Monday, March 9, 2015

Hospice CAP Form Finally Approved

CMS has finalized the form to use in computing the self-determined hospice cap. The form labeled 'PROVIDER SELF-DETERMINED AGGREGATE CAP LIMITATION' is attached. Instructions for completing the form are also attached.  The form is only one page. The top section contains the cap computation. The lower section contains the certification statement. Be sure to complete both sections. 
Please note the following related to submitting the self-determined hospice aggregate cap for the period ended October 31, 2014.  The due date for submitting the form isMarch 31, 2015.  Only send the signed form (supporting information is not needed).  Current instructions do not include sequestration as part of hospice payments subject to the cap, if CMS moves forward to added sequestration payments to the hospice cap it will be done by the Medicare Administrative Contractor (PalmettoGBA, CGS, or NGS).

PalmettoGBA actually sent Hospice PSR's to their providers in late February.  CGS and NGS Hospice providers will be required to obtain their own PSR.  If a hospice does not currently have access to the PS&R system, please register for access through the Enterprise Identity Management System (EIDM) when that system is available. Providers will be required to register in the EIDM system in order to have access to their PS&R data and the Medicare Contractor will no longer be providing the PS&R data.





Wednesday, March 4, 2015

CMS Moving Forward with Value Based System for Home Health

CMS released a Fact Sheet titled "Health Care Payment and Learning Network".   This network if for the entire healthcare system, not just home health.  The aim is to move the health care system toward value-based-purchasing.   The goal for 2016 is to have 30% of Medicare payments into alternative payment models and increase this to 50% by 2018.  The Fact Sheet gives you the opportunity to become a participant in the overall Health Care Payment and Learning Network.  This will keep you up to date on CMS's plans for the future of the healthcare delivery system.  (This will not volunteer you to join the home health demonstration program described below)  You will have the opportunity to provide input in the overall health care system.

We learned of the Value Based Purchasing for home health agencies in the final home health prospective payment rules.  CMS pointed out it was looking for a demonstration program that would consist of all of the home health agencies in 5 to 8 states. (If your state is chosen you must participate). The proposal states the demonstration program would place 5 percent to 8 percent of home health payments at risk meaning your reimbursement could increase up or down by that amount.  We will be providing more information in future email alerts.  I will be presenting a session on Value Based Purchasing for home health agencies at the Cutting Edge Home Health Leadership Summit to be held in Maui, Hawaii on August 12th to 14th

Tuesday, February 24, 2015

CMS Still Has Not Issued Hospice CAP Forms

The new rules require hospices to complete their own aggregate CAP Form calculations for the period of 11/1/2013 to 10/31/2014 and to remit any overpayments. The reports are due by March 31, 2015. We have a brief paragraph below from the Palmetto GBA website. 

The website states the release of the CMS approved form to use in submitted the self-determined cap is pending.  As soon as the form is approved, we will provide and post an update to our website.  It also states that Palmetto will be sending payment and beneficiary count for all hospices served by Palmetto GBA in February. They issued instructions on how to order your PSR.  We will send further email updates when CMS releases the Final Hospice CAP Forms.


Wednesday, February 18, 2015

Expect More HIPAA Enforcement in 2015

All healthcare providers, suppliers, physicians, and insurers should expect more HIPAA enforcement actions from HHS Office for Civil Rights in 2015.  They have received more money in the 2015 budget and they expect to collect more fines, so we can expect more activity this year.  It is a good time to check that you are complying will all of the HIPAA Privacy Rules and Regulations.  Look at potential holes due to phones, laptops, and tablets being unsecured.  Make sure you have Business Associates Agreements will all applicable contractors who may have access to your patient information.

We will have Robert Liles speaking at our "Cutting Edge Leadership Summit" in Maui, HI in August of 2015 on the topic of "Shielding Your Company from HIPAA Violations".  We have three separate seminars. One for home health, one for hospice and one for private duty.  Make plans to attend.

