Final 2015 Home Health PPS Rules & Rates Published

The spooky present you did not want for Halloween! CMS publishing the Final 2015 Home Health PPS Rules & Rates.  This is a lengthy rule so this email will only be a brief summary.  You will receive more emails concerning the final rule next week.  The total economic impact is a $60 million reduction in home health Medicare payments for 2015.  There have been some slight changes to the 2015 base episode rate.  It has increased from the proposed rate of $2,922.76 to $2,961.38 or $38.62.  There has also been some slight changes in the LUPA Payment Rates and a slight decrease in the medical supply severity base payment rates.  We will report more on these and other issues in next week's emails.

We have scheduled a webinar titled "Understanding the Final 2015 Home Health PPS Rules and Rates" for November 20, 2014 from 3:00 pm to 4:30 pm EST.  The webinar will be held live, and the recording will also be available after November 20th.  The price for the webinar is $199 for your entire company, and you will able to view it multiple times for the one all-inclusive price.
 

Temporary Link to Final 2015 Home Health PPS Rules & Rates

The final rule will be published in the Federal Register on November 6th.  We will provide a new link at that time.

Webinar Information 

Registration Form 

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President Signs Improving Medicare Post-Acute Care Transformation Act of 2014

On October 6, 2014 President Obama signed the "Improving Medicare Post-Acute Care Transformation Act of 2014".  This bill puts in place new and streamlined quality measures for nursing home, home health agencies, hospices, and other post-acute providers.

Nursing Homes will receive Nationwide Focused Survey Inspections, Improved Scoring Methodology, Timely and Complete Inspection Data, and Additional Quality Measures.  The other item is Electronic Payroll-Based Staffing Reporting on a quarterly basis. Could this eventually be required of home health or hospice? 

Home Health Agencies will see new emphasis on explanation of patient rights.  An expanded comprehensive patient assessment requirements that focuses on all aspects of patient well-being. An integrated communication system, increasingly enabled by health information technology that ensures the patients' needs are identified and addressed, care is coordinate among all disciplines, and that there is active, timely, needs-based communications between the home health agency and the physician.  A data-drive, agency-wide quality assessment and performance improvement program that continually evaluates and improves agency care for patients.  An expanded care coordination requiring that a licensed clinician be responsible for all patient care services, such as coordinating referrals and assuring that plans of care meet each patient's needs at all times.   Didn't the Proposed Home Health COPs we reported on yesterday address most of these?  They did but this act is a new law that will require new proposed regulations.

Hospices will see increase in frequency of surveys. By law hospice were intended to be surveyed every 36 months, but there has not been the funds for these surveys.  Many hospice have between 5 and 7 years between surveys. This law adds $25 million for hospice surveys for FY 2015 through 2017 and adds $45 million for hospice surveys for FY 2018 through 2025.  The law also addresses hospice patients with length of stays that exceed 180 days.  This will set an automatic medical review on hospices that have more than a certain percentage of their patient who have length of stays more than 180 days.  The law does not specify the percentage.  It states the Secretary, which is the Secretary of Health and Human Services would establish this percentage.  I believe most hospices that have a high percentage of patients with length of stays beyond 180 days are probably already having their claims moved to medical review. 

We intend to provide future emails to give you more information on the impact of this bill.  We will also have information for home health agencies at our 3 Day Home Health Seminar to be held in Las Vegas at the Monte Carlo Hotel & Casino on January 28-30, 2015.  We will also have more information for hospices at our 3 Day Hospice Seminar to be held in Las Vegas at the Monte Carlo Hotel & Casino on February 2-4, 2015. 

Link to Bill

http://www.gpo.gov/fdsys/pkg/BILLS-113hr4994enr/pdf/BILLS-113hr4994enr.pdf

Correction to Hospice Notice of Revocation Processing

CMS issued MLM Matter # MM8795 related to Change Request 8795.  When a hospice period is terminated, the hospice provider is required to submit the termination or revocation notice within five (5) calendar days. If the provider is not prepared to submit their final claim, they must submit the 08XB type of bill (TOB) to terminate the hospice period. Currently, there are fields providers do not have access to under DDE, which are required to submit this TOB through DDE. Therefore, MACs must facilitate the completion of the submission for the hospice. CR8795 requires updates to the DDE system to allow providers to complete all fields required for complete submission of the notice of revocation. CR8795 contains no change in policy.

For more information please read the link below – MLM Matter MM8795

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8795.pdf

Do You Advocate For Your Patients?

