CMS Expands Home Health Pre-Claim Demonstration to Florida Beginning April 1st

CMS has decided to expand their Home Health Pre-Claim Demonstration to Florida for claims with dates of services beginning on April 1, 2017.  We have heard horror stories about the impact of this with the original demonstration state of Illinois.  CMS claims they have worked out the bugs in the system, but many of the home health agencies in Illinois disagree.  This adds to the continuing regulatory burden placed on home health agencies.  CMS continues to increase spending on the administration of the home health benefit instead of providing care to Medicare patients.

Our best hope to stop some of the insanity must begin with the new administration.  I do not know if the new CMS Administrator will stop or make changes to this program.  I hope they will listen to the US Senators who have written letters to the previous administrator to change this demonstration program. 

We will be addressing many parts of this Pre-Claim Demonstration program in our “New Directions in Home Care” seminar in Las Vegas on January 26^th & 27^th.

Link

https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Pre-Claim-Review-Initiatives/Overview.html

Seniors Do Fall Especially When On A Ladder

For the last month, I have been recovering from a fall from a ladder.  I should have known better than to climb up an extension ladder to take down the storm shutters from hurricane Matthew.  We have a two-story house with a large window in the second story over the foyer.  I was trying to remove a storm shutter and Margaret was holding the extension ladder.  I lost my balance and fell about 10 feet landing on the concrete entrance way.  The best news is that Margaret was not struck by the ladder or the falling storm shutter.  I was not so lucky.

Fortunately, I had four angels watching over me.  The first angel held my head up and it was not injured.  The second angel held my back up and it was not injured.  The third angel placed the corrugated storm shutter on the concreted which protected my hip and it was not broken. Unfortunately, the forth angel figured I needed to learn not to climb ladders again so I broke a bone in my foot.

I have learned very quickly it would have been much cheaper to hire a person to take down my storm shutters. Margaret has several ladders for sale in case anyone is interested. 

Now back to business.  Today is the second cut off for our New Directions in Home Care Seminar and our New Directions in Hospice Seminar that will be held in Las Vegas in January.  After today the price goes up by $100.  All of us have been forced to endure numerous changes and these seminars will help you implement needed changes to your organizations so you can succeed.  We do not have a room block at Bally’s.  We have found that you can obtain cheaper rates by going to Orbitz, Travelocity, or Kayak.  Many times you can book you hotel and airline ticket together and save even more.  

Richard Dixon

http://dixonhealthcaresolutions.com/home-health/

Are You Ready for the Emergency Preparedness Requirements Rule? This impacts all healthcare providers and suppliers

September 8, 2016 the Federal Register posted the final rule Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers. The regulation goes into effect on November 16, 2016. Health care providers and suppliers affected by this rule must comply and implement all regulations one year after the effective date, on November 16, 2017.

The purpose is to establish national emergency preparedness requirements to ensure adequate planning for both natural and man-made disasters, and coordination with federal, state, tribal, regional and local emergency preparedness systems. The following information will apply upon publication of the final rule:

• Requirements will apply to all 17 provider and supplier types.
• Each provider and supplier will have its own set of Emergency Preparedness regulations incorporated into its set of conditions or requirements for certification.
• Must be in compliance with Emergency Preparedness regulations to participate in the Medicare or Medicaid program.

Some items may include transfer documentation between facilities during disasters. Each agency must have a risk assessment, training and testing.

Since this is now part of the final rule, surveyors can evaluate and cite agencies who are out of compliance. Are you ready to meet these requirements? The above was written for us by J’non Griffin, President of Home Health Solutions, Inc.  She will one of our presenters at our New Directions in Home Care and New Directions in Hospice Seminars that will be held in Las Vegas in January 2017.  She will be addressing the Emergency Preparedness Requirements Rules in her presentations at both seminars.

Trump HHS Nominee Opposes Pre-Claim Review 12/1/2016

President Trump’s nominee for Secretary of Health and Human Services Representative Tom Price, Republican Congressman from Georgia. In September, he introduced a bill to pause the Pre-Claim Review Demonstration.  If he is confirmed by the Senate and follows through with his belief the Pre-Claim Review should be paused, it would be great news for all home health providers especially those in Illinois.

Representative Price is an Orthopedic Surgeon.  He should be aware of the numerous and burdensome regulations imposed on home health agencies in the last few years.  He is not in favor making bundled payments programs mandatory.  He is expected to work with the new president on repealing and replacing the Affordable Care Act.

We will be addressing the latest changes in the Home Health Update portion of our New Directions in Home Care Seminar in January.

Dramatic Change in Outlier Calculations - 11/10/2016

CMS is completely changing the methodology it outlier payment policy.  It is changing from a cost per visit approach to a cost per unit approach.  This means that visits with more minutes will count more toward outliers than visits with less time per visit.  The unintended (or intended) consequence of this approach is to dramatically decrease the outlier payments of daily visit diabetic and BID diabetic patients who cannot self-inject insulin.  CMS has tried for many years to reduce the cost of these patients. 

