Medicare Issues Final Rule for Home Health CoPs - 1/10/2017

On Friday January 9th CMS issued the new Conditions of Participation for Home Health Agencies.  They will be published in the Federal Register on January 13^th.  This final rule revised the conditions of participation (CoPs) that home health agencies (HHAs) must meet to participate in the Medicare and Medicaid programs.  The requirements focus on the care delivered to patients by the HHAs, reflect an interdisciplinary view of patient care, allow HHAs greater flexibility in meeting quality care standards, and eliminate unnecessary procedural requirements.  The effective date for the regulations is July 13, 2017.

Jnon Griffin will be addressing the new CoPs at our New Directions in Home Care seminar that will be held in Las Vegas on January 26^th & 27^th.  We have some space available for the seminar, but it is important to register immediately to ensure you seat.  We have listed a temporary link to the new CoPs below.  The final rule will be published in the Federal Register on January 13th.

Link

https://s3.amazonaws.com/public-inspection.federalregister.gov/2017-00283.pdf

Broken Bone Update 1/5/2017

Last month I provided an update on my gracious fall from a ladder, which broke a bone in my left foot.  After seven weeks, I am now able to walk on the foot without the boot.  I went upstairs for the first-time last week since November 13^th.  I found a new bed in my bedroom.  I have been sleeping and working in my old bed for the last seven weeks downstairs.  I will no longer go up on high ladders.  It is much cheaper and less painful to pay someone to do that job.

Margaret and I have been working hard preparing for the Home Health and Hospice seminars that will be held at Bally’s in Las Vegas on January 26^th and 27^th.  We have been preparing the seminar notebooks and making other final preparations.  We have some space available for both seminars, but please register as soon as possible to ensure you reserve your spot.  I believe this will be one of our best seminars ever.  I look forward to seeing you in Las Vegas.

Richard Dixon

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