition. Select Data enjoys working closely with clinicians to provide the codes being captured in the plan of care. It is truly a team- work experience. If you have any OASIS review or Coding questions please call Select Data at 1.800.332.0555.
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians Click here to read more.

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Assigning Diagnoses and Developing a Plan of Care | Select Connects with Clinicians

Events, OASIS-C2, Uncategorized

Assigning Diagnoses and Developing a Plan of Care | Select Connects with Clinicians

Assigning Diagnoses and Developing a Plan of Care


Webinar Overview:

The MD documentation, the diagnoses listed, the OASIS assessment and the plan of care have all got to agree. They are all parts of a cohesive units, or all chapters of the same book. As you go from one part of a patient's documentation to another part of the patient's documentation you should be able to obviously see that they are all describing the same patient. For example: If a patient has some type of wound you should see that wound addressed in the the MD documentation, the diagnoses coding, the OASIS assessment and in the plan of care. To watch the Assigning Diagnoses and Developing a Plan of Care live presentation fill out your name and email address

Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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CoPs Delayed a Proposed 6 Months. Breathe a Sigh of Relief, but Don’t Relax as You Have Much Work to do.

Clinical Practices, Conditions of Participation (CoPs), Healthcare, HIPPA, Legislation, Uncategorized

CoPs Delayed a Proposed 6 Months!!!

Breathe a Sigh of Relief, but Don’t Relax as You Have Much Work to do.

CMS has proposed delaying the new Conditions of Participation (CoPs) for six months, until January 13, 2018.  QAPI  implementation would be required in July, 2018. Though a 60 day comment period is required, it is unlikely that home health agencies will complain and demand to implement the new CoPs sooner, so industry experts are saying we can presume the delay will occur. Agencies have expressed relief as the CoP changes were significant and many HHA expressed concern that there was inadequate time to prepare.  But don’t sit back with this postponement. You have much work to do. The Changes in General The organizational structure of the regulations was changed dividing the general provisions into three subparts: general provisions, patient care, and organizational environment. Certain CoPs were consolidated; i.e. Skilled Nursing, Therapy Services, and Medical Social Services were consolidated into Professional Services. Two CoPs were added; Quality Assessment and PI (QAPI) and Infection prevention and control. Many of the remaining standards were revised significantly: Patient Rights, Comprehensive Assessment, Care Planning/Care Coordination, Home Health Aide, Organization and Administration, Clinical Records, and Personnel Qualifications. The CMS Focus The focus is one of integrated care processes including:
  1. A patient-centered assessment with measureable outcomes.
  2. Patient-specific care planning and service delivery
  3. Agency-specific processes for Quality Assessment and Performance with active Governing Body involvement
  Transforming the CoPs CMS has found that directing a QA approach toward identifying providers that furnish poor quality or failed to meet minimum Federal standards does not always  work. CMS stated, “We have found that this problem-focused approach has inherent limits.” CMS wants to stimulate broad-based improvements in the quality of care delivered to all patients.  They want “Patient-centered, data-driven, outcome-oriented processes promoting high quality care for all patients at all times.” Surveyors are undergoing intensive new training. Some of the Action Items that an Agency May Need to Complete Intensive education for all personnel especially in the areas of patient rights, comprehensive assessment with ongoing POC updates, and patient engagement. Active patient involvement in their POC. New updated Patient Rights Forms with names and addresses and phone numbers of care givers.  Have space on the form for the Patient/Legal Representative to sign. Make certain the new CoP language is included in the Patient Rights form. Have copies of policies regarding admission, transfer, and discharge available for patients that reflect the new standards. Be certain the patient knows the Clinical Manager’s name and number to call with any clinical questions. It is now required under the CoPs to provide the Administrator’s name and number to call with any complaints. CMS is seeking a more “holistic patient assessment.” This means they expect the agency to develop a better understanding of the patient; knowing their strengths and abilities for active involvement in their own care plan and ultimate outcomes. How will your agency ensure this process?  Will it be Integrative Care Management?  Is education and training needed? Educate personnel to identify signs and symptoms of stress in the caregiver as well as how to speak with the caregiver re strain and burdens of care. Will you use a screening tool? Identify where you will note the education and training for patients and their specific needs. A one- size fits all care plan for a specific diagnosis will no longer be sufficient. How will revisions to the care plan be flagged so clinicians know they are working with the most current POC? The POC is to become an “evolving document.” CMS is stressing team care. The new CoPs require agencies to coordinate care delivery. How will your HH interdisciplinary team communicate? “Coordinated care requires communication with integration of orders with all physicians.” A patient hospital risk assessment is required for all HHA admissions.” All patient orders, including verbal orders must be recorded in the POC. They must have not only the date, but the time of the order noted. “The HHA must develop, implement, evaluate, and maintain an effective ongoing, HHA-wide, data-driven program. The HHA governing body must ensure that the program reflects the complexity of its organization and services, involves all HHA services including those services provided under contract or arrangement, focuses on indicators needed to improve outcomes, including hospital admissions and readmissions and takes actions that address the HHA performance across the spectrum of care including the prevention and reduction of medical errors. The HHA must maintain documentary evidence of the QAPI program and be able to demonstrate its operation to CMS.” A plan to educate/ consult with the Governing body re the new CoPs as well as each QAPI project is required. Agency must create new policies and procedures, modify and/or update certain old P&P in keeping with new CoPs and consolidation of certain old standards. Are new job description modifications needed? As to infection control; what new P&P are needed? What surveillance, identification, prevention, control, and investigation program will be put in place to meet the new standard?  Of course this will require further education and training for personnel. As to home health aides: What education and training modifications will be required to meet the new communication requirements? What changes will be needed to the policies, procedures, and job descriptions? What about your agency cybersecurity and Emergency Preparedness Plans? Your system must include a system of medical documentation that preserves patient information, protects confidentiality, and maintains availability of records. So, you may think of the postponement as a reprieve, but it is a short one. As you can see…there is much to do, so get started now. For assistance with your coding, documentation review, and revenue cycle management needs, contact Select Data at 1.800.332.0555. We are  100% USA based, here to assist you.
Related articles New Conditions of Participation (CoPs) and Your Agency Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians webinar on December 14, 2016. Click here to read more. Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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It’s All About The Data


It's All About The Data

Smart Data combined with Smart Clinical Management leads to Smart Care.

