HHS Releases Proposed Incentives for Nondiscriminatory Wellness Programs

This document proposes amendments to regulations, consistent with the healthcare reform bill, regarding nondiscriminatory wellness programs in group health coverage.  These proposed regulations would increase the maximum permissible reward under a health-contingent wellness program offered in connection with a group health plan from 20 percent to 30 percent of the cost of coverage.  They also propose a further increase to maximum permissible reward to 50 percent for wellness programs designed to prevent or reduce tobacco use.  They also clarify reasonable design of health-contingent wellness programs and the reasonable alternative they must offer in order to avoid prohibited discrimination.  

The full proposed rule can be viewed using the following link:

http://www.gpo.gov/fdsys/pkg/FR-2012-11-26/pdf/2012-28361.pdf

HHS Releases Proposed Standards Related To Essential Health Benefits

Beginning January 1, 2014 the healthcare reform bill will require health insurance companies to maintain a single, statewide pool for all of their individual health plans.  They may actually combine their small employer market group with the individual health plan into a single statewide pool.  This ensures that insurance premium rate increases would be based on the entire risk pool.  This prevents insurance companies from carving up a state to place higher risk people in single groups to achieve higher premiums.  This proposed rule also includes provisions for health insurance companies to develop catastrophic health insurance plans for the individual market for young adults and people who qualify for the catastrophic health insurance plan.

It also provides a list of the 10 categories that must be included in the core package of essential services.  It identifies the four health insurance plan types which are: the bronze plan which covers 60% of the cost, a silver plan that covers 70% of the cost, a gold plan that covers 80% of the cost and a platinum plan that covers 90% of the cost.  It also establishes the maximum out of pocket cost and in network versus out of network coverage.

The full proposed rule can be viewed using the following link:

http://www.gpo.gov/fdsys/pkg/FR-2012-11-26/pdf/2012-28362.pdf

HHS Releases Proposed Healthcare Reform Regulations

Beginning January 1, 2014 it will be illegal for health insurance companies to discriminate against people who have pre-existing conditions.  Insurance companies will be able to vary health insurance premiums based on family size, tobacco use, geography, and by age.  The age variance is based on the 64 year old people paying only three times more than a 21 year old person.  Health insurance companies can no longer use claim history, gender, health status or occupation to increase premiums.

The full proposed rule can be viewed using the following link:

http://www.gpo.gov/fdsys/pkg/FR-2012-11-26/pdf/2012-28428.pdf

CMS Publishes Home Health Wage Index for 2013

CMS published the Home Health Wage index for 2013.  Since the Home Health PPS Rules increase the percentage of cost related to salaries and benefits by 1.453%.  This makes the changes in the wage index more important on payment rates for 2013.  The table below shows the potential impact of the changes in the Home Health Wage index for 2013.

Wage Index Changes FY 2013 Compared to FY 2012	Rural Areas	Urban Areas
Payment Decrease by over 5%	3	22
Payment Decrease between 2% and 5%	9	78
Payment Decrease between 0% and 2%	23	131
Payment Increase between 0% and 2%	12	89
Payment Increase between 2% and 5%	1	52
Payment Increase by over 5%	1	19

Listed below is the link for the Home Health Wage Index for 2013:

http://www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html?redirect=/center/hospice.asp

Please click on CMS-1358-F

If you have questions or need additional information please call Richard Dixon at (321) 473-8561.

Hospice Quality Measures Reporting included in Final Medicare Home Health PPS Update for 2013

CMS has announced the publication of the Final PPS Rules and Rates for 2013.  This update includes information on the Hospice Quality Measures Reporting. 

For data collection period 10/1/2012 to 12/31/2012 the data must be submitted by 1/31/2013.  This will impact hospice payments for FY 2014.  The first item will be the National Quality Forum (NQF) - endorsed measure related to pain management (NQF #209).  This data will be gathered at the patient level, but is reported in the aggregate for all patients.  They also must report Participation in a Quality Assessment and Performance Improvement (QAPI) program that includes at least three quality indicators related to patient care.  They are also required to check off from a list, from a list of topics, all patient care topics which they have at least one QAPI indicator.

Beginning January 1, 2013 all quality measures will be reported on an annual basis.  CMS will provide a Hospice Data Submission Form to be completed using a web-based data entry site.

CMS will provide additional information at the CMS website.  Hospices will be required to report on NQF #209. They also must report Participation in a Quality Assessment and Performance Improvement (QAPI) program that includes at least three quality indicators related to patient care. For data collection period 1/1/2013 to 12/31/2013 the data must be submitted by 4/1/2014.  This will impact hospice payments for FY 2015. 

CMS is in the process of developing required measures to include NQF 1634, 1637, 1638, 1639, and 0208.  They are also working on a standardized assessment instrument to be utilized to capture all the data for each patient.  This would be similar to OASIS data set utilized in the home health industry.  This standard data set could be implemented as soon as 2014.  They are also considering future implementation of measures based on an experience of care survey such as the Family Evaluation of Hospice Care Survey (FEHC).  This could be implemented in the year prior to the standard data set or the year after the standard data set.  They specifically stated they would not implement both in the same year.

Listed below is the link for the final rule. 

http://www.gpo.gov/fdsys/pkg/FR-2012-11-08/pdf/2012-26904.pdf  

If you have questions or need additional information please call Richard Dixon at

(321) 473-8561.

CMS Publishes Final PPS Rules and Rates for Home Health Agencies

CMS published the final Home Health Prospective Payment Rates for 2013 on November 8, 2012. They made some small changes from the proposed rules including reducing the inflation rate from 1.5% to 1.3%. The also changed the Fixed Dollar Loss Ratio from .67 to .45 to increase the Medicare Outlier payment to 2.5%.  The most detailed change relates to the survey and certification areas. Please carefully read this section of the final rules.

Listed below are the basic revised payment rates:

Description	Final Urban Episode Base Rate For 2013	Final Rural Episode Base Rate For 2013
Base Payment Rates (1)	$2,137.73	$2,201.86

(1)     This must be adjusted by wage index and case mix

LUPA Rates	Urban LUPA Base Rate	Rural LUPA Base Rate
Skilled Nursing (2)	$114.35	$117.78
Physical Therapy (2)	$125.03	$128.78
Occupational Therapy (2)	$125.88	$129.66
Speech Pathology (2)	$135.86	$139.94
Medical Social Services (2)	$183.31	$188.81
Home Health Aide (2)	$51.79	$53.34
LUPA Add On (2)	$95.85	$98.73

(2)     This must be adjusted by wage index

Please remember that all of the above payment rates will be reduced by 2 percent for home health agencies that do not submit quality data.

CMS also made a change to the labor and non-labor portion of payment rates:

Labor & Non Labor Portion of Payment Rates	New 2013	Old 2012	Variance
Labor Portion	78.535%	77.082%	1.453%
Non Labor Portion	21.465%	22.918%	(1.453%)

Listed below is the link for the final rule. 

http://www.gpo.gov/fdsys/pkg/FR-2012-11-08/pdf/2012-26904.pdf  

If you have questions or need additional information please call Richard Dixon at (321) 473-8561.