CMS Holds Its July Home Health and Hospice Open Door Forum
July 13, 2015 09:48 AM
The Centers for Medicare & Medicaid Services (CMS) hosted its Home Health, Hospice, and DME Open Door Forum on July 8. A summary of home health and hospice issues are provided below.
2016 Home Health Payment Rate Update
The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (CMS-1625-P) that would update the Medicare Home Health Prospective Payment System (HH PPS) rates and wage index for calendar year (CY) 2016. In the CY 2016 proposed rule, CMS is implementing the third year of the four-year phase-in of the rebasing adjustments to the HH PPS payment. A 2.3 % basket market update is proposed along with a decrease in the national, standardized 60-day episode payment amount by 1.72 percent in each year for CY 2016 and CY 2017 to account for nominal case-mix growth between CY 2012 and CY 2014.
In addition, CMS recalibrated the case mix weights, again, for 2016 and plans to implement annual case mix weight adjustment as part of the payment rate updates. CMS officials announced that the recalibrated case mix weights (Table 9) issued in the propose rule contains errors. CMS has re-issued Table 9 and is posted on the web site. Finally, CMS is proposing to implement a Home Health Value-Based Purchasing (HHVBP) model effective for CY 2016. CMS estimates that the net impact of this proposed rule would result in a decrease in Medicare payments to HHAs of 1.8 percent ($350 million decrease) for CY 2016.
Home Health Value-Based Purchasing (HHVBP)
CMS proposes to launch a HHVBP program the will be implemented in all agencies in nine randomly selected states, which represents the national population of all HH agencies. The program will run for five years with payment adjustments up to 5 % in the first and second years; 6% in the third year; and 8% in the four and fifth years. CMS is proposing to use 25 quality measures derived from the OASIS, HHCAHP and claims, along with four new quality measures.
Home Health Quality Reporting Program (HHQRP)
CMS is proposing to require one standardized cross setting new measure for CY 2016 to meet the requirements of the Improving Medicare Post-Acute Care Transformation Act (IMPACT Act): Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678).
HHQRP for OASIS requires that agencies submit 70 % of quality assessments for the first reporting or year, which begins July 1, 2015 –June 30, 2016 in order to receive the full annual payment update (APU) for CY 2017. Agencies have been provided informational reports via CASPER that show historical data for the previous years, but have no impact on the current year’s performance. These reports will remain in agency’s CASPER folder for 120 days, until Oct 25, 2015.
The first round of the Star Rating for home health agencies on HHC is scheduled for July 13. In April, agencies were provided preview reports of their rating through the CASPER folder that were removed in early June. At the industry’s request, these reports have been returned to the CASPER folder for another 120 days. These reports are refreshed every quarter. CMS recommends that for long-term retention, agencies should download their reports.
The next round for Star Rating reporting on HHC is scheduled for Oct 8, 2015. The new set of preview reports that were distributed June 30 have been removed due to errors. CMS will be distributing new reports to agencies on July 10.
For questions or concerns related to accessing reports from the CASPER system, contact the QTSO help desk at 800-339-9313 or email them at Help@qtso.com
Questions regarding quality reporting and reports should be addressed through a new CMS email address: Homehealthqualityquestions@CMS.HHS.gov
A star rating for the HHCAHPS is scheduled to begin on January 1, 2016. CMS will be providing agencies with a “dry run” report on the HHCAHPS Star Rating in September. This information will not be publicly reported.
Outcome and Assessment Information Set (OASIS)
OASIS C1/ICD-10 has been approved by the Office of Management & Budget and is now available on the CMS web site.
Two claims processing transmittals have been released. Change Request (CR) 9192is the quarterly update of HCPCS codes used for HH consolidated billing. CR 9198corrects errors in the 2015 HH Pricer program. The revised Pricer is scheduled to be installed in Oct 2015 and will include regrouping logic and instructions. Agencies will not need to take any action; claims will be adjusted at the contractor level.
Officials reminded participants of Medlearn Matters article SE 1410which provides special instructions for home health agencies related to the ICD-10 transition.
During the Question and Answer session of the call, a caller inquired about what would be acceptable practice for compliance with the requirement that the physician provide an estimate of how much longer the skilled services will be required for recertifications. The caller asked if an agency received a verbal order for the duration of services, could the agency add the duration to the recertification statement for physician signature in order to meet the requirement. The CMS official indicated that they would be open to such a process but will review the issue and provide further guidance.
CMS is currently reviewing comments submitted on the proposed FY2016 payment update/HQRP update and expecting the final version of the rule to be publishedaround August 1, 2015. A question was asked regarding how soon after publication of the final rule there would be instructions available for the billing/payment changes. CMS responded that an update to the Medicare Claims Processing Manual is expected to be issued as soon as possible after the final rule - perhaps within a couple of days.
Related to the hospice CAHPS survey, hospices with fewer than 50 survey-eligible decedents during the period January 1-December 31, 2014 may file for a 1-year size exemption from the hospice CAHPS survey and must do so by August 12, 2015. Any exemptions granted are good for one year only. Hospices will find the exemption request form at: http://www.hospicecahpssurvey.org/content/ExemptionSizeForm.aspx
The deadline for survey vendors and hospices to submit the 2015 access to CAHPS Hospice Survey Data Warehouse Form was July 1, 2015. This form is required to obtain user account information and be granted access to the CAHPS Hospice Survey Data Warehouse. CMS states that those providers who have not yet completed and submitted this request may still do so. The link for the form is: http://www.hospicecahpssurvey.org/Content/TechnicalSpecifications.aspx
Hospices must ensure their respective CAHPS Hospice Survey vendors have set up procedures necessary for data submission as no late submissions can be accepted and submissions are how CMS tracks compliance for hospices to determine if the hospice will receive its full annual payment update.