Tuesday, September 20, 2016

Free Webinar - “Home Health Update: Pre-Claim Reviews are Here And More HHS-OIG Audits are on the Horizon”

Date: Thursday, September 22, 2016 at 1:00 EST (Noon CST)

Summary:  The home health “Pre-Claim Review” demonstration project has now started and will be in place for at least the next three years. How did we get to this point?  Unfortunately, this demonstration project was initiated (in large part) based on the fact that improper payment rate for home health claims has gone 17.3 % in FY 2013 to 51.38% in FY 2014 and 58.95% in FY 2015. While the demonstration project only initially impacts home health agencies in five states, the problems areas noted will likely be pursued by CMS contractors around the country. Is your home health agency ready for this level of scrutiny?

The delay in the Pre-Claim Review moving forward to other states gives us the opportunity to learn from what has already happened.  It also shows how we can apply so of what we have learned to improve our home health documentation.

In addition to the program integrity initiative already underway, HHS-OIG has also ramped up its review of home health agency claims and has expressly advised agencies that they intend to seek extrapolated damages of any overpayments identified. We anticipate a new round of home health audit letter to be sent to agencies in Fiscal Year 2017 (Starting October 1, 2016).  What is HHS-OIG looking for?  Join us as we discuss this initiative and how your agency should respond if selected for audit.

Moderator: Richard Dixon
Speakers:  Robert W. Liles and Adam Bird.

Duration:  This webinar is scheduled for 60 minutes with a Q & A session to follow.

Liles Parker PLLCPresented by:    Liles and Parker, Attorneys and Counselors at Law

              Sponsored by:   Dixon Healthcare Solutions

Cost: Registration is free for Dixon Healthcare Solutions and Liles Parker clients and friends of the firm.

By signing up for this webinar, you permit Liles Parker to share your registration information with Dixon Healthcare Solutions.  You will also be placed on Liles Parker’s newsletter distribution list.

Questions? Please call Liles Parker with your questions, comments, and feedback at: 202-298-8750.

How to Register and Join the Webinar:

1.      Please register in advance for the webinar by clicking the following link:

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3.      Choose one of the following audio options:
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TO USE YOUR TELEPHONE: If you prefer to use your phone, you must select “Use Telephone” after joining the webinar and call in using the numbers below.
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Access Code: 648-175-423
Audio PIN: Shown after joining the webinar
Webinar ID: 591-369-515

CMS Places Expansion of Pre-Claim Audit on Hold

In an abrupt turn around CMS announced yesterday that the expansion of the Pre-Claim Audit for home health agencies in the states of Florida, Texas, Massachusetts, and Michigan has been placed on hold.  CMS intends to provide at least a 30-day notice before that move forward. 

CMS stated the delay is based on the early information from the state of Illinois.  They also indicated that additional education is needed before they can expand this program to the other states.

We can thank the various trade organizations, members of Congress, and public outcry for this delay.  Unfortunately, the program is still moving forward in Illinois.  We all need to continue to press our members of Congress to stop the program in Illinois and make the necessary changes before the program moves forward.  A letter from both Florida US Senators, they recommend if the program moves forward it should be scaled down approach with a random sample of a small number of claims.

Dixon Healthcare Solutions, Inc., has received information that the program is flawed with many failures points.  Some agencies are receiving a denial rate of 80% on their initial reviews.  The MAC (Palmetto GBA) has lost paperwork.  It is taking hours to submit the paperwork.   The MAC’s claim review workload has increased by 40 to 50 times.   The whole program is a mess.

Link to CMS Announcement

Tuesday, September 6, 2016

CMS Finalizes Hospice CAP for 2016 - 9/6/2016

CMS issued the final Per Beneficiary Hospice CAP for 11/1/2015 to 10/31/2016 amount of $27,820.75.  Remember you are required to complete your Hospice CAP Report for period 11/1/2015 to 10/31/2016 by March 31, 2017.  CMS is also changing the Hospice CAP Year to coincide with the federal fiscal year beginning 11/1/2016.  There will be a short period beginning 11/1/2016 to 9/30/2017.  All other Hospice CAP years will then begin in October 1st each year and end September 30th.
We have helped several clients complete their Hospice CAP Reports for a nominal fee in the past.  We have found that many hospices have trouble managing the per beneficiary cap.  We will be providing some new tools to manage the hospice cap to attendees of our “New Directions in Hospice Care” seminar to be held at Bally’s Las Vegas on January 26th to 27th.