Tuesday, February 17, 2015

CMS Moves Forward on Home Health 5 Star Rating System

Based on CMS's latest open meeting it is moving forward with its 5 Star Rating System for Home Health Agencies, but they have actually added more breadth to the rating system by adding half stars.  This will be listed on the Home Health Compare site beginning sometimes this summer. 
They propose to use 4 Process Measures and 6 Outcome Measures. 
The Process Measures:
  1. Timely Initiation of Care
  2. Drug Education on all Medications Provider to Patient/Caregiver
  3. Influenza Immunization Received for Current Flu Season
  4. Pneumococcal Vaccine Ever Received.
The Outcome Measures:
  1. Improvement in Ambulation
  2. Improvement in Bed Transferring
  3. Improvement in Bathing
  4. Improvement in Pain Interfering With Activity
  5. Improvement in Shortness of Breath
  6. Acute Care Hospitalization

Monday, February 16, 2015

Medicare Cost Report


Is your year end December 31 for Medicare and Taxes?  Seventy Percent of Home Health Agencies and Hospice have a year end of December 31.  This means that your Company Income Tax return is due on March 15 and your Medicare Cost Report is due on May 31.  This mean it is time to start working on Year End Reports.  If we are preparing your Medicare Cost Report you should have an email with information or will soon be receiving a letter with information.  Please call us if you have questions, we do not want you to waste time spinning your wheels and not accomplishing anything, we want it to be as painless as possible for you.   Is someone else is preparing it for you call them, they should be able to help you.

Thing to consider when choosing who to prepare your Medicare Cost Report
  • Cost report preparation experience prior to 2000
  • Helpfulness - Answers your questions timely
  • Price that is affordable to your company

Friday, January 9, 2015

Healthcare Status 2015

Hello and welcome to 2015.  We are very concerned with the increasing government rules, regulations, claim denials and payment cuts.  Did you know that your actual average home health episode reimbursement is less than it was when PPS began?  During the same period of time inflation rose by over 30 percent.  Medicare has placed increased pressure physicians to make it more difficult to refer patients to home health.  First with the physician narrative, which thankfully has been eliminated as of January 1, but requiring their medical records to support the need for home health referrals.  Remember physicians have always been required to document that patients are home bound and needed skilled care, now they are just increasing physician paperwork.  Do you think that makes physicians more or less likely to refer patients to home health?  I would guess it makes them less likely to refer patients.  The impact of the above appears to show CMS is trying to close thousands of home health agencies. 

 
CMS is making similar efforts in the hospice area, such as increasing government rules, regulations, and claim denials.  Studies have proven that hospice saves the Medicare program compared to traditional care at end of life, but all CMS wants to do is to restrict hospice access.  Medicare is concerned with hospice patients with length of stay beyond 180 days.  Just because a patient lives beyond 180 days after they were admitted does not mean they were inappropriate for hospice at the time they were admitted.  I do not believe any doctor in this world can determine the actual time and date of when a patient will pass away.  I think they would admit that is beyond their pay grade, but still CMS still is trying to hold hospices to that unreal standard.  I am not saying there has not been abuse in long term stays for hospice, but CMS's treatment of every hospice as guilty until proven innocent is not the answer. Establishing contractors such as RACs and ZPICs as bounty hunters is not appropriate since they are paid based on what they deny.  The impact of the above appears to show that CMS is trying to close hundreds of hospices.

The federal government always advertises to our senior citizens that Medicare will cover their most of their health care needs.  What they do not tell seniors is they are working diligently to reduce access to home health, hospices, physicians and other Medicare providers.  They have several methods to reduce access by reducing payments for services, denying claims, adding new rules and regulations.  We should continue to be advocates for our senior citizens to ensure they receive the Medicare services they deserve.

Even private duty home health agencies are not immune to the increase government rules and regulations.  The government is not concerned about the care available to the patients in their home or the patient's ability to pay privately for care, or even the increased cost of their government regulations on Medicaid Waiver programs.  The impact of the proposed changes to the companionship exemption and overtime rules shows their lack of concern.

Only the strong and well informed home health agencies, hospices, and private duty agencies will survive in the future.  To keep our clients and friends informed and up to date we provide free email newsletters, we produce webinars, and we hold three day comprehensive seminars. 

Our company mission is to help our clients survive and flourish. Why not join us in Las Vegas in January or February for one of our three day seminars and learn to survive and flourish.

http://dixonhealthcaresolutions.com/las-vegas-seminars/