CMS Holds Its November Home Health and Hospice Open Door Forum
November 7, 2015 09:38 AM
The Centers for Medicare & Medicaid Services (CMS) held its Home Health, Hospice & DME Open Door Forum on November 4, 2015. A summary of home health and hospice issues are provided below.
2016 Final Rule for the Home Health Prospective Payment System (HHPPS) Rate Update
CMS officials provided an overview of the 2016 final rule for the HHPPS. The rule implements the third year of the four year phase-in of the rebasing adjustments to the HHPPS payment rates as required by the Affordable Care Act. In addition, CMS will decrease the national, standardized 60-day episode payment amount by 0.97 percent in each year for CY 2016, CY 2017, and CY 2018 to account for nominal case-mix growth between CY 2012 and CY 2014. CMS estimates that the net impact of the payment provisions of the final rule will result in a decrease of 1.4 percent ($260 million) in Medicare payments to HHAs for CY 2016.
Home Health Value-Based Purchasing (HHVBP) model
Effective 1/1/2016, a HHVBP program will be implemented in 9 states: Massachusetts, North Carolina, Maryland, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee. All certified agencies within the state will be required to participate in the HHVBP program. In the final HHPPS rule, CMS modified the maximum payment adjustment percentage range from 5% - 8% to 3% - 8%, which will be phased-in over the length of the program. The selected measures were decreased to 24 from 29. Four process measures and one of the new measures have been eliminated.
CMS recommend participating agencies begin selecting a contact person for the HHVBP program and submit the contact name, phone number, email address and associated agency CCN number to HHVBPquestions@cms.hhs.gov. In addition, agencies may submit question regarding the HHVBP program to the same email address or dial 844-280-5628.
CMS will hosting a webinar on the HHVBP program on Dec. 2, 2015 from 2:00pm - 3:00pm EST. Details on the webinar will be announced on the CMS website and the CMS learning email list.
Home Health Quality Reporting Program
CMS finalized one measure under the skin integrity domain required by the Improving Medicare Post Acute Care Transformation (IMPACT) Act. National Quality Forum (NQF)-endorsed measure: Percent of Residents or Patients with Pressure Ulcers That Are New or Worsened (Short Stay) (NQF #0678) will be included in the HHQRP with the measure reporting period beginning in 2016 impacting payment year 2018.
CMS also finalized an 80% Pay-for-Reporting Performance Requirement for Submission of OASIS Quality Data for Year 2 reporting period July 1, 2016, to June 30, 2017, and a 90% Pay-for-Reporting Performance Requirement for Submission of OASIS Quality Data for the reporting period July 1, 2017, to June 30, 2018, and thereafter.
ICD-10-CM coding guidance
CMS is revising the ICD-10-CM translation list and adding certain initial encounter codes to the HHPPS Grouper based upon revised ICD-10-CM coding guidance. Based upon the 2015 revised coding guidance, certain “initial encounters” codes are appropriate when the patient is receiving active treatment during a home health episode. The HHPPS Grouper logic will be revised to award points for certain initial encounters codes for M0090 dates on or after 10/1/2015. Agencies may resubmit claims for episodes affected by the revised coding guidance once the Grouper is revised.
Home Health Compare (HHC) and Star Rating System
Agencies that have questions related to HHC should contact the ASPEN coordinator for their state. The ASPEN coordinators and contact information can be found here.
The next HHC update is scheduled for Jan, 21, 2016. This refresh will include the initial roll out of the HHCAPHS Star Rating.
CMS clarified that the new G codes to distinguish between services provided by a registered nurse (G0299) and a licensed practical nurse (G0300) will be effective for dates of service on and after 1/1/2016. At that time, code G154 “Direct skilled nursing services of a licensed nurse (LPN or RN) in the home health or hospice setting” will be retired. For claims that span 2016, if the service date is before 1/1/2016 G154 will used and for service dates on or after 1/1/2016 agencies are to use G0299 or G0300.
The IMPACT Act requires the reporting of standardized patient assessment data with regard to quality measures, resource use, and other measures. It further specifies that the data be standardized and interoperable so as to allow for the exchange of data among post-acute care providers to facilitate coordinated care and improve Medicare beneficiary outcomes.
CMS announced opportunities for agency engagement related to the IMPACT Act measure development activities. CMS will post measures that are under development and public comment periods, along with announcements for Technical Expert Panel participation on the Measures Management System website. CMS is currently seeking public comments on the IMPACT Act measure for Potentially Preventable Readmissions for Skilled Nursing Facilities (SNFs), Inpatient Rehabilitation Facilities (IRFs), Long-Term Care Hospitals (LTCHs), and Home Health Agencies (HHAs). The measure description and specifications are located here. Public comments are due November 16, 2016.
In addition, the National Quality Forum, Measures Application Partnership will be holding a web meeting on November 13, 2015, from 2:00pm-3:00 pm EST. The web meeting is open to the public. To register go here.
CMS encouraged hospice providers to review their HIS Final Validation reports in CASPER following submission of HIS records and to print and retain these reports as evidence of successful submission and processing of HIS records. If the hospice finds that there is no Final Validation Report or there is a Final Validation Report with fatal errors, the HIS records were not successfully submitted and the hospice may not be in compliance with reporting requirements and may be subject to a 2% reduction in its annual payment update.
CMS reminded hospices that there are four new HQRP training modules available to assist providers in successfully submitting their Hospice Item Set admission and discharge records to CMS. Each module provides helpful tips including submission instructions, top ten errors, how to access and review the hospice final validation reports, available CASPER reports and suggested uses, as well as where to locate useful technical documentation and QTSO help desk contact information. Providers may access each of the four modules in the downloads section here.
The next data submission deadline for the CAHPS hospice survey is November 11, 2015. CMS suggested that all hospice facilities contact their vendors to be sure the vendor is ready to submit data. Hospices should also check the Hospice Survey Data Warehouse to ensure the data was submitted successfully. It is the hospice’s responsibility to ensure the vendor is submitting data on its behalf timely and that the data is received by CMS. This can be checked through the Hospice Survey Data Warehouse. If a hospice does not have access to the Warehouse, it can apply for credentials for access on the CAHPS hospice website at www.hospicecahpssurvey.org.
The hospice CAHPS manual has been updated to V2.0 which can also be accessed on the hospice CAHPS survey website. The CAHPS Hospice Survey XML File Specification V1.3 has been released and is available on the survey website as well. The Specification manual is primarily for vendors and contains technical information. Also primarily for vendors, but open to the public, was a training call for the CAHPS hospice survey on September 30, 2015. The training slides from this call are available for reviewing or downloading from the CAHPS hospice website (link above).