CMS has released Transmittal 125, which revises the State Operations Manual (SOM), chapter 2, sections 2180 through 2202.19. These sections govern CMS’ policy for home health agencies. The transmittal updates the SOM with revisions to chapter 2 that were issued earlier this year in a Survey and Certification letter. The letter included instructions for home health agency alternate sanctions, which has been incorporated into the SOM as chapter 10, and revised Appendix B, Guidance to Surveyors-Home Health Agencies.
The revision to chapter 2 reflects CMS policy changes that have occurred over the years, and also includes structural changes and reorganization of sections for clarity. The following are some of the key changes:
- Revised web sites and policy information;
- Sections on HHA branches have been renamed and revised to clarify current CMS policy on branches;
- Sections that are no longer applicable have been deleted;
- The survey process information has been deleted from this Chapter and updated and moved to Appendix B Guidance to Surveyors – Home Health Agencies; and
- The OASIS requirements in sections 2202-2202.18 have been updated to reflect current CMS policy and Federal regulations.
Click here to read more from NAHC.
According to NAHC, the Department of Veterans Affairs (VA) has started issuing notices to inform home health providers of the VA’s revised payment methodology for SNF services. Starting on October 1, 2014, the VA will require an Outcome and Assessment Information Set (OASIS) to be completed to generate a health insurance prospective payment system (HIPPS) code to reimburse non-contracted home health agencies for skilled home health services using the Medicare home health prospective payment system (HHPPS). The VA will continue to pay a per diem rate for non-contracted hospice providers.
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The Centers for Medicare & Medicaid Services (CMS) issued a notice announcing proposed changes to the Outcome and Assessment Information Set (OASIS) in the June 21 Federal Register. The proposed version reflects changes to accommodate ICD-10-CM coding set which go into effect October 1, 2014.
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The Office of Inspector General’s (OIG) 2012 Work Plan includes review of the Centers for Medicare & Medicaid’s (CMS) oversight of home health agencies’ compliance with submission of accurate and complete Outcome and Assessment Information Set (OASIS) data. Pursuant to this review, OIG’s Boston Regional Office has notified 70 home health agencies in Region 1 that their agency’s OASIS claim submissions are under review. The OIG Audit Manager, Mike Aubin, has told HMS Healthcare Management Solutions that this audit will go national in the next few weeks.
Click here for more on the audits from HMS Director of Consulting & Regulatory Affairs, Attorney Pamela Meliso.
HMS Healthcare Management Solutions has learned Region 1 Office of the Regional Inspector General (OIG) for Audit has targeted 60 Home Health Agencies (HHAs) in the New England area for review of the Outcome and Assessment Information Set (OASIS) transmissions as a condition for payment.
The OIG has cross-walked Common Working Files (CWF), which deny claims for primary payment that are submitted for applicable individuals during the 30-month coordination period, with OASIS state repositories. Agencies without matching OASIS dispersions will be audited.
It’s unclear at this time if Requests for Anticipated Payments (RAPs) are subject to the condition for payment or just finals. HMS is also seeking information on how the Third Party Liability (TPL) Project here in Connecticut, which recently uncovered a purging of OASIS files, may impact this audit.
The notice being sent to New England HHAs serve as a precursor to what is sure to happen nationwide. As audits become more prevalent, agencies can turn to HMS for assistance with questions and concerns. Our experienced staff of consultants has a proven track record of success with federal and state audits and can support your agency through the process. Contact us today to find out how and stay tuned to the HMS Blog for details on this important issue as they continue to unfold.
Last month, representatives from the Centers for Medicare and Medicaid Services (CMS) participated in a panel discussion during the National Association for Home Care and Hospice (NAHC) March on Washington and Law Symposium education session in Washington, D.C. The discussion, which centered around regulatory and policy initiatives for 2012 and beyond, included an overview of OASIS, process measures, survey tools and available guidance manuals from the Survey and Certification Group.
The top ten home health survey deficiencies identified by the panel, several of which center on failure to comply with plan of care requirements, are listed below.
Top Ten Survey Deficiencies:
- G158 – Written Plan of Care established & periodically reviewed
- G159 – Plan of Care covers diagnosis, required services, visits, etc.
- G236 – Record with past/current findings maintained for all patients
- G337 – Assessment includes review of all medications
- G121 – Compliance with accepted professional standards/principles
- G229 – Supervisory visits if skilled care no less than once every 2 weeks
- G143 – Coordination of Patient Services
- G170 – Skilled Nursing Services furnished in accordance with Plan of Care
- G176 – RN prepares notes, coordinates, informs MD, other staff of changes
- G165 – Drugs and treatment administered only as ordered by physician
Materials from the session, including conference educational tools and handouts, can be accessed on the National Association for Home Care & Hospice (NAHC) website by clicking here.
The Office of Inspector General (OIG) released a report this week on its evaluation of the timeliness of submission of OASIS data by home health agencies (HHA).
The OIG study Limited Oversight of Home Health Agency OASIS Data focused on the role of OASIS in Medicare payment, quality measures, and compliance with the home health conditions of participation (CoP). Although The Centers for Medicare and Medicaid Services (CMS) agreed with only one of the three recommendations made by OIG, they did spell out plans to develop an interface between OASIS and claims files, with a target date of October 2012, where any home health claims submitted without an OASIS assessment will be denied.
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