CMS Holds its Latest Home Health, Hospice and DME Open Door Forum
November 18, 2014 02:29 PM
The Centers for Medicare & Medicaid Services (CMS) recently hosted its most recent Home Health, Hospice, and DME Open Door Forum. A summary of Home Health issues covered is provided below. A summary on the hospice issues that were addressed during the ODF will appear in tomorrow’s NAHC Report.
Home Health Conditions of Participation (HHCoPs)
The proposed rule for the HHCoPs was released October 9, 2014. There is a 60 day open comment period. Comments are due December 8 and can be submitted here.
2015 home health prospective payment system (HHPPS) rate update
On October 30, CMS issued the final rule for the 2015 HHPPS rate update. In the rule, CMS projects that Medicare payments to home health agencies in CY 2015 will be reduced by 0.30 percent, or $60 million. This decrease reflects the effects of the 2.1 percent market basket update and the second year of the four-year phase-in of the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, and the non-routine medical supplies (NRS) conversion factor.
The rule implements a 3.5 percent increase to the national per-visit payment rates, a 2.82% reduction to the NRS conversion factor, and a reduction to the national, standardized 60-day episode rate of $80.95 for CY 2015. The national, standardized 60-day episode payment for CY 2015 is $2,961.38.
HH PPS case-mix weights
CMS is recalibrating the HH PPS case-mix weights using CY 2013 home health claims data to ensure that the case-mix weights reflect the most current utilization and resource data available.
Core Based Statistical Area (CBSA) changes for the HH wage index
CMS is finalizing changes to the wage index based on the revised CBSA delineations for the CY 2015 HH PPS wage index. These changes will be made to the wage index using a blended wage index for a one-year transition. For each county, a blended wage index is calculated as 50 percent of the wage index using the current OMB delineations and 50 percent of the wage index using the revised OMB delineations.
CMS finalized three changes to the face-to-face encounter requirements for episodes beginning on or after January 1, 2015. First, CMS is eliminating the narrative requirement currently in regulation. The certifying physician would still be required to certify that a face-to-face patient encounter occurred and document the date of the encounter as part of the certification of eligibility. For medical review purposes, CMS will require documentation in the certifying physician’s medical records and/or the acute/post-acute care facility’s medical records (if the patient was directly admitted to home health) to be used as the basis for certification of patient eligibility.
Second, CMS is finalizing that if a HHA claim is denied, the corresponding physician claim for certifying/re-certifying patient eligibility for Medicare-covered home health services is considered non-covered as well.
Lastly, CMS is clarifying that a face-to-face encounter is required for certifications, rather than initial episodes; and that a certification - versus a re-certification - is generally considered to be any time a new start of care assessment is completed to initiate care.
CMS is finalizing the elimination of the 13th and 19th visit reassessment requirements. For episodes beginning on or after January 1, 2015, at least every 30 calendar days a qualified therapist - instead of an assistant - must provide the needed therapy service and functionally reassess the patient.
CMS is hosting a National Provider Call - Certifying Patients for the Medicare Home Health Benefit on December 16, 2014 at 1:30 pm ET. To register click here.
CMS has established a minimum submission threshold for the number of OASIS assessments that each HHA must submit in order to receive the full annual payment update. Beginning in CY 2015, the initial compliance threshold will be 70 percent. This means that HHAs will be required to submit both admission and discharge OASIS assessments for a minimum of 70 percent of all patients with episodes of care occurring during the reporting period. CMS will increase the compliance threshold over the next two years to reach a maximum threshold of 90 percent.
Home Health Value-based Purchasing Model
The HHA VBP model being considered would include a five to eight percent adjustment in payment made after each planned performance period in the projected five to eight states selected to participate in the model. A HHA VBP model presents an opportunity to test whether larger incentives would lead to higher quality of care for beneficiaries.
If CMS decides to move forward with the implementation of an HHA VBP model in CY 2016, it intends to invite additional comments on a more detailed model proposal to be included in future rulemaking
Conditions of Participation for speech-language pathologists
CMS has revised the Home Health Conditions of Participation (CoPs) for speech language pathologist (SLP) personnel. Now, a qualified SLP is an individual who meets one of the following requirements: a) has a masters’ or doctoral degree in speech-language pathology, and is licensed as a speech-language pathologist by the state where they furnish services (CMS believes that all states license SLPs; therefore all SLPs would be covered by this option); or b) has successfully completed 350 clock hours of supervised clinical practicum (or be in the process of completing these hours), has at least nine months of supervised full-time speech-language pathology experience, and has successfully completed a national examination approved by the Secretary.
These requirements, which align with the requirements in the Social Security Act, will replace the current stringent requirements.
Outcome and Assessment Information Set (OASIS) and Quality Measures
CMS officials also reported that the OASIS C1/ICD- 9 has received approval from the Office of Management and Budget and is posted on the CMS Home Health Quality Initiative website site. To view the website, please click here.
Public reporting for the claims based re-hospitalization measure is scheduled for the July, 2015 release of home health compare.
CMS announced a new email address for questions related to quality measures, Homehealthqualityquestions@cms.hhs.gov.
Conversion to Assessment Submission and Processing (ASAP) System
Officials reminded participants that OASIS submissions to the state system will discontinue starting at 6:00 p.m. ET on December 26, 2014. The HHA state submission system will no longer be used for OASIS submissions. New, modification, or inactivation records in the current flat file format must be submitted prior to 6:00 p.m. ET on December 26, 2014.
Effective January 1, 2015, OASIS assessment data will be submitted to CMS via the Assessment Submission and Processing (ASAP) system. With the implementation of the OASIS ASAP system, Home Health Agencies will no longer submit OASIS assessment data to CMS via their state databases.
CMS released Change Request 8950 - Correction to Remittance Information When HIPPS Codes are Re-coded by Medicare Systems here . The CR instructs contractors to include remittance advice code pairs to claims where currently only a remittance advice remark code (RARC) is used. In addition, HIPPS codes that are changed based on validation with QIES data are not currently displayed to providers on Direct Data Entry (DDE) screens. They are also not being sent to the remittance advice. The requirements below also ensure the HIPPS code used for payment is displayed appropriately.