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.

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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.

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CMS Posts Specifics For Five Star Rating System For LTC

Under a new payroll system scheduled to become mandatory in July 2016, CMS has posted technical specifications to show long-term care facilities how to electronically submit staffing information based on payroll data. Long-term care facilities will now be able to voluntarily submit data beginning in October 2015. The new Payroll-Based Journal (PBJ) system will be posted on the CMS Nursing Home Compare website and used in the Nursing Home Five Start Quality Rating System to help consumers understand the level and differences of staffing in long-term care facilities.

Click here for more information from CMS.

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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.

NAHC Offers Hospice “Survey Readiness” Educational Opportunity

Last year, President Obama signed The IMPACT Act into law requiring CMS to ensure that each Medicare-certified hospice undergoes a survey once every 36 months. This requirement became effective in early April 2015, allowing CMS and state survey agencies time to gear up to tackle the increased survey frequency.

Some hospices have not had a state survey since before the revised Hospice Conditions of Participation (CoP) went into effect in late 2008. Therefore, these agencies may have changed since the last time a surveyor assessed its adherence to the CoP.

NAHC is offering a 90-minute web event to help hospice agencies ensure they are survey ready. The session will review CMS’s implementation plans for the IMPACT Act and walk through the hospice federal recertification survey process.  Additionally, NAHC will review the steps the surveyors will take and the reports, forms and other documents hospices should have ready.

The web event, “Hospice Survey Preparedness and Readiness,” is scheduled for Wednesday, April 22, from 3:00 p.m. to 4:30 p.m. (Eastern).

Click here to register for the event.

Click here to read more from NAHC.

New QIO Report Highlights Nursing Homes’ Progress

A new progress report on CMS’ Quality Improvement Organization Program, a five-year project designed to enhance the quality of services for Medicare beneficiaries, notes key achievements since the implementation of the program. These achievements include significant reductions in adverse drug events, infections, wounds and use of restraints in nursing homes.

In August 2014, CMS redesigned the QIO program for which 5,000 nursing homes were recruited to participate. The following are some of the achievements among participating nursing homes:

  • 44,640 potential adverse drug events prevented
  • 3,374 pressure ulcers were prevented or healed in 787 facilities
  • 6,250 Medicare beneficiaries in 981 facilities are now restraint free
  • 85,149 fewer days with urinary catheters for Medicare beneficiaries.

The QIO program “hopes to unite nursing homes, key stakeholders and organizations throughout their communities to share tools, knowledge and technology to achieve system-wide improvement.” According to a recent Inspector General report, one in five nursing home residents suffer preventable harm.

Click here to read more.

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.”

Click here to read more.