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.
Last week, the Office of Management and Budget (OMB) completed their work on a proposed rule that revises the home health Conditions of Participation (HH CoPs). CMS may send the proposed rule to the Office of the Federal Register for publication, according to NAHC. Once the proposed rule is published, interested parties will have 60 days to submit comments. Home health agencies must meet the Medicare HH CoPs to participate in the Medicare program. Any agencies that fail to meet any of the HH CoPs are at risk for the imposition of a number of sanctions and also may be at risk for program termination.
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.
CMS is to revalidate all providers and suppliers that were enrolled in Medicare before March 25, 2011. Newly enrolled providers and suppliers that submitted their enrollment applications on or after March 25, 2011, are not impacted. Once a provider or supplier is revalidated, they will be placed on a five year revalidation cycle. CMS has the authority to request revalidation sooner than five years, but that’s usually reserved for providers/suppliers suspected of fraud or abuse, or some other issue.
Click here to download files for all revalidation requests.
Hospice policy changes addressed in the final regulation are as follows:
Timeframes for Filing the Notice of Election (NOE) and Notice of Termination/Revocation (NOTR)
Timeframe for Hospice Cap Determination and Overpayment Remittance
Addition of the Attending Physician to the Hospice Election Form
Coding Guidelines for Hospice Claims Reporting
FY2015 Final Payment Rates
NAHC’s article provides an in-depth look at the new requirements for addition of attending physician to the hospice election form and for documentation of a change in a patient’s designated attending physician.
Click here for details on the new requirements from NAHC.
CMS has announced that its next Home Health, Hospice and DME Open Door Forum will be held this Wednesday, August 20. Key issues, including the revised hospice cost report for freestanding agencies, will be addressed. The link attached to the announcement appears to be the second version of the cost report that was issued November 22, 2013. It is not yet known whether these will be the actual, final cost report forms and instructions for freestanding agencies that CMS has indicated will be required for cost reporting years beginning October 1, 2014, and afterward, or if CMS will release another version that includes additional changes that were recommended during December 2013. NAHC points out that the cost report changes on the agenda, and the forms and instructions appear to be the versions that were released in November 2013.
Click here for more detailed information from NAHC.
CMS has officially announced the new deadline for ICD-10 implementation as October 1, 2015.
“Deadline for ICD-10 allows health care industry ample time to prepare for change.
The U.S. Department of Health and Human Services (HHS) issued a rule today finalizing October 1, 2015 as the new compliance date for health care providers, health plans, and health care clearinghouses to transition to ICD-10, the tenth revision of the International Classification of Diseases.
This deadline allows providers, insurance companies and others in the health care industry time to ramp up their operations to ensure their systems and business processes are ready to go on Oct. 1, 2015.”
Beginning July 1, 2014, Medicare Advantage Organizations (MAO) and other entities will be required to submit Health Insurance Prospective Payment System (HIPPS) codes on all skilled nursing facility (SNF) and home health care encounter data submissions as a result of a new requirement from CMS.
CMS is clarifying that for 2014 DOS beginning on or after July 1, 2014, MAOs must submit HIPPS code on a SNF encounter that comes from the initial OBRA-required comprehensive assessment (Admission Assessment). SNF encounters with “from” dates July 1, 2014 or after that are submitted without a HIPPS code will be rejected.The OBRA-required tracking records and assessments are federally mandated for all residents of Medicare and/or Medicaid certified SNFs and nursing facilities
CMS is clarifying that for 2014 DOS beginning on or after July 1, 2014, MAOs must submit a HIPPS code on an HHA encounter that comes from the initial Outcome and Assessment Information Set (Start of Care assessment), or OASIS. OASIS assessments are federally mandated for all Medicare and/or Medicaid patients receiving skilled care from HHAs.
Being unprepared for ICD-10 could result in increased denials for your practice, impacting cash flow. HMS’ team of expert coders can get you on the right track to ICD-10 readiness/compliance so you can maintain your revenue stream.
Assessment package includes review of 10 records for $250:
A comprehensive review of each record submitted.
An analysis outlining findings on a clear and concise report.
A detailed summary report providing an in-depth explanation of each record reviewed.
Documentation, recommendations, and cross references to coding guidelines when applicable.