Change on the Horizon
The 2015 update to Home Health PPS is considerable and provides for major and minor changes, plus a lot of interesting information. Here’s the bullet points.
Reduction in Payment
No news here. Everyone was expecting a decrease in payment. It comes to approximately $81.00 subtracted from the standard episode rate. The standard episode rate is that dollar amount which is adjusted by OASIS and other factors to find the final payment rate. In contrast, the per visit rate has gone up slightly.
Face to Face documentation requirements
A face-to-face document is still required but the narrative section has been removed effective January 1, 2015. Within the regulations the effect of the Face-to-Face requirement has been described as follows:
- The error rate for home health claims was calculated to be 17.5 percent.
- The majority of home health improper payments were due to “insufficient
documentation” errors. “Insufficient documentation” errors occur when the medical documentation submitted is inadequate to support payment for the services billed or when a specific documentation element that is required (as described above) is missing. Most “insufficient documentation” errors for home health occurred when the narrative portion of the face-to-face encounter documentation did not sufficiently describe how the clinical findings from the encounter supported the beneficiary’s homebound status and need for skilled services, as
required by §424.22(a)(1)(v).
- CMS-1611-F Page 37
Important: All episodes beginning with an OASIS Start of Care assessment will require Face-to-Face documentation. While the risk of denial related to the narrative has been reduced, agencies will have far more opportunities to make an error. This includes patients who return to service after being discharged and patients who were in the hospital over day 60 of an episode and must be readmitted for purposes of billing.
MD/hospital documentation: The regulations state that if requested, an agency must cough up the hospital’s documentation if the patient was admitted directly from the hospital or the physician’s notes that demonstrates eligibility. This should be happening already but from reading clinical records, it is obvious that often the nurses caring for the patient are not reading the hospital documentation. Do not wait until 2015 to add getting the MD records in the chart prior to billing.
Interesting and Important: I think the following excerpt is saying that if agencies provide the physician with the information to support eligibility, the physician may use it if he or she signs off on it. This is in stark contrast to not being able to help the physician compose the narrative. Read for yourself and feel free offer your own opinion.
The initial assessment visit must be done to determine the immediate care and support needs of the patient and to determine eligibility for the Medicare home health benefit, including homebound status. The Medicare CoPs, at §484.55(b), require a comprehensive assessment to be completed in a timely manner, consistent with the patient’s immediate needs, but no later than 5 calendar days after the start of care, and for eligibility for the Medicare home health benefit to be determined, including homebound status. We would expect that the findings
from initial assessment and/or comprehensive assessment of the patient would be communicated to the certifying physician.
The certifying physician can incorporate this information into his/her
medical record for the patient and use it to develop the plan of care and to support his/her certification of patient eligibility. The certifying physician must review and sign off on anything incorporated it into his or her medical record for the patient that is used to substantiate the certification/re-certification of patient eligibility for the home health benefit.
End in Sight
Twice in the Federal Regs, there is a directive that all patients whose care extends into a second episode, must be recertified with a documented estimated end in sight for skilled care. I really thought I missed something in the proposed regs but Lisa Selman-Holman did not see it, either. Regardless of who saw what, the directive is in place. Be careful of ‘statutory’ reasons for denial. This has the potential to be like dates, signatures, etc. Once it is identified that a recertification did not meet requirements, a full denial can be issued.
There are some changes to the payment calculations. I am hoping that someone with a better head for math than myself with go through all the numbers and explain to us the difference. Consider that a cry for help.
There has always been a provision in the Prospective Payment System for a 2 percent penalty for those agencies that did not submit OASIS data. Nobody knew what that meant. Did it mean penalties for no data submission or less than 100% data submission? It has finally been clarified for agencies as 70% of qualifying episodes in 2015 with gradual increases over the next several years.
Since it is now a requirement for payment that the OASIS data used to determine payment be in the state repository prior to billing, this new definition strikes us as ‘late’ for lack of a better word. If you are not sure of your data submission status, call us now. You need help.
Value Based Purchasing
Value Based Purchasing is recycled Pay-for-Performance. The actual indicators that will factor into any payment adjustments have yet to be determined which was common theme in the P4P predecessor. Although this is not our first rodeo with the concept of Value Based Purchasing, this one may stick. Keep your ears to the ground for more information.
These regulations run through 259 pages but like most, there is a lot of fluff and stuff inserted between the good stuff. Take some time and read through the comments and look at some of the data. We will be doing so as well and posting anything interesting or important we find.
Good luck. It’s always an adventure when the regulations are changed.