Razor thin bottom lines and an increasing demand for improved clinical quality have created a boiler of tension within our industry.  Agencies are struggling with meeting the demands of their referral sources, their patients, and their clinicians.  Technology has given many resources to aid in meeting the needs of the industry but these resources have seldom met both the business and clinical need. This session will offer the attendee insight into the question, “Why, when I have these resources, information at my fingertips, and all of this data; why is it still so hard?” By answering this question, the presenters will engage the audience in a solution that evolved from a process that gleaned insight from cognitive and behavioral sciences, data science and Lean and Six Sigma principles.  That if you take Smart Data and combine it with Smart Clinical Management you provide Smart Care
Check out our FREE 30-minute webinar for OASIS-C2 corrections and more. Select Connects with Clinicians webinar. Click here to read more. Select Data is committed to a strong compliance program that includes educating all personnel on mitigating HIPAA breaches. For more information about Select Data and their commitment to quality in Home Health and Hospice, call 1.800. 332.0555.

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Case Mix Diagnoses Changes in 2015

Coding, OASIS, Uncategorized

What does this mean for your agency?

The 2015 PPS Rule brings many changes including the elimination of case-mix points for nearly 200 codes from pulmonary, psych 1 and 2, as well as blindness/low vision diagnoses categories. OASIS items such as M1200 (Vision) and M2030 (Injectable drug use) will lose case-mix value. In general, there is a reduction of case mix diagnoses for clinical items but high therapy (14+ visits) episodes garner more points.  Industry experts believe we will see more therapy in cases as the reward for higher therapy episodes is there. Other experts believe the trend of declining home health aide utilization will continue as agencies strive to better manage certain cases such as those with high ADL assistance. In certain of these cases, an OT consult, plan, and OT intervention could decrease dependence on an aide and focus more on patient and/or patient caregiver optimal level of functioning and caregiving.

Recalibration of case mix adjuster

The recalibration of the home health case-mix adjuster can have significant impact on individual agencies. From 2000-2014, the 124 variables remained relatively the same, but in 2015 there has been significant change as CMS overhauls the four equation model which has been used to determine clinical and functional points for episodes. The new 124 variable model saw 63 prior variables dropped with 21 new variables added. Collectively, this new model impacts all 153 case-mix categories. (Dombi, 11/19/2014 NAHC Seminar). CMS states the changes are to be budget neutral, however, some home health experts state home health agencies that focus on skilled nursing services with less therapy are likely to experience reimbursement decreases. Many experts have states their surprise at the reward for high therapy episodes. CMS contends the changes occurred because of utilization patterns in 2013 final claims data. This means that one thing is clear, therapists are documenting time spent with the patient better than nurses. They are accustomed to justifying billable time. Nurses are going to need to be more exact as to the tasks and education completed with the patients and families and have the documentation that supports the depth of time spent to achieve the skilled visit.

Coding Guidelines have not changed

The Coding Guidelines have not changed, so coding for COPD, depression or Alzheimers will still occur as appropriate. Those codes just will not garner the case mix points once attached. CMS continues to seek the appropriate portrait be painted of the patient’s conditions and needs.

Additional areas of focus

For instance CMS is honing in on insulin injections being given by home health agencies. CMS expects to see supportive diagnoses that justify why the patient requires agency personnel to administer prescribed insulin. They have identified 164 diagnoses, certain of which they expect to see on final claims when a patient is receiving agency administered insulin injections. Those diagnoses categories include:
  • Cognitive/behavioral conditions
  • Arthritis
  • Vision condition
  • Amputation
  • Effects of Stroke and other disorders of the Central Nervous System
CMS will be monitoring claims of insulin injection administered by the home health agency. More and more, agencies are seeing the need for coding experts. Missing supportive codes could mean ADRs.

Diagnoses with case mix attached

Diagnoses groups that have case mix still attached include:
  • Selected benign neoplasms
  • Cancer
  • Stroke
  • GI disorders with ostomy
  • Heart disease or HTN, not both
  • Ortho conditions
  • Skin ulcers
  • Tracheostomy
  • Urostomy
  • Certain Brain disorders
  • Paralysis

Monitoring Documentation by independent experts

It appears the home health industry will continue to lose further case mix diagnoses if documentation is not substantive to quantify time spent with the patient and family delivering skilled services. Agencies need claims submitted with correct primary diagnosis, supporting diagnoses, and comorbidities.  Who is monitoring the documentation at your agency?  Acquiring revenue is easy. Keeping your revenue through an audit is more difficult. Be certain there is congruence between the codes chosen to describe the patient and the documentation written to describe the patient condition, interventions, and plans. Having third party expert coding specialists can make the difference. To learn more, contact Select Data.

ICD-10 is 10 months away

Remember, ICD-10 is coming. If your agency has difficulty with documentation under ICD-9 CM, ICD-10 CM is far more detailed. Intervene now and prepare for ICD-10. Call Select Data now for more information on how you can be better prepared for ICD-10.

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Home Care ICD-10 Coding | Home Health ICD-10 Coding | Select Data


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