CMS Holds Third Special Open Door Forum On F2F Encounter Templates

CMS held its third Special Open Door Forum call for the voluntary electronic clinical template for the home health face-to-face (F2F) encounter on May 20. CMS officials presented the latest version of the electronic and paper templates. The paper version is two pages and consists mostly of questions requiring a narrative response; the electronic version is a combination of questions that require a narrative response and checkboxes. Included in these revised versions is a “Progress Note Guidance” page that describes the purpose of the template and the criteria for the home health certification, including the F2F encounter.

During the forum, presenters reminded participants that the templates are not mandatory but can serve as a physician progress note and/or guide for documenting the F2F encounter for patients who are referred to home health care. CMS also informed participants that the Office of Management and Budget must approve the templates before they can be released. CMS estimates that it will take approximately six months.

The majority of the call was dedicated to a question and answer period related to process issues when a physician’s co-signature would be required on the F2F encounter document. CMS did not provide a definitive answer to these questions because it is currently reviewing its policies on co-signatures on the F2F encounter document. However, CMS was clear the progress note must be completed by the physician or the allowed non-physician practitioner.

Click here to view the revised electronic and paper F2F encounter templates.

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May 7 Online Forum Will Explain New Home Health Rating System

CMS is holding a one-hour, web-based open door forum on May 7 at 1:30-2:30 p.m. EST to explain the new set of star ratings for the Home Health Compare website. CMS will use the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) survey results to create Patient Survey Star Ratings for the Home Health Compare website.  The forum will describe the rationale and overview of the patient survey star ratings.

Click here to read more.

Important Medicare Physician Fee Schedule Update

The Medicare Physician Fee Schedule (MPFS) was updated using the Sustainable Growth Rate (SGR) Methodology as required by law. Beginning April 1, 2015, the SGR methodology required a 21% decrease in MPFS payments.

CMS took steps to limit the impact on Medicare providers and beneficiaries by holding claims paid under the MPFS with dates of services on and after April 1, 2015. Medicare is also holding therapy claims that no longer qualify for the therapy cap exceptions due to the expiration of the therapy cap exceptions process on April 1, 2015. In an effort to avert the negative update, “CMS must update payment systems to comply with the law, and implement the negative update.”

“Beginning on April 15th, 2015, CMS will release held MPFS claims, paying at the reduced rate, based on the negative update, on a first-in, first-out basis, while continuing to hold new claims as they are received. CMS will release one day’s worth of held claims, processing and paying at the rate that reflects the negative update. At the same time, CMS will hold the receipts for that day, thus, continuing to hold 10 days’ worth of claims in total. This is to provide continuing cash flow to providers, albeit at the rate that reflects the negative update. This “rolling hold” will help minimize the number of claims requiring reprocessing should Congress pass legislation changing the negative update.”

Please be aware that claims for services furnished on or before March 31, 2015 are not affected by the payment cut and will still be processed and paid under normal time frames.

Click here to read more.

*Information provided by NGS. 

MedPAC May Stop Covering “Low Value” Procedures

The Medicare Payment Advisory Commission (MedPAC) is considering a plan that would stop covering “low value” procedures and tests due to their return on investment being too low. The procedures cost Medicare nearly $6 billion a year but yield little benefit, according to panel members. MedPAC came to this decision after exploring the results of 2012 analysis that found $5.8 billion in claims were paid that year for “low value procedures,” including a computed tomography for lung cancer and a prostate-specific antigen test for prostate cancer. As an alternative, MedPAC might consider charging beneficiaries more for low value services. MedPAC leaders say the cost of these procedures “subtract from the availability of public resources for high-value services and ‘appropriate subsidies’ for low-income people.”

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CMS Delays Enforcement Of “Two Midnights” Rule

CMS is delaying enforcement of the “two midnight” payment policy for short hospital stays until the end of April. The delay allows Congress time to pass the package repealing Medicare’s sustainable growth-rate formula when it reconvenes on April 13. The legislation includes a six-month delay in enforcement of the payment rule. The “two midnight” rule assumes an admission was appropriate if a patient’s stay spanned two midnights and that outpatient observation status was appropriate if it did not.

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Medicare Providers Could Face Up To 100% Late Tax Penalties Under New Provision

Congress recently proposed a bill that would reset Medicare physician pay rates. However, details about the measure emerged that it would also include penalties as high as 100% for providers delinquent with income tax payments. According to the Government Accountability Office (GAO), thousands of Medicare providers are late paying their income taxes every year. Under the provision, the IRS would be allowed to impose late tax penalties as high as double the amount of the back taxes, reducing the offenders’ Medicare reimbursement checks. The current law sets the ceiling at 15%.

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NAHC Outlines CMS’ Revised Medicare Revalidation Policies

CMS has issued change request (CR) 9011 which updates the Medicare Program Integrity Manual on policies related to provider and supplier revalidations. In the manual, sections 15.29.1-15.29.10 are new and include policies that outline the process and timing for revalidations and subsequent deactivations.” CMS will now request that providers and suppliers respond to a revalidation request within 60 days of sending the revalidation letter.

Click here for more detailed information on the revalidation process, including how the new process works.

Click here to view CR 9011.