Drastic Payment Cuts for Home Health

CMS has published the Proposed Rule for the Home Health Prospective Payment System update for 2014. It will impact home health payments for the next four years.  The current year impact will reduce home health payments by 1.5 percent or $290 million, but the future impact will be much worse.

There are many moving parts to this rule.  We will cover some of the basics in this update, but will follow it with other updates next week to provide more detailed information.  Below is a brief analysis of the episode rate.  To provide a better comparison we have one column with the new adjustment for episode case mix standardization and another column without the case mix standardization. (Episode standardization will move the average episode case mix weight from 1.3517 to 1.0000 by reducing all case mix weights by 35.17 %.)

Description	With Case Mix Adjustment	Without Case Mix Adjustment
2012 National Standardized 60 Day Episode Rate	$2,138.52	$2,138.52
Inflate Case Mix Adjustment (x1.3517)	$2,890.64	$2,138.52
Reduce for Nominal Case Mix Growth 2013 (x.9868)	$2,852.48	$2,110.29
Payment Update Percentage for 2013 (x1.013)	$2,889.56	$2,137.72
Outlier Adjustment (Divide by .975)	$2,963.65	$2,192.53
Rebasing Adjustment 2014 (x.965)	$2,859.92	$2,115.79
Outlier Adjustment (x .975)	$2,788.42	$2,062.90
Standardization Factor (x1.0017)	$2,793.16	$2,066.41
2014 Market Basket Adjustment (x1.024)	$2,860.20	$2,116.00

Remember your episode case mix rates will be decreased by 35.17% so for example C1F1 with 0 to 5 therapy visits will go from 0.8186 case mix rate in 2013 to 0.6056 in 2014.  There are positive adjustment to LUPA payment rates and negative adjustments to Non Routine Medical Supplies. 

Your episode rates will be reduced by 3.5% for rebasing in 2015, 2016 and 2017.  You will also have a reduction inflation factor adjustment of 1% in 2015, 2016, and 2017.

We sent a note out to home health agencies last week titled “It is Time to Step Up or Fall Behind”.  We stated that your home health agency is currently going up the down escalator.  The current momentum of the health care industry is constantly pushing your company down, just like a down escalator is constantly moving down.  To step up to the next stair, you adapt and embrace the changes or place your head in the sand and move further down the escalator. 

If you would like to step up instead of falling behind attend our Home Health Leadership Conference on September 23^rd to September 25^th at the Hilton Waikoloa Village on the “Big Island” in Hawaii. We will cover the home health proposed PPS Rule and methods to successfully adapt to the changes.

For more information use the temporary link below (The final link will be available on July 3^rd when proposed rule is published in the Federal Register):

https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-15766.pdf

It is Time to Step Up or Fall Behind - Hospice

Your hospice is currently going up the down escalator.  The current momentum of the health care industry is constantly pushing your company down, just like an escalator is constantly pushing you to the bottom.    To step up to the next stair, you adapt and embrace the changes or place your head in the sand and move further down the escalator. 

·         Are you ready to implement the changes necessary to adapt to the Proposed 2014 Rules and Rates?

·         Do you have a good understanding of the new coding issues impacting hospice?

·         Have you developed new financial strategies to increase your hospice’s profitability?

·         Do you have the essential leadership skills to allow your hospice to step up and make changes?

·         Have you implemented the changes necessary to comply with the Final HIPAA Rule?

·         Are you managing your medical review process to respond to ADRs, ZPICs, and RACs?

·         Do you understand the health care reform bill and the changes it will force on your hospice?

·         How will your hospice adapt to the latest changes in quality measures?

·         Do you have strategies to successfully implement new technologies in your hospice?

·         Has your hospice reviewed its processes for documenting eligibility?

·         Have you addressed the changes you need to make to your contracts to comply with the latest rules?

·         Do you know how to make a friend to grow your business?

Do you believe the latest headline that “the game is up for hospice”?  We certainly believe that this is incorrect, but failure to step up will leave your hospice behind and destined to fail.

If you would like to step up instead of falling behind attend our Hospice Leadership Conference on September 18^th to September 20^th at the Hilton Waikoloa Village on the “Big Island” in Hawaii. 

