CMS Issues Home Health Coverage Manual Updates

CMS has updated the Medicare Benefit Policy Manual, Chapter 7, with Change Request (CR) 9119, relating the requirements for physician certification and recertification. This CR also updates the timeframe required for therapy functional assessments. The CR, however, leaves questions for providers regarding CMS’ expectation for implementing some of the new provisions. NAHC is currently seeking answers from CMS.

CMS states it has eliminated the narrative requirement from the face-to-face (F2F) encounter document. However, the certifying physician is still required to certify that a F2F patient encounter occurred. The encounter document should include the date of the encounter, be related to the primary reason the patient requires home health services, and be performed by an allowed provider type.

In the updated manual revision, CMS affirms a new requirement for documentation that was stated in the 2015 HH PPS Final Rule. When a patient is admitted to home health directly after discharge from an acute or post-acute care setting and the physician who cared for the patient in that setting is the certifying physician, but will not be following the patient after discharge, the certifying physician must identify the community physician who will be following the patient. CMS says the certification must be completed prior to when the home health agency bills Medicare. CMS reiterates that is not acceptable for HHAs to wait until the end of a 60-day episode of care to obtain the completed certification/recertification.

Click here to view CR 9119.

Click here for more detailed information regarding CR 9119 from NAHC.

Report: Medicare Fee-For-Service Consumes Most Medicare Outlays

According to a new report from the Catalyst for Payment Reform, more than half of the $360 billion in Medicare payments made two years ago were based on traditional fee-for-service models without regard to quality or value.

However, as the government moves toward outcomes-based payment models, the number is expected to shrink significantly. The U.S. Department of Health and Human Services (HHS) is pushing to tie at least half of all traditional fee-for-service Medicare payments to quality or value through alternative payment models by the end of 2018.

Click here to read more.

CMS Delays Requirement That Part D Prescribers Be Enrolled In Medicare Or In Valid Opt-Out Status

CMS has released an interim final rule delaying a regulatory requirement that prescribers of Part D medications that are eligible to enroll in Medicare either be enrolled in Medicare approved status or in a valid opt-out status.

The enrollment requirement was scheduled to go into effect on December 1, 2015 but now will go into effect on January 1, 2016. Furthermore, “in cases where Part D enrollees submit prescriptions for processing through Part D that are not prescribed by an eligible professional that is either enrolled in Medicare in an approved status or is in a valid opt-out status, the Part D plan must provide a provisional prescription (3 month supply) for the Part D enrollee to allow the prescriber time to either enroll in Medicare or to allow the patient time to secure a prescription from another professional.”

Click here to see the regulation.

Click here to read more.

PEPPER Updates For Home Health & Hospice

TMF Health Quality Institute, CMS’ contractor for the Program for Evaluation Payment Patterns Electronic Reports (PEPPER), hosted a webinar on April 30 to present PEPPER updates and to announce the addition of PEPPER for home health agencies.

PEPPER summarizes Medicare claims statistics for one provider in targeted areas that may be at risk for improper Medicare payments.

NAHC has put together a summary of updates, including target areas, for both home health and hospice.

Click here to see it.

CMS Releases A Proposed Hospice Payment Rule

CMS has released a proposed payment rule for fiscal year (FY) 2016 that address payment reform of the routine home care (RHC) level of care by providing a differential payment of two separate rates. One rate is for care provided from day one through day 60 of an episode of hospice care and another for days 61 and after.

In the proposed rule, CMS also provides for a Service Intensity Add-on (SIA) that would be added to RHC payment for RN and social work visits provided during the last seven days of life. The rule “conveys CMS’ intent to transition the hospice Cap year to the federal fiscal year and implement the alternative method for annual updates to the aggregate Cap mandated by the IMPACT Act, signals CMS’ future intent relative to public reporting of hospice quality data, and clarifies that hospice programs must submit on claims all diagnoses (related or unrelated) of patients under their care.”

NAHC is currently conducting an in-depth analysis of the proposed regulation and its potential impact on hospices.

Click here to see the proposed rule.

Click here for more details from NAHC.

Tiptastic Tuesday: 4 Essential Steps For Healthcare Compliance

According to new guidance from the U.S. Department of Health and Human Services’ Office of Inspector General (OIG), healthcare providers must focus on four major principles in order to create effective compliance programs.

The increase in fraud crackdowns means compliance is more important than ever. OIG collaborated with industry leaders to develop the four following guidelines:

  1. Define your audit, compliance and legal departments’ jobs and relationships with one another. Make sure each department understands its role in the compliance process.
  2. Assess your organization’s protocols for gathering information and reporting issues. Make sure each compliance-related sector reports on its compliance and risk-management efforts and measures its implementation of compliance programs.
  3. Identify and audit potential risk areas. Make sure to establish clear processes for risk identification.
  4. Encourage compliance throughout the enterprise. The OIG recommends regular performance assessments to help facilitate this process.

Click here to see the guidance.

Click here to read more.

Medicare To Pay Hospices $200 Million More In 2016

CMS is proposing that hospices get a 1.3% rate increase from Medicare in a newly issued rule. The rule means Medicare would spend $200 million more on hospices in 2016 than in 2015.

CMS is also using the rule is clarify how to properly document a diagnosis on claims forms. CMS said it is “concerned that some hospices are neither conducting a comprehensive assessment nor updating the plan of care as articulated by the conditions of participation to recognize the conditions that affect an individual’s terminal prognosis.”

Under the new rule, hospices would be required to report all diagnoses identified in initial and comprehensive assessments on hospice claims – whether they are related or unrelated to the patient’s terminal prognosis.

Click here to read more.