OIG Would Like More Home Health Surveys

The HHS Office of Inspector General (OIG) issued a report on Home Health Agencies Survey’s.  They did this study to determine if State agencies and accreditation organizations conducted timely recertification surveys of HHAs.  They also identified the extent to which HHAs received deficiency citations, corrected deficiencies, or had complaints lodged against them.

They found that State agencies and accreditation organizations conducted recertification surveys for nearly all HHAs within the required 36-month timeframe and cited 12 percent of HHAs with “condition”-level deficiencies, the most serious type of deficiency.  Ninety-three percent of these HHAs corrected their condition-level deficiencies within the required 90-day timeframe; the remaining 7 percent correct the deficiencies late or left Medicare.  Fifteen percent of the HHAs had complaints lodged against them; surveyor’s conducted complaint investigation surveys for nearly all of these HHAs and cited 7 percent of them with condition-level deficiencies.  With few exceptions, HHAs corrected all condition-level deficiencies cited during the complaint survey.

They recommend that CMS analyze survey data to determine whether it should routinely conduct look-behind surveys for oversight of State agencies, which conduct most HHA recertification surveys.  CMS has concurred with their recommendations.

To view the OIG Report go to:

http://oig.hhs.gov/oei/reports/oei-06-11-00400.pdf

CMS Proposed 1.1% Payment Increase for Hospice

CMS has issued its Proposed Rule FY 2014 Hospice Wage Index and Payment Rate Update.  It has yet to be published in the Federal Register.  The proposed rule will be published in the Federal Register on May, 13. The rule would increase hospice payments by 1.1%.  It proposes to replace the current quality reporting system in 2016 with new a system that requires to hospice to collect and submit new patient-data forms.  It also proposes beginning in 2017 to implement a hospice experience-of-care survey for families and friends of hospice patients.

Look for more information in a future Email Alerts.  To view the CMS Fact Sheet go to:

http://www.cms.gov/apps/media/press/factsheet.asp?Counter=4588&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=&cboOrder=date

CMS Plans to Have a Fifth RAC for Home Health, Hospice & DME

The Center for Medicare & Medicaid Services (CMS) is planning on making significant changes to the Recover Auditor Program (RAC) in 2014.  It plans to consolidate all Home Health, Hospice, and DME RAC duties to a new nationwide RAC.  Yes there will be a new RAC to review Home Health, Hospice and DME claims. 

CMS will also require the RAC auditors to support CMS in the administrative appeals process.  This will require the RAC auditors to defend their denials all the way to federal court if necessary.  They will be required to represent CMS at any hearings if requested by CMS.  These new requirements will hopefully make the RACs act in a more responsible manor, since the appeal process will require utilization of their resources.

Look for more information in a future Email Alerts.

CMS Announces Temporary Delay in PECOS Edit Implementation Temporary Delay in Implementing Ordering and Referring Denial Edits

Due to technical issues, implementation of the Phase 2 ordering and referring denial edits is being delayed. These edits would have checked the following claims for an approved or validly opted-out physician or non-physician who is an eligible specialty type with a valid individual National Provider Identifier (NPI). If either of these were missing or incorrect, claims would deny.

• Medicare Part B claims from laboratories, imaging centers and Durable Medical Equipment, Orthotics, and Supplies (DMEPOS) that have an ordering or referring physician/non-physician provider; and  
• Part A Home Health Agency (HHA) claims that require an attending physician provider. 

CMS will advise you of the new implementation date in the near future. In the interim, informational messages will continue to be sent for those claims that would have been denied had the edits been in place.

MedPAC Recommends 3% to 5% Cut for Hospice SNF Residents

On April 4, 2013 Kim Neuman and Sara Sadownik MedPAC staff members spoke at a meeting in the Ronald Reagan Building concerning Medicare Hospice Policy Issues.   They reviewed MedPAC’s recommendations for hospice payment reform.  One of the recommendations was a 3% to 5% cut for Hospice patients who reside in Skilled Nursing Facilities.  They also discussed other issues such as the U-Shaped payment method which would pay hospice’s a higher rate at the beginning of care, lower rates during the middle of care, and a higher rate on the last seven days of the patients life. 

For more information please utilize the following link.

http://www.medpac.gov/transcripts/hospice_April_2013_presentation.pdf

CMS Issues Fact Sheet for Implementation Improvement Standard

On January 24, 2013 the U.S. District Court for the District of Vermont approved a settlement agreement in the case of Jimmo V. Sebelius.  The case involved skilled care being denied by contractors based on a rule-of thumb “Improvement Standard” – under which a claim would be summarily denied due to a beneficiary’s lack of restoration potential, even though the beneficiary did in fact require a covered level of skilled care in order to prevent or slow further deterioration in his or her clinical condition.

CMS agreed to the settlement agreement.  The language in the settlement agreement did not modify or expand existing eligibility requirements for receiving Medicare coverage. 

On April 4, 2013 CMS issued a fact sheet that describes their plans to conduct the following activities under the term of the settlement agreement.

1.     Clarifying Policy & Updating Program Manuals

2.     Develop an Education Campaign to inform stakeholders

3.     Preform a claims review to ensure beneficiaries are receiving care

CMS agrees to complete the manual revisions and educational campaign by January 23, 2014.

For more information please utilize the following link.

http://www.cms.gov/medicare/medicare-fee-for-service-payment/SNFPPS/downloads/jimmo-factsheet.pdf

CMS Rescinds Modifier on Medicare Claims

On April 2, 2013 CMS published Transmittal 2680 to remove the modifier to visits not ordered by the certifying physician for episodes starting July 1, 2013. 

The requirement to report where home health agencies and hospices services are provided remains the same.  Beginning on or after July 1, 2013, HHAs must report where home health services were provided.  The following codes are used for this reporting are listed below:

Q5001: Hospice or Home Health Care provided in patient’s home / residence

Q5002: Hospice or Home Health Care Provided in Assisted Living Facility

Q5009: Hospice or Home Health Care provided in a place not otherwise specified (NO)

If the location where services were provided changes during the episode, the new location should be reported with an additional line corresponding to the first visit provided in the new location.

For more information please utilize the following link.

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2680CP.pdf