Great Room Rate $179 per Night - Use Group Code DHW

Special Discounted Rates from Delta Airlines, National Rental Car & Speedy Shuttle

Approved for 15 Continuing Nursing Education Hours

This educational activity is co-provided by Dixon Healthcare Solutions, Inc. and Corexcel.  Corexcel is accredited as a provider of continuing nursing education by the American Nursing Credentialing Center’s Commission on Accreditation.

Approved for 15 Hours of Hospice Administrator Continuing Education

By Texas Department of Aging & Disability Services

For more information please go to: www.dixonhsi.com

For a seminar brochure go to: http://www.dixonhsi.com/Final%20Hawaii%20Hospice%20Brochure.pdf

For a registration form go to: http://www.dixonhsi.com/Final%20Hawaii%20Hospice%20Program%20Outline.pdf

It is Time to Step Up or Fall Behind - Home Heatlh

 Your home health agency is currently going up the down escalator.  The current momentum of the health care industry is constantly pushing your company down, just like an escalator is constantly pushing you to the bottom.    To step up to the next stair, you adapt and embrace the changes or place your head in the sand and move further down the escalator. 

·         Are you ready to implement the changes necessary to adapt to the Proposed 2014 PPS Rules and Rates?

·         Do you have a good understanding of ICD-10 and a plan to implement it in your agency?

·         Have you developed new financial strategies to increase your agency’s profitability?

·         Do you have the essential leadership skills to allow your agency to step up and make changes?

·         Have you implemented the changes necessary to comply with the Final HIPAA Rule?

·         Are you managing your medical review process to respond to ADRs, ZPICs, and RACs?

·         Do you understand the health care reform bill and the changes it will force on your agency?

·         How will your agency cope with the latest changes in medical coding?

·         Do you have strategies to successfully implement new technologies in your agency?

·         Is your agency implementing low cost marketing strategies to allow your agency to grow and prosper?

·         Have you addressed the changes you need to make to your contracts to comply with the latest rules?

·         Do you know how to make a friend to grow your business?

Do you believe the latest headline that “the game is up for home health”?  We certainly believe that this is incorrect, but failure to step up will leave your home health agency behind and destined to fail.

If you would like to step up instead of falling behind attend our Home Health Leadership Conference on September 23^rd to September 25^th at the Hilton Waikoloa Village on the “Big Island” in Hawaii. 

Great Room Rate $179 per Night - Use Group Code DHW

Special Discounted Rates from Delta Airlines, National Rental Car & Speedy Shuttle

Approved for 15 Continuing Nursing Education Hours

This educational activity is co-provided by Dixon Healthcare Solutions, Inc. and Corexcel.  Corexcel is accredited as a provider of continuing nursing education by the American Nursing Credentialing Center’s Commission on Accreditation.

Approved For 15 Hours Of Home Health Administrator Continuing Education

By Texas Department of Aging & Disability Services

For more information please go to: www.dixonhsi.com

For a seminar brochure go to: http://www.dixonhsi.com/Final%20Hawaii%20Home%20Health%20Brochure.pdf

For a registration form go to: http://www.dixonhsi.com/Hawaii%20Home%20Health%20Registration%20Form.pdf

MedPAC June Report to Congress Recommends More Bundling of Payments

Home health agencies and other post-acute providers can look for more pressure from MedPAC regarding bundling of payments.  CMS has several model demonstration projects related to bundling currently in progress.  CMS Model 2 bundles inpatient stay with post-acute care and readmissions.  CMS Model 3 bundles post-acute care and readmissions.  Both models are currently under the no risk portion of the demonstration program.  They will move to the at risk portion in October of 2013.  Once providers begin the risk portion of the program, CMS will provide a reward for savings compared to their set targets, but they will require repayment if the cost are above their targets.  CMS also expects the providers to discount their normal reimbursement by either two or three percent depending on the program. 

We believe that MedPAC and CMS will continue to push the bundling programs over the next few years to reduce the overall cost to Medicare.  This will continue to squeeze the Medicare payments for all providers.  To succeed all Medicare providers must carefully monitor cost along with clinical documentation. 

For more information please utilize the following link:

http://www.medpac.gov/documents/Jun13_EntireReport.pdf

Home Health Agencies and Hospices Need to Move Forward or Fall Behind

Home health agencies have seen their Medicare episode payments decrease over that last few years and the future payments will probably continue to fall over the next few years.  Hospice Medicare payments have not decreased but they are not receiving their full inflation updates and the likelihood is that payments will not be keeping up with inflation in the future.

