Wednesday, July 2, 2014

CMS Proposes To Eliminate Face-To-Face Narrative with PPS Rates for FY 2015

The proposed rule changes home health payment rates for 2015, it updates home health wage index, case-mix rates, addresses the delay of ICD 10, changes some of the therapy reassessment timeframes, solicits comments on a Home Health Value Based Purchasing Program and make changes to the Face-To-Face narrative. 

Most home health agencies are having difficulties with the Face-To-Face narrative.  CMS is proposing to eliminate the physician Face-To-Face narrative, but the physician must document that the encounter occurred and the date the encounter occurred.  In instances where the physician is ordering skilled nursing visits for management and evaluation of the patient's care plan, the physician will still be required to include a brief narrative that describes the clinical justification of this need as part of the certification/recertification of eligibility. Next CMS is proposing for medical review purposes to only consider medical records from the patient's certifying physician or discharging facility in determining initial eligibility for the Medicare home health benefit.  Finally CMS intends to deny the physicians Medicare claim for the Face-To-Face encounter if the home health claim is not covered because the patient is not eligible for the benefit. This portion of the proposed rule would be implemented in future regulations.

The bottom line appears to still require the physician narrative in some cases and to utilize the physician medical records to justify home health certification. The home health industry will still be penalized based on the record-keeping of the physicians.   Penalizing a home health patients by disallowing their coverage due to poor record-keeping of the physician is a disgrace.  It appears that CMS is continuing to ration care to eligible Medicare beneficiaries by unclear and unfair rules and regulations.  We support the Lawsuit filed by the National Association of Home Care on home health Face-To-Face issues.  This proposed rule continues to show CMS lack of understanding of the issue and their need to restrict and deny Medicare patients their needed home health services.

We will have much more on the proposed home health payment rules and rates for 2015 in future email alerts.  We have scheduled a Home Health Webinar titled "Understanding the Proposed Home Health PPS Rules & Rates for 2015" for July 31, 2014 from 3:00 pm to 4:30 pm EDT.  The webinar will be held Live, but will be available later on demand because it will be recorded.

The proposed rule will be published in the Federal Register on July 7, 2014. We have a temporary link to the proposed rule below:
 
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Understanding the Proposed Home Health PPS Rules and Rate for FY 2015
 We have a Special Live and On Demand Webinar on Thursday July 31, 2014 from 3:00 - 4:30 PM EDT.  This 90 Minute Webinar covered the following items. 

1. Proposed Home Health PPS Payment Rates for FY 2015   
2. Changes in Home Health Wage Index  
3. Changes in Face-To-Face Encounter Narrative
4. Case-Mix Adjustment Variables and Scores for 2015    
5. Clinical and Functional Thresholds for 2015
6. Case-Mix Payment Rates for 2015    
7. Simplification of Therapy Supervision Timeframes  
8. Update on Home Health Quality Reporting Program   
9. Implementation Date for ICD-10
10. CMS views on Diabetic Patient's who cannot self inject  
11. Update Home Health Value Based Purchasing Model

This Webinar can be viewed at a later time because it was recorded.  Your registration fee is only $199 for your entire company.  The registration fee also will include handouts that you will receive via email when you register.
  
To attend the exciting new Webinar please download the Registration Form and fax it back to us at (888) 577-6932 We do accept all major credit cards.  

You can register by phone by calling (321) 473-8561 and asking to speak with Margaret.

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