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NAHC Report: Issue# 2465, 7/11/2014
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NAHC’s Intervention Aids in Halting OASIS Audit
Hospices Encouraged to Download their PEPPER Reports
For Your Information: Next National Council on Medicaid Home Care Call with the Experts Set for July 24, 2014/a>
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NAHC’s Intervention Aids in Halting OASIS Audit

The Centers for Medicare & Medicaid Services (CMS) has informed the National Association for Home Care& Hospice (NAHC) that the Outcome and Assessment Information Set (OASIS) submission audit conducted in the New England states has been suspended. CMS has instructed Strategic Health Solutions (SHS) to begin issuing record request cancellation letters to the providers from whom they have requested records

In a recent NAHC Report article, NAHC reported that the Supplemental Medical Review Contractor (SMRC), SHS, had initiated an audit of home health agencies in New England states with a focus on OASIS assessments submitted in 2010.  The audits were triggered by a recent OIG study that found a high incidence of Medicare paid claims where the home health agency did not have an accepted OASIS prior to the date of billing.

NAHC contacted CMS officials to discuss the validity and appropriateness of these audits. NAHC informed CMS of concerns that the audit included the re opening of claims that were 3-4 years past payment and that HHAs are not required to retain OASIS validation reports. CMS itself does not retain the validation reports beyond one year. In the audits, HHAs were at risk for retroactive claims denials because they could not produce the evidence necessary to demonstrate compliance.

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Hospices Encouraged to Download their PEPPER Reports

The Texas Medical Foundation (TMF) Health Quality Institute, the Quality Improvement Organization (QIO) in the state of Texas and developer of the Program for Evaluating Payment Patterns Electronic Report (PEPPER), recently issued notice regarding hospices’ access of the most recently-issued PEPPER report.    

The current release - version Q4FY13 - of the PEPPER for hospices has been available for download through the Secure PEPPER Access page since April 21, 2014. As of June 30, only 38 percent of the 3,030 hospice PEPPERs have been accessed.

TMF encourages hospices that have not yet obtained their PEPPER to access the report, which can be done by having the Chief Executive Officer, President or Administrator: 

  1. Review the Secure PEPPER Access Guide.
  2. Visit the Secure PEPPER Access page at
  3. Review the instructions and obtain the information required to authenticate access.
  4. Click on the button to access the Secure Portal.
  5. Complete all the fields.
  6. Download your PEPPER as a Microsoft Excel file. 

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Next National Council on Medicaid Home Care Call with the Experts Set for July 24, 2014

On Thursday, July 24, 2014 the National Council on Medicaid Home Care will host it’s next “Call with the Experts” teleconference. This is a regular call for Council members hosted by the Council where subject matter experts provide valuable information on crucial issues facing Medicaid home care.

The focus of the July call will be the recently released report: Medicaid Expenditures for Long-Term Services and Supports in FFY 2012. The report will be presented by lead author, Paul Saucier and project director, Effie George.

The report was created by a team at Truven Health Analytics where Mr. Saucier serves as Director, Integrated Care Systems. Ms. George works at the CMS in the Disabled and Elderly Health Programs Group, Division of Community Systems Transformation. Together they will provide some background for the report and will detail the findings contained within the report. For those who wish to review the report prior to the call, it can be found here.  

This teleconference is set for Thursday, July 24, 2014 at 3:00PM-4:00PM EST.

The teleconference is open to all Medicaid Council members without charge. Feel free to include any and all of your staff. The teleconference will include two-way communication capabilities.

To access the teleconference:

Call-in: 877-722-1471

Passcode: 1189334780

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