Home health agencies and hospices claims continue to receive more scrutiny from Medicare Administrative Contractors (MACs), Zone Program Integrity Contractors (ZPICs), Recovery Audit Contractors (RACs), and the Office of Inspector General (OIG). 

Many home health agencies and hospices have adopted a bunker mentality.  They are so busy and overwhelmed that they have failed to keep up with the latest information to enable them to move forward and survive. 

Operating a successful home health agency or hospice requires you to move forward and adapt to the changes.  You can either move forward of fall behind.  The best description of this is walking up a down escalator.  You are either moving forward or if you stand still you are falling behind. 

Take some time to learn and adapt to the changes in Home Health and Hospice.  You need to think outside the box to enable your company to survive.  We have a fabulous set of leadership seminars coming up in Hawaii in September.  The Hospice Leadership Conference will be held on the “Big Island” of Hawaii on September 18^th to 20^th.  The Home Health Leadership Conference will be held at the same location on September 23^rd to 25^th.  Join with us, a wonderful set of presenters, and many of your colleagues in Hawaii in September.  We have developed a tremendous program that will help you to move forward and not fall behind.

CMS Adds New Items to ICD-10 Questions and Answers

We are all aware that we will be changing from ICD-9 to ICD-10 for coding.  CMS has a Question and Answer Page that includes many items related to ICD-10 (The link is listed below).  They have added three new items to the site this week and will continue to do so for the next year.  We encourage you to begin planning for ICD-10 implementation. 

We are very fortunate to have Lisa Selman-Holman, a leader in ICD-10 coding, presenting the topic “Are you ready for ICD-10” at our Home Health Leadership Conference  to be held on the “Big Island” in Hawaii September 23^rd to 25^th.  Just because you are not a coder does not mean you do not need to understand ICD-10.  Remember that ICD-10 will be a vital part of the payment mechanism for home health agencies.  This will be a very valuable presentation to the owners and administrators of home health agencies to help them get ready for ICD-10.

We hope to see you in Hawaii.

For more information please utilize the following link:

https://questions.cms.gov/

Lions, TIGERS and Bears, OH MY!

One of our speakers for our Leadership Conferences called this week, he can’t go to Hawaii for the Leadership Conferences, Oh My!

So, Dixon Healthcare Solutions, Inc. must do what we tell you to do, make the best of the situation.

So you know it, we found you a Tiger.  He is Richard Martin, a leader to talk to you on “Leading through a myriad of changes” and he is a Mizzou Football Tiger.  Oh My!

RICHARD BIO
Richard Martin is a fun-loving recreational pilot by preference, food chemist by degree, visionary and passionate Internet entrepreneur by choice.  He is the founder of WCN Interactive, Inc. a company dedicated to helping businesses effectively promote their company using online techniques so they can attract more business.  Richard has over forty years of business leadership experience, most with fortune 1000 companies, he has spent the last 15 years establishing and improving Internet marketing, sales, and business development for companies in various industries both locally and nationally.  He has a proven track record in creating, deploying and managing numerous clients’ Internet marketing strategies by means of Search Engine Optimization, Pay-Per-Click Campaigns and Social Media Marketing.  A creative thinker at applying Social Media, Richard is a student of his craft; his strengths lie in translating his clients’ needs and applying solutions into actionable plans.

Richard has been giving presentations as well as conducting workshops on Internet Marketing since 1998 and is a graduate of international Social Media Trainer Mari Smith’s ‘Social Media Mastery Immersion’ and an Authorized Local Expert with Constant Contact.  He has completed speaker training with the World’s Leading Motivational Speaker, Les Brown, and has spoken at and/or been an educator at Chambers of Commerce, Small Business Development Centers (SBDC), Colleges and Universities, International Builders Show (IBS), South Eastern Builders Conference (SEBC), a number of Specialized Seminars (Transportation, Direct Sellers, Home Health Care), Cities, Companies, Groups, plus currently offers a variety of Social Media workshops and webinars.   As a web marketing pioneer, Richard’s enthusiasm of the Internet naturally engages everyone in his audience.  His desire for each person to have ‘take-a-ways’ they can instantly implement on their own dramatically increases the value of all his coaching, workshops and presentations.  Richard’s key to success is avoiding those who say it can’t be done!

