CMS: Hearings Related To State Survey Actions Must Be Filed Electronically

CMS has issued a survey and certification letter stating that effective October 1, 2014, providers that disagree with actions imposed on their agencies/facilities and want to request a hearing with an Administrative Law Judge in the Civil Remedies Division must submit their request electronically to the Departmental Appeals Board using the DAB E-File. Click here to see it. Petitioners must first become registered users to utilize the electronic filing system. The letter includes an attachment that provides instructions on how to register and use the DAB’s Electronic Filing System.

Please note, written requests for hearings delivered by postal delivery are no longer accepted unless the petitioner does not have access to the internet or a computer. In those instances, the petitioner may call the Civil Remedies Division and provide an explanation as to why they cannot file electronically.

Click here to read the letter.

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Tiptastic Tuesday: 5 Changes To Help Medicare ACOs Thrive

In order for the Medicare Shared Savings Program to reach its full potential, some key changes must be made, according to the authors in a recent Health Affairs blog post. Medicare ACOs have made progress on care quality and patient experience, however, only 1 in 4 MSSP ACOs have cut spending enough to share in overall savings.

According to authors in Health Affairs, the Medicare Shared Savings Program needs to make the following changes to truly thrive:

  • Increased certainty: A major issue with MSSPs is uncertainty. In order to correct this, CMS should transition to a benchmark calculation formula that combines ACOs’ historical spending and regional spending to eventually transition to a benchmark based completely on regional spending.
  • Clear definition of the transition away from fee-for-service: CMS should drive the transition with incentives greater than those for fee-for-service for organizations that demonstrate reduced costs and improved quality.
  • Alignment of MSSP with other Medicare reimbursement programs: In order to get MSSP and other Medicare alternative payment models on the same page, the authors recommend risk adjustment calculations, reporting mechanisms and requirements, and consistent quality measures.
  • Patient engagement: ACOs need more support to communicate and engage with their patients. The authors suggest expanding CMS’ pilot program for Pioneer ACOs’ “attestation models.”
  • Use of pointers from commercial ACOs: Many ACOs in the private sector have seen more success than those under Medicare by shifting away from fee-for-service with limited financial risk. CMS “should seek to reinforce those successful steps.”

Click here to read more.

Reminder: Educational PEPPER Webinar On April 30

CMS, through its contractor, TMF Health Institute, will be providing an educational PEPPER webinar for home health and hospice agencies on April 30 from 11:00 a.m. to 12:30 p.m. (CDT). The webinar will provide updates on the Q4FY14 PEPPER for Hospices, Skilled Nursing Facilities, Long-term Acute Care Hospitals, and Inpatient Rehabilitation Facilities. Additionally, the webinar will provide a preview of the PEPPER reports home health agencies will be receiving for the first time this coming July.

No registration is required to access the webinar. Click here at the time of the event.

The event number: 923 918 378

The event password: lantana

Click here to read more.

CMS Requests Approval For The OASIS C1/ICD-10 Data Item Set

CMS is requesting approval by the Office of Management and Budget (OMB) for an Outcome and Assessment Information Set (OASIS) data set to accommodate the International Classification of Diseases (ICD)-10. The newest version of the OASIS is referred to as the OASIS C1/ICD-10 data item set.

The OASIS-C1 data item set could not be implemented on October 1, 2014 due to the Protecting Access to Medicare Act of 2014 (PAMA) being enacted. PAMA prohibited the Secretary from adopting ICD-10 prior to October 1, 2015. Since ICD-10 had been delayed until October 1, 2015, CMS made interim changes to the OASIS-C1 data item set to accommodate the continuation of the ICD-9 diagnosis codes. Five of the data items which used ICD-10 codes were modified.  The current version of the data item set for OASIS-C1/ICD-9 is still in use until the implementation of ICD-10.

The OASIS C-1/ICD-10 version replaces the five items that were modified in the OASIS C1/ICD-9 version.  OASIS C-1/ICD-10 is “essentially the OASIS C1 with a few technical and typographic corrections and a new name.”

Click here to read more.

 

Tiptastic Tuesday: How To Spot Signs Of Elder Abuse

According to The Elder Justice Roadmap, a report by the U.S. Department of Justice and the Department of Health and Human Services, five million Americans are affected by elder abuse every year. Abuse of the elderly can be difficult to pinpoint as its signs could appear to be symptoms of dementia or the natural results of frailty that come with growing older. It is important to know that elder abuse is not always physical and  includes other categories, including sexual, psychological, and financial neglect.

Be on the lookout for the following common signs that abuse may be happening:

  • Frequent arguments between the caregiver and the patient
  • Changes in a senior’s personality or behavior
  • Unexplained injuries like burns, bruises, welts, cuts or scars
  • Broken bones, dislocations and sprains
  • Failure to take medication or overdose of medication
  • A caregiver’s refusal to let you see the patient alone
  • Appearing disheveled, in torn or soiled clothing, or not being appropriately dressed for the weather
  • Appearing hungry, malnourished, disorientated or confused
  • Unexplained charges or a suspicious drain of money
  • Unexplained weight loss

If you notice something strange, it is important to notify authorities or to report it to Adult Protective Services (APS).

Click here to read more.

CMS Corrects Inaccurate Info On The Home Health F2F Requirement

Earlier this month, CMS held a Special Open Door Forum for the voluntary electronic and paper clinical template for the home health Face-to-Face (F2F) encounter document. During this call, a presenter provided inaccurate information regarding what would be acceptable documentation within the physician’s medical record to support home health eligibility.

Several participants questioned the presenters about the CMS policy that allows a physician to sign information from an agency’s assessment and incorporate it into his or her medical record to support eligibility. CMS answered by comparing agency documentation to consultation notes that may be found in a physician’s record, saying that CMS does not actually consider these documents to be a part of the physician’s record, since they are not generated by that physician. CMS indicated it would only look for documentation the physician generated to support home health eligibility. However, this interpretation goes against what CMS has spelled out in the final rule for home health prospective payment system (HHPPS) rate update.

NAHC contacted CMS requesting clarification of this matter. On March 24, CMS released the following statement:

“In reviewing the transcript, CMS realizes that inaccurate information was provided related to HHA documentation to support certification for home health services.  Per 42CFR 424.22 (a) and (c), the patient’s medical record must support the certification of eligibility and documentation in the patient’s medical record shall be used as a basis for certification of home health eligibility.  Therefore, reviewers will consider HHA documentation if it is incorporated into the patient’s medical record and signed off by the certifying physician.   More guidance will follow regarding the review of home health claims shortly.  CMS apologizes for the confusion.”

Click here to read more.

Home Health Star Rating System Begins In July

CMS has announced plans to implement a five star rating system for home health agencies on the Home Health Compare website starting in July 2015. The Home Health Compare (HHC) Star Rating includes nine of the 22 currently reported process and outcome quality measures. These measures include three process measures, five outcome measures, and one claims based measure. The methodology for calculating “is based on a combination of individual measure rankings and the statistical significance of the difference between the performance of an individual HHA on each measure and the performance of all HHAs.” These quality measure values for HHAs are compared to the national agency median with their rating adjusted to reflect the differences relative to other agencies’ quality measure values. The adjusted ratings are then combined into one overall HHC Star Rating that summarizes each of the nine individual measures.

Please note, CMS is sponsoring a webinar to review the format of the report and the process for requesting review of the HHC rating on March 26, 2015, at 1 p.m. ET. Click here to register for this webinar.

Click here to view frequently asked questions on the HHC Star Rating System.

Click here to read more.