8/1/2013

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Home Health Regulatory Review

Presented by:

Deanna LoftusDirector of Regulatory Compliance

July 2013

Webinar Agenda

• ICD 10 Update• OASIS C-1 Proposed Rule• 2014 PPS Proposed Rule/Payment Update• Sequestration• Home Health Audits, Edits and Billing Changes• Potential changes on the horizon• Medicare Administrative Contractors

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ICD-10 Update

• Tabular and index of ICD-10-CM

• Addenda (changes since the 2012 version)

• Complete list of ICD-10-CM code titles – long and

abbreviated

• General Equivalence Mappings

• Reimbursement Mappings

• Duplicate ICD-9-CM and ICD-10-CM codes

http://cms.hhs.gov/Medicare/Coding/ICD10/2013-ICD-10-PCS-GEMs.html

ICD-10 Files

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Start Preparing for ICD-10 NOW

http://apps.who.int/classifications/icd10/browse/2010/en

http://cms.hhs.gov/Medicare/Coding/ICD10/index.html

http://www.cms.gov/Medicare/Coding/ICD10/Downloads/ICD-10Overview.pdf

Training and Preparedness Materials

• Get to know your top 25 diagnoses in your agency.

• Learn the documentation requirements for these diagnoses

first.

Training and Preparedness Materials Cont.

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OASIS C-1

OASIS C-1

• Changes needed to support ICD-10• Currently under proposal

• Comments due August 20, 2013• Implementation date would be Oct. 1, 2014

http://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-R-245.html?DLPage=1&DLFilter=CMS-R-245&DLSort=1&DLSortDir=descending

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OASIS C-1 Cont.

• Draft OASIS data Specifications v2.10.0 were also recently announced.

• Submission format change also as of Oct. 1, 2014

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/OASIS/DataSpecifications.html

OASIS C-1 Cont. (Wording Changes)

Text change from “i.e” to “for example”:

• M0150 – Response numbers 6 and 7 text • M1100 – Living arrangement c, change from “i.e” to “for example” and

additional wording “residential care home” added to end of description.• M1300 – responses 1 and 2• M1400 – responses 2 and 3• M1510 - responses 2 and 5 have change from “i.e” to “for example”, item

description change “since the previous Oasis assessment” was changed to “at the time of or at any time since the previous OASIS assessment”.

• M1700 – response 2• M1740 – response 2 • M1890 – response 1 • M2000 – item description 1 has change from “ ie.” to “for example” and adds

additional words in two separate places “significant” and “[non-adherence}”• M2310 – responses 3 and 5 have a change from “ ie.” to “for example” , the

item description has “seek and/or” added and response number 1 is completed reworded.

• M2430 – Responses 3 and 5 have a change from “ ie.” to “for example”.

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OASIS C-1 Cont. (Wording Changes Cont.)

Text change from “i.e” to “specifically”

• M1610 – response 2 • M1800 – Item description• M1880 – response 0 (b)• M1900 – Grid response/first column (a.) has change from “

ie.” to “specifically” and adds the text “and toileting hygiene”.

OASIS C-1 Cont. (Wording Changes Cont.)

M Item # Changing

• M01010 – Item is changing to M1011, item description changing to state ICD-10 and V, W, X, Y or Z codes, a new response of NA was added.

• M1020/1022/1024 – Items changing to M1021/1023/1025, description/instruction wording almost completely updated for ICD-10 and new M item response numbers. (Make sure to note changes to columns 2, 3, 4 under Diagnosis row, Description row and primary diagnosis row).

• M01032 – Item is changing to M1033, item description remains the same but the wording of the responses are different and more responses exist now. (CMS stated this was revised to collect data on factors that have been identified in the literature as predictive of hospitalization, and to order responses based on length of the appropriate look-back period.)

• M1040 – Item is changing to M1041, item description changes and response wording changes.

• M1045 – Item is changing to M1046, item description changes, response wording changes and one additional response added.

• M1050 – Item is changing to M1051, item description changes and response wording changes.

• M1055 – Item is changing to M1056, item description changes, response wording changes and item has one less response now.