And the Bonus is we also get an additional session from Cheri Martin titled “Make a friend. Grow your business.” Oh My!  Yes she is the wife of a Tiger.

She will speak to you on the Second Day from 2:00 to 3:15

CHERI BIO
Cheri Martin, lover of family, music, decorating, sports and conversation; is a Social Networking Visionary with 15 years of online marketing experience.  Cheri delights in Internet research; her skill in mastering the different Social Media sites, passion for networking, plus her joy of teaching, led her to begin educating others on Facebook, Pinterest, LinkedIn, Twitter and other social platforms.  She is co-founder of WCN Interactive, a Social Business Marketing and Coaching company, and is always eager to share her expertise with others through training, coaching and speaking, so they too can have a better understanding of how to utilize the various social networking sites to attract more business and excel in Social Media and grow their vision.

 As a graduate of international Social Media Trainer Mari Smith’s ‘Social Media Mastery Immersion’ as well as a member of Mari’s Inner Circle, Cheri realizes the importance of offering continuing education for those seeking knowledge of the ever-evolving social platforms, so she launched TheGPSAcademy.com, an online Social Business learning center, in January 2012.  Cheri, a certified Coach, Trainer, Speaker and Founding Partner with internationally respected Leadership Expert, John C. Maxwell’s Team and an Authorized Local Expert with Constant Contact; enjoys teaching workshops and webinars, as well as giving presentations.  When asked what the key to her success is, Cheri says it is her ease at talking with people and building relationships.  She remembers fondly her mother telling her as a teenage ‘phone junkie’ that she would never make a living by talking to people, this makes her smile as that is exactly what social networking is all about.

Okay, you noticed there are no Lions and Bears.  But you have Tigers.  On My!

Margaret and Richard Dixon

The Auburn Tigers

Dixon Healthcare Solutions, Inc.

321-473-8561

Beware of Adult Failure to Thrive and Debility as Primary Hospice Diagnosis

The Proposed Hospice Wage Index and Payment Rules that were published on May 8, 2013 included many other items for the hospice industry.  We have received phone calls and emails concerning the Adult Failure to Thrive code (783.7) and Debility code (799.3) as the primary diagnosis code for hospice patients.  In the proposed rule CMS states that Adult Failure to Thrive and Debility cannot be used as the primary diagnosis code.  They could be utilized as a secondary diagnosis code.  The proposed rule (see link below) goes into detail on page 27830 through 27834 concerning diagnosis coding.  The latest claims data available show that over 70% of hospice claims only utilize one diagnosis code.  CMS will begin require much more detailed coding now and in the future.

Of primary concern for hospice’s today is CMS plans to immediately implement that the Adult Failure to Thrive and Debility codes cannot be utilized as primary diagnosis. This was stated by CMS in the Hospice Open Door Forum Meeting on May 8^th.   CMS stated that this only clarifying existing policy and guidelines.  CMS is developing a special edit that will return all claims to hospice’s that have Adult Failure to Thrive or Debility as their primary diagnosis.  They have not released a date when the edit will become effective.  We will notify our newsletter subscribers as soon as we find that date the edit will be released.

We encourage all hospices’ to carefully review their coding and immediately stop utilizing Adult Failure to Thrive and Debility as the primary hospice diagnosis.  We understand that coding can be very confusing and difficult to understand.  We will have two speakers at our Hawaii seminar in September 18^th to 20^th to provide more detailed information on hospice coding and other important issues.  For more information about our upcoming Hawaii Seminar please see the information listed below this email.

To obtain a copy of the Proposed Hospice Wage Index and Payment Rules that were published on May 8, 2013 please click on the link below:

http://www.gpo.gov/fdsys/pkg/FR-2013-05-10/pdf/2013-10389.pdf

CGS Joins Palmetto GBA in In-Depth Review of Face-To-Face Documentation

CGS and the Comprehensive Error Rate Testing (CERT) contractor have found numerous errors related to the home health face-to-face encounter.  They have joined Palmetto GBA in a Widespread Home Health Probe in Face-To-Face Encounter Documentation.  The topic code for this review will be 52xxT (‘xx” denotes various numbers) and the edit will select start of care home health claims equally across the provider community.  Once selected, the claims will be reviewed for valid FTF encounter documentation, medical necessity compliance with all CMS guidelines, correct billing, and coding.

