NAHC Participates in a CMS Home Health, Hospice and Durable Medical Equipment Open Door Forum
July 12, 2013 09:43 AM
Earlier this week, the Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice, and Durable Medical Equipment (DME) Open Door Forum. The Natioanl Association of Home Care & Hospice (NAHC) participated in the Forum, during which the following issues in hospice and home health care were discussed.
Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS)
On July18, three important events will occur related to HHCAHPS:
Home Health Compare will be update to reflect data reported from January 2012 through December 2012 (CY 2012 Q1-Q4).
Patient mix adjustment factors are scheduled to be updated; and
Data submission deadline for the 1st quarter of 2013 are due.
Medicare-certified home health agencies (HHAs) that served 59 or fewer unduplicated patients from April 1, 2012 through March 31, 2013 who met HHCAHPS survey-eligibility criteria are eligible for an exemption from participating in the HHCAHPS Survey for the calendar year (CY) 2015 annual payment update (APU).
The deadline for requesting an exemption from HHCAHPS for CY 2015 is January 16, 2014.
Home Health Prospective Payment System (HHPPS) Rate Update: Proposed Rule
CMS issued a proposed rule to update Medicare's HHPPS payment rates and wage index for CY 2014. As required by Section 3131(a) of the Affordable Care Act (ACA), this rule proposes rebasing adjustments - with a 4-year phase-in - to the national, standardized 60-day episode payment rates, the national per-visit rates, and the NRS conversion factor.
Payments to HHAs are estimated to decrease by approximately 1.5 percent in CY 2014, reflecting the combined effects of the 2.4 percent home health payment update percentage, the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, the NRS conversion factor, and the effects of ICD-9 coding adjustments. 170 ICD-9 codes have ben removed that are for conditions either too acute to be appropriately cared for in a home health setting or would not impact the home health POC or result in additional resource use.
This proposed rule would also establish home health quality reporting requirements for CY 2014 payment and subsequent years and would specify that Medicaid responsibilities for home health surveys be explicitly recognized in the State Medicaid Plan, which is similar to current regulations for surveys of Nursing Facilities (NF) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IID).
Additionally, this proposed rule also seeks comment on a methodology for calculating state Medicaid programs’ fair share of HHA survey costs. Finally, this rule proposes to describe the transition to ICD-10-CM coding and announces the release of draft lists of ICD-10-CM codes to be included in the HH PPS Grouper.
Comments are due August 26, 2013. To view the proposed rule click here.
Home Health Quality Update
The draft Outcome and Assessment Information Set (OASIS) C-1 has been released and can be found here. Comments on the draft OASIS-C1 are due August 20, 2013
The technical specifications for the Process Quality Measures have been revised, and are available here
The technical specifications for the Outcome Based Quality Improvement measures have been revised and are available here
An OASIS Guidance Manual errata has been posted and is available here
Continuous Positive Airway Pressure (CPAP) documentation
Suppliers have been having difficulty obtaining all the required documentation for CPAP with the implementation of Round 2 of competitive bidding. Round 2 of the competitive bidding program went in to effect July 1, and expands the competitive bidding areas for certain DME items to 91 MSA areas.
CMS is permitting a 120-day grace period for written physician orders for CPAP in order to help with the transition. Suppliers are encouraged to review the Medlearn Matters (MLM) document that provides guidance to the required documentation for CPAP for Medicare beneficiaries.
Click here to view the MLM guidance document.
Home Health Advanced Beneficiary Notice (HHABN)
The revised HHABN which replaces Option Box 1 with the General ABN and Option Box 2 and 3 with the Home Health Change of Care Notice (HHCCN) has been cleared by the Office of Management and Budget and should be available on the CMS web site soon. Agencies will have 60 days after its’ release to transition to the new forms.
Hospice Quality Update
The next Hospice Quality Reporting Program (HQRP) reporting deadline is April 1, 2014. Hospices will be required to have submitted both the NQF pain measure (#0209) and a modified structural measure by that date or risk a 2 percentage point reduction in their fiscal year 2015 payment update.
Providers should be collecting data on #0209 for all patients, and should continue to collect such data through December 26, 2013 for submission.
A user guide and presentation to assist hospice providers in fulfilling the 2014 reporting requirements will be available later this summer. Additional details will be published in NAHC Report and on the NAHC member listserv as they become available.
Hospice Vendor Call
CMS’ Division of National Systems has scheduled a technical information call for hospice software vendors and developers for the Hospice Item Set (HIS) on Tuesday, July 16, 2013, from 2:00 P.M. to 3:30 P.M. EST.
The call-in number is 1-866-712-2205 and the conference code is 4260581739.
CMS strongly recommends that all hospice software developers/vendors participate in this call and review the Technical Data Submission Specifications (v1.00.0) related to the submission of Hospice Item Set (HIS), anticipated to be required effective July 1, 2014.
Software developers/vendors are also encouraged to submit questions in advance to the Hospice Technical Issues Mailbox by 6 P.M. EST on Friday, July 12, 2013. Please note that the subject line must read: “VENDOR CALL”
Please note that a previous notice indicated questions must be submitted by COB of July 9. CMS has since extended the deadline.
Additional information about the call is available here.
Requirements for Long-Term Care Facilities and Hospice Services
Late last month, CMS published a rule finalizing requirements for a written agreement betweenl ong-term care facilities (LTCF) that choose to arrange hospice services and a hospice provider.
The agreement specifies the roles and responsibilities for each provider type. While the LTCF rule was developed to be mirror image of the requirements established for hospices under the 2008 Conditions of Participation, it did undergo some changes through the notice and comment process, including a revision that requires the LTCF to alert the hospice immediately when any transfer of a hospice patient occurs - rather than just when a transfer occurs that is related to the terminal diagnosis, as was included in the proposed rule.
Hospices are encouraged to coordinate with their LTCF partners to ensure that the written agreements meet both the hospice and LTCF requirements.
During the question and answer period, one listener commented that some hospice providers have indicated that LTCFs are requesting separate written agreements that govern care for each patient rather than a single written agreement that governs care of all patients that are provided hospice services in the facility, and asked if CMS has any guidance or position on the issue.
CMS responded that as long as the contracts meet the requirements, LTCFs may structure them as they see fit. CMS is interested in hearing any concerns that may result from this type of arrangement.
NAHC is seeking additional guidance from CMS on this issue.