Final Link


Tuesday, July 12, 2016

OIG Places 562 Home Health Agencies and 4,500 Physicians on Red Flag List - 7-12-2016

In June the Office of Inspector General of the Department of Health and Human Services issued a nationwide analysis of common characteristics in OIG home health fraud cases.  470 home health agencies had an unusually high percentage of home health episodes for which the beneficiary had no recent visits with the supervising physician.  483 home health agencies had an unusually high percentage of home health episodes with primary diagnosis of diabetes or hypertension.  770 home health agencies were outliers on the percentage of beneficiaries who received home health care from 3 or home health agencies over the course of 2 years.  778 home health agencies had an unusually high percentage of beneficiaries with multiple home health readmissions in a short period of time.  Listed below two tables of home health information:

Home Health Agencies Outlier Characteristics
# of Agencies
Outliers on 2 characteristics
Outliers on 3 characteristics
Outliers on 4 characteristics

Home Health National Medians and Outlier Thresholds
Outliers as a
of Total
No recent visit with the supervision physician




Diabetes of hypertension diagnosis




Beneficiaries with claims from multiple HHAs




shortly after discharge





Where does your agency stand with these Characteristics?

For more information, please go to:


Friday, July 8, 2016

Proposed Home Health LUPA Payment Rates 2017

Home Health episodes that have four or less visits are paid a LUPA rate instead of an episode rate.  Listed below are the National LUPA Payment Rates.  Remember these rates will be adjusted for each home health agencies wage index.

Listed below are the LUPA Payment Rates Per Discipline

Urban Agencies
Quality Data
Urban Agencies
Not Submitted
Quality Data

Rural Agencies
Quality Data
Rural Agencies
Not Submitted
Quality Data

LUPA Episodes are paid a higher rate for the first visit of the episode.  Listed below are the payment rates for the first visit of LUPA episodes

Urban Agencies
Quality Data
Urban Agencies
Not Submitted
Quality Data

Rural Agencies
Quality Data
Rural Agencies
Not Submitted
Quality Data

To view the rule please go to:


Proposed Home Health PPS Rules & Rates for 2017 - 7/5/2016

CMS has issued the Proposed Home Health PPS Rules & Rates for 2017 late Tuesday July 5th.  The overall impact is to reduce home health payment by 1% or $180 million in 2017.  This is the first of several email alerts that we will publish this week on the information contained in the proposed rules & rates for 2017. 
2017 National Standardized 60-Day Episode Rate   $2,936.68

The national standard 60-day episode rate is the basis for all home health payments.  Home health agency patients living in a rural area have the 3 percent add on which is scheduled to expire on January 1, 2018.  Home health agencies that do not submit quality data will have the above rates reduced by an additional 2 percent. 

Proposed National Urban Agency Rate                                               $2,936.68
Proposed Urban Agency Rate That Do Not Submit Quality Data      $2,879.27
Proposed Rural Agency Rate                                                               $3,024.78
Proposed Rural Agency Rate That Do Not Submit Quality Data        $2,965.65

Your individual home health agency rate will also be adjusted by location wage index. 

Other items included in the proposed rule:

1.       Changes to the outlier program computations
2.       New payment measures to meet (IMPACT) 2014
3.       Changes in the HHVBP Model
4.       Changes in Case-Mix Weights



Friday, June 17, 2016

How to Stop Pre-Claim Demonstration for Home Health Services - 6/17/2016

We know we all feel CMS has lost their mind trying to implement the Pre-Claim Demonstration for Home Health Services.  This program can only be stopped by the 46 million senior citizens in the country and other concerned citizens.  Congress and the President do not really care about the home health industry’s opinion of the program.  But they do care about the opinion of the 46 million senior citizens and other concerned citizens that will be voting in November. 

If you really want to stop the program listed below is a simple but effective game plan:

  1. Have all of your patients, family members of your patients and friends of your patients contact their two US Senators, their Congressman, and the President of the United States.
  2. Have all of your employees, family members of your employees and friends of your employees contact their two US Senators, their Congressman, and the President of the United States.
  3. Notify your local TV, Radio, Newspapers, community leaders, elderly spokesman, churches and synagogues.  

What do the above people need to say about the Pre-Claim Demonstration for Home Health Services? 

  1.  It will put patient care at risk if home health providers have to wait for approval of care.
  2. At a time when we try to reduce the cost of Medicare, it will cause longer hospitalizations and nursing home stays and reduce lower cost home health stays.
  3.  It will be a huge raise to the administrative cost of the Medicare program at a time when we need to focus on providing patient care.
  4. The Medicare Administrative Contractors do not have the staff needed to implement the program.
  5. It will waste administrative dollars targeting all home health agencies, instead of the potential abusers in the industry.
  6. While the Medicare coverage of home health will appear to the beneficiaries to be unchanged the reality is it will be another barrier the administration is placing on home care benefits. 

We believe that if we can get the public to raise the above to their Congressman, Senators, and the President of the United States that we have an opportunity to stop this program.