We performed a simple analysis of the impact on outlier payments for these patients and found payments for daily diabetic patients decreased by 40% and the BID diabetic patient’s payments decreased by 57%.  These are dramatic cuts for these patients and will force the home health agencies that are already losing money on these patients to lose even more.

We intend on providing more information on this at our upcoming conference in January in Las Vegas.

To view the rule please go to:

https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26290.pdf

Final Home Health LUPA Payment Rates 2017 11/8/2016

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

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$141.84	$139.07
PT	$155.05	$152.03
OT	$156.11	$153.06
SP	$168.52	$165.23
MSW	$227.36	$222.92
HHA	$64.23	$62.97

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$146.10	$143.24
PT	$159.70	$156.59
OT	$160.79	$157.65
SP	$173.58	$170.19
MSW	$234.18	$229.61
HHA	$66.16	$64.86

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

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$261.71	$256.60
PT	$258.93	$253.89
SP	$274.11	$268.76

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$269.57	$264.29
PT	$266.70	$261.51
SP	$282.35	$276.83

To view the rule please go to:

https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26290.pdf

Final Home Health PPS Rules & Rates For 2017 - 11/7/2016

We just returned from a 10-day cruise from New York to Ft Lauderdale.  Our trip started with 2 nights in New York which included seeing the Broadway Play “Beautiful” (Story of Carol King), visit to Ground Zero, trip to the top of Freedom Tower (Amazing), and Harbor Cruise to see the Statue of Liberty and other sites.  The cruise had stops in St. Martin, Antigua, and Bonaire.  While we were away many things happened including the release of the Final Home Health PPS Rules & Rates for 2017.

The final rules reduced the cut in home health payments from $180 million to $130 million. 

The national standard 60-day episode rate is the basis for all home health payments.  Home Health agency patients living in rural areas have a 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.

2017 National Urban Agency Rate $2,989.97

2017 National Urban Agency Rates (not submitting quality data) $2,931.63

2017 National Rural Agency Rate $3,079.67

2017 National Rural Agency Rate (not submitting quality data) $3,019.58

Individual home health agency rates will be adjusted by geographic location of the patient’s residence.  Individual episode rates will be adjusted by case-mix.

Other items changed in the final rule are LUPA Rates, Medical Supply Rates, Case-Mix Weights, HHVBP Model, and Outlier program. This is the first of several email alerts that will be published this week.

To view the rule please go to:

https://www.gpo.gov/fdsys/pkg/FR-2016-11-03/pdf/2016-26290.pdf

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.

Presented 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:

https://attendee.gotowebinar.com/register/8672183936740021506.

2.      You will receive an email with a personalized link to access the webinar.  Click this link at the specified date and time.

3.      Choose one of the following audio options:

TO USE YOUR COMPUTER’S AUDIO: When the webinar begins, you will be connected to audio using your computer’s microphone and speakers (VoIP). A headset is recommended.

—OR—

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.

United States: +1 (213) 929-4232

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

https://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Pre-Claim-Review-Initiatives/Overview.html

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 1^st each year and end September 30^th.

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 26^th to 27^th.

Final Link

https://www.gpo.gov/fdsys/pkg/FR-2016-08-05/pdf/2016-18221.pdf

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
Description	# of Agencies
Outliers on 2 characteristics	469
Outliers on 3 characteristics	84
Outliers on 4 characteristics	9

Home Health National Medians and Outlier Thresholds
Characteristics	National Median	Threshold For Outliers	Number  of Outliers	Outliers as a Percentage of Total
No recent visit with the supervision physician	22.6%	62.5%	470	3.9%
Diabetes of hypertension diagnosis	10.1%	45.1%	483	4.0%
Beneficiaries with claims from multiple HHAs	6.3%	25.9%	770	6.5%
Readmission shortly after discharge	5.6%	19.3%	778	6.5%

Where does your agency stand with these Characteristics?

For more information, please go to:

https://oig.hhs.gov/oei/reports/oei-05-16-00031.pdf

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

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$141.54	$138.77
PT	$154.72	$151.69
OT	$155.77	$152.73
SP	$168.16	$164.87
MSW	$226.87	$222.43
HHA	$64.09	$62.84

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$145.79	$142.93
PT	$159.36	$156.24
OT	$160.44	$157.31
SP	$173.20	$169.82
MSW	$233.68	$229.10
HHA	$66.01	$64.73

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

Discipline	Urban Agencies Submitting Quality Data	Urban Agencies Not Submitted Quality Data
SN	$261.66	$256.04
PT	$258.38	$253.32
SP	$273.53	$268.18

Discipline	Rural Agencies Submitting Quality Data	Rural Agencies Not Submitted Quality Data
SN	$269.00	$263.72
PT	$266.13	$260.92
SP	$281.72	$276.23

To view the rule please go to:

https://www.gpo.gov/fdsys/pkg/FR-2016-07-05/pdf/2016-15448.pdf