Recent CMS Changes & Revisions For Hospices

CMS has issued Transmittal 123-Revisions to State Operations Manual For Home Care and Hospice. These revisions affect Chapters 1, 2 and 3 of the Manual. CMS has also released Change Request 8501-Instructions to MACs for Defending Medical Review Decisions.

Click here for more detailed information about the new revisions and change requests from NAHC.

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Proposed Rule On Conditions Of Participation For Home Health Agencies

CMS has issued a proposed rule to improve Medicare’s Home Health Agency Conditions of Participation to ensure safe delivery of quality care to home health patients. The proposed rule reflects the most current home health agency practices by focusing on the care provided to patients and the impact of that care on patient outcomes.

The proposed rule focuses on key changes in the home health industry, including promotion and protection of patient rights, enhancing the process for care delivery and coordination of services, streamlining regulatory requirements and building a foundation for ongoing, data-driven, agency-wide quality improvement.

To see the full text of the rule, click here.

Providers Should Be Prepared For HIPAA Audits

The Office of Civil Rights will begin to audit providers from large to small across the country. The best option for providers is to prepare to be in compliance and to conduct a comprehensive risk analysis. Although that advice may seem obvious to some, the OCR’s auditing process is “something of a mystery to healthcare providers,” according to experts. The OCR typically looks for patterns. For example, if the office receives information about a given provider having several similar breaches and it appears they are not doing anything about them, this suggests to the OCR that the provider is not in compliance or does not have proper procedures set in place.

Click here to read more.

RACs Recouped $3 Billion For Medicare Last Year

A new government report shows Medicare’s recovery auditors returned more than $3 billion into the program’s coffers last year. Providers that appealed those audits won less than 1 in 5 tries. In total, RACs found $3.75 billion in incorrect payments made to hospitals and doctors in FY 2013, according to CMS’ annual RAC report to Congress. $3.65 billion of the amount was related to overpayments. The government report also states that only 18.1% of all claims that providers took to the Medicare’s appeals process were overturned in favor of the provider.

Click here to read more.

OASIS (HHA) To QIES Assessment Submission & Processing (ASAP) System (Posted 5/28/2014)

Attention: Effective January 1, 2015, OASIS assessment data will be submitted to CMS via the national OASIS Assessment Submission and Processing (ASAP) system.

With the implementation of the OASIS ASAP system, Home Health Agencies will no longer submit OASIS assessment data to CMS via their state databases.

In order to transition data from the state databases to ASAP, the OASIS submission system will shut down at 6:00 p.m. ET on December 26, 2014. The OASIS ASAP system will be available at 12:00 a.m. ET on January 1, 2015.

Files submitted on or after January 1, 2015 must follow version 2.10 (which supports OASIS-C) and version 2.11 (which supports OASIS-C1) of the OASIS data submission specifications.

Reimbursement For Administrating Flu Shot

Reimbursement for the vaccine administration for home health agencies is based on the outpatient prospective payment system (OPPS) vaccine administration rate,
which is determined each calendar year (CY). The 2014 OPPS rate for the influenza vaccine administration is $29.50.This rate is in effect for CY  2014.

Sixty percent of the rate is wage adjusted using the hospital wage index  core based statistical area (CBSA). For home health agencies, vaccines are reimbursed  based on the reasonable cost.

To determine the amount the HHA will be reimbursed for the vaccine administration, the agency will need to use the hospital wage index that applies to the CBSA where the service is furnished and adjust 60 percent of the national unadjusted payment for vaccine administration by the applicable wage index.

In 2014, for example, the national unadjusted payment rate is $29.50.  If the hospital wage index for the applicable CBSA is .99, payment to the HHA will be $29.32

$29.50*.6=$17.70 (the portion to be wage adjusted); $17.70 *.99 (the wage index) =$17.523 (the wage adjusted portion of the payment) $17.523+$11.80 (the 40% of the national unadjusted payment that is not wage adjusted)= $29.32 (after rounding).

*Information above provided by NAHC

Also, nursing homes are mandated to offer the flu vaccine to their residents. If you have a nursing home resident on the hospice benefit, it is the nursing home’s responsibility to manage the payment and should not come out of your per diem rate.

Federal Fair Labor Standards Effective January 1, 2015

The Department of Labor’s Final Rule, effective January 1, 2015, brings important minimum wage and overtime protection to workers who enable individuals with disabilities and the elderly to continue to live independently in their homes. The Final Rule contains significant changes from the prior regulations, including (1) the tasks that comprise “companionship services” are more clearly defined; and (2) the exemptions for companionship services and live-in domestic service employees are limited to the individual, family, or household using the services; and (3) the recordkeeping requirements for employers of live-in domestic service employees are revised.

Click here for more info on the Final Rule.