The Face-To-Face documentation, which must be a separate and distinct section of or an addendum to the Start of Care Certification must include:

1.      Clear title to show it is a FTF encounter (HHA may title documentation)

2.      The patient’s name

3.      The date of the encounter

4.      A description of the clinical findings during the encounter

5.      An explanation of how the clinical findings support homebound

6.      An explanation of how the clinical findings support the need for skilled home care

7.      The certifying physician’s dated signature

(HHA may enter date received if not dated by the physician)

This is similar to the probe initiated by Palmetto GBA in May.

For more information about the CGS probe use the following link:

http://www.cgsmedicare.com/hhh/pubs/news/2013/0613/cope22393.html

For more information about the Palmetto GBA probe use the following link:

http://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Jurisdiction%2011%20Home%20Health%20and%20Hospice~CERT~General%20Information~Face%20to%20Face%20Documentation%20for%20Home%20Health%20Certification%20Important%20Information%20for%20Certifying%20Physicians%20and%20Non-physician%20Practitioners%20(NPPs)

IRS Proposed Safe Harbors on Employee Health Coverage Required by Obama Care

On May 3, 2013 the Internal Revenue Services published proposed Safe Harbors to comply with the Affordable Care Act.  The first safe harbor is a plan with a $3,500 integrated medical and drug deductible, 80 percent plan cost-sharing, and a $6,000 maximum out-of-pocket limit for employee cost-sharing.  The second safe harbor is a plan with a $4,500 integrated medical and drug deductible, 70 percent cost-sharing, a $6,400 maximum out-of-pocket limit, and a $500 employer contribution to a Health Savings Account.  The third plan with a $3,500 medical deductible, $0 drug deductible, 60 percent plan medical expense cost-sharing, 75 percent plan drug cost-sharing, a $6,400 maximum out-of-pocket limit, and drug co-pays of $10/$20/$50 for the first, second and third prescription drug tiers, with 75 percent coinsurance for specialty drugs.

These safe harbors can help home health agencies and hospices to comply with rules.  It will not reduce the cost of compliance or eliminate penalties for non-compliance.  We recommend you work with a qualified insurance broker and shop with the state agency exchange to obtain the lowest cost possible.  Remember you must be in compliance by January 1, 2014.  We will be covering more information about the impact of the Affordable Care Act at our Home Health, Hospice, and Private Duty Leadership Conferences in Hawaii in September. 

To read the proposed rule please go to:

http://www.gpo.gov/fdsys/pkg/FR-2013-05-03/pdf/2013-10463.pdf

SafeGuard Services, LLC Issues Home Health Comparative Billing Report

In February of 2013 a Comparative Billing Report was sent to over 4,800 home health agencies.  The data in these reports were based on the average services received and paid for per beneficiary.  To provide additional education to the home health community, the data was modified and is included in the following report.  The services are based on Medicare final claims data with services dates from January 1, 2011 through December 31, 2011 and scheduled paid dates through December 7, 2012.

They issued three reports for national and state data.  The first report is the average number of home health visits per episode.  The second report is the average number of home health therapy visits per episode.   The third report is average Medicare Payment per episode.

Medicare Administrative Contractors (MACs), Zone Program Integrity Contractors (ZPICs) and Recovery Audit Contractors (RACs) utilize average data per state in determine what to audit.  They audit by exception.  For example if your agency has substantially higher visits per episode that the other agencies in your state you will be at a higher risk for an audit.  This does not mean your agency is doing anything inappropriate.  The above reports are not risk adjusted.  Risk adjusted means the fact that your agency serves patients whose diagnosis would indicate they need more visits per episode is not reflected in the reports.

We recommend you look where your agency ranks compared to your state and on a national basis on the three reports.  If you are substantially higher or lower, you may have a higher risk for an audit.  If you have such a risk ensure your documentation supports the care you have given.

To obtain the report please go to:

http://www.safeguard-servicesllc.com/cbr/faqs.asp?id=cbrfaqs2c#myfaq