• M2100 – Item is changing to M2102, one of the columns is being eliminated, the column descriptions have been revised, responses a – d and f have been updated to change “i.e” to “for example”, responses e and g have been updated to change “includes” to “for example”.

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OASIS C-1 Cont. (Wording Changes Cont.)

Miscellaneous Text Changes

M1306 – “(EXCLUDES Stage I pressure ulcers and healed Stage II ulcers)” added to the end of the description. M1308 - “(EXCLUDES Stage I pressure ulcers and healed Stage II ulcers)” added to the end of the description, one of the response columns was removed at all timepoints and the remaining column title is reworded. CMS stated this change was for increased harmonization and added a new item to take the place of the removed column information (See new item section).M1334 – 0 response removedM1340 – Wording of 1 and 2 responses revised to show different questions to goto nextM1910 – Item description completely changes, wording of all three (0, 1, 2) responses completely changes. M2004 – Almost the entire description is revised, the end of NA response is revised. M2015 – Two additional words added to the item description “adverse” and “significant”.M2040 – Part of the item description was updated to change from “prior to the current assessment” to “prior to his/her most recent illness,” M2250 – The Not Applicable column response descriptions for responses b – g have been almost completely revised. M2300 – Item description has been almost completely revised. M2400 – The item description has been revised, the not applicable response column for all responses have had wording description revisions.

OASIS C-1 Cont. (New Item at Discharge)

• M1309 Worsening in Pressure Ulcer Status since SOC/ROC was added to collect information on worsening pressure ulcer status using wording harmonized with the MDS and CARE instruments.

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OASIS C-1 Cont. (Items deleted at Discharge)

• Item M1350 reports whether the patient has a skin lesion or open wound that is receiving intervention from the home health agency, other than a surgical wound, pressure or stasis ulcer.

• Item M1410 reports the types of respiratory treatments (oxygen, ventilator etc) the patient is receiving at home.

• Item M2110 reports how frequently the patient receives assistance with activities of daily living from caregivers other than the home health agency.

OASIS C-1 Cont. (Items deleted at all Timepoints)

• Item M1012, Inpatient Procedures.• Items M1310, M1312, and M1314, which report the

length, width and depth of the pressure ulcer with the largest surface dimension.

• Item M2440 - Reason patient was admitted to a nursing facility. Collected at the time of transfer from home health to a skilled nursing facility.

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2014 HH PPS 2014 Proposed Rule

https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-15766.pdf

2013 vs. 2014 Payment Rates

• CMS is reporting that changes will result in an overall

reduction in payment of 1.5%

2013 Base Rate / Rural Base Rate 2014 Base Rate / Rural Base Rate

(PROPOSED)

$2,137.73/ $2201.86 $2,860.20/ $2,946.01

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2013 vs. 2014 Discipline Rates

Discipline 2013 Non-Rural / Rural 2014 Non-Rural / Rural

(PROPOSED)

HHA $51.79 / $53.34 $54.91 / $56.56

MSS $183.31 / $188.81 $194.34 / $200.17

OT $125.88/ $129.66 $133.46 / $137.46

PT $125.03 / $128.78 $132.56 / $136.54

SN $114.35 / $117.78 $121.23 / $124.87

SLP $135.86 / $139.94 $144.03 / $148.35

*note a 2% reduction to these rates when not submit ting quality data

2013 vs. 2014 Supply Rates

Non-Routine

Supply Rates (NRS)

*note a 2% reduction to

these rates when not

submitting quality data

Severity

Level

2013 Non-Rural / Rural 2014 Non-Rural / Rural

(PROPOSED)

1 $14.56 / $15.00 $14.53 / $14.96

2 $52.58 / $54.16 $52.45 / $54.03

3 $144.16 / $148.49 $143.82 / $148.14

4 $214.19 / $221.61 $213.67 / $220.10

5 $330.29 / $340.20 $329.49 / $339.40

6 $568.06 / $585.11 $566.69 / $583.74

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2013 vs. 2014 LUPA Rates

LUPA Add-On Rates

http://www.cms.gov/Center/Provider-Type/Home-Health-

Agency-HHA-Center.html?redirect=/center/hha.asp

*note a 2% reduction to these rates when