Over the last couple of years ZPICs and RACs have reviewed and denied home health claims from various patients.  Their denial may claim that the patient is not home bound and is not qualified for home health services.  Have you received one of those denials?  If you believe the patient was homebound have you filed an appeal?  Some home health providers have just rolled over and accepted the denial, meaning they lose the reimbursement for the claim, but what about the patient.  Has your failure to appeal the denial flagged the patient as not home bound for other home health agencies? I know this has happened because some of my clients have tried to admit some of these patients after they were denied for not being home bound in the past.  Their claims were also denied, because the MAC stated they had been previously determined as not being home bound.  This could be for a patient that may have recently been a patient of a previous home health agency or it could be many months since that patient was receiving home health services.   The failure of the previous home health agency to appeal the denied claim has now placed a red flag on the patient's record and restricted their ability to receive home health services in the future.  My advice to all my clients and seminar attendees is to appeal denials.  I am not suggesting that a home health agency or hospice admit a patient that is not qualified.  You should only admit patients who qualify and need your services. If it were my home health agency or hospice and a RAC, ZPIC, CERT or MAC denies a claim, they better bring their lunch and dinner.  If I believed the patient was qualified, I would appeal the claim to every level.  I realize the appeals are costly and I would do everything I could to reduce the potential cost of the appeal, but I would appeal all of the claim denials.  If my appeal failed at the first level, I would continue to appeal the denial all the way to the highest level.  I would not only be advocating for my company I would also be advocating for the patient. I think most of us would agree that health care providers, physicians and suppliers are now considered guilty until proven innocent.  I agree that all of the bad actors in the health care area should be removed from the business, but viewing all health care providers, physicians and suppliers as bad actors is wrong.  This must change.  You should advocate for your business and your patients.  It is starting to make a difference in ALJ Level because appeals by law that should be heard within 90 day are now taking over 2 years.  Keep their feet to the fire! We have Robert Liles speaking at our Home Health, Hospice, Private Duty, and Physician Practice seminars in Las Vegas in late January and early February next year.  He is the best healthcare attorney I know dealing with ZPIC, RAC, CERT, and MAC denials.  He will be speaking on "Preparing and Responding to Various Medicare Claim Audits", "Compliance Plans (Your First Level of Defense)", "Latest Employment Law Issues", and "HIPAA and Other Privacy Issues".  There is more information about the seminar below.   **********************************************

Dixon Healthcare Solutions, Inc. Next Destination Seminars  Exploring Trends & Routes for Success

Four Great Seminars presented by  Dixon Healthcare Solutions, Inc. Home Health Agencies - January 28-30, 2015 Physicians Practices - January 28-30, 2015 Hospices - February 2-4, 2015 Private Duty - February 2-4, 2015 **** Brochures Home Health Brochure Physician Practice Brochure Hospice Brochure Private Duty Brochure **** Location is the Monte Carlo in Fabulous  Las Vegas, NV **** Registrations Forms Home Health Physician Practices Hospice Private Duty It is important to register early, because the rates go up as the date gets closer and their is limited seating. **** The speakers include: Richard Dixon, J-non Griffin Robert Liles Richard Martin Cheri Martin Robert Floyd Donna Floyd Adam Bird (Physician Practice Only) **** Program Outlines Home Health Physician Practice Hospice Private Duty The program is great for each and we hope to see you in Las Vegas at the Monte Carlo ***********************************

Explanation on Hospice Q5003 and Q5004

CMS issued Transmittal 3032 which covered many issues facing hospices beginning on October 1, 2014.  This included non-allowable primary diagnoses, Notice of Election changes and penalties, and an explanation on hospice use of Q5003 compared to Q5004.

 
According to the CMS Transmittal 3032, Q5004 shall be used for patients in a skilled nursing facility (SNF), or hospice patients in the SNF portion of dually-certified nursing facility.  There are 4 situations where this would occur:

1. If the beneficiary is receive hospice care in a solely-certified SNF
2.  If the beneficiary is receiving general inpatient care in the SNF
3. If the beneficiary is in a SNF receiving SNF care under the Medicare SNF benefit for a condition unrelated to the terminal illness and related conditions, and is receiving hospice routine home care, this is uncommon.
4. If the beneficiary is receiving impatient respite care in a SNF

If a beneficiary is in a nursing facility but doesn't meet the above criteria for Q5004, the site shall be coded as Q5003, for a long term care nursing facility.

For more information please read the link below 

 

Transmittal 3032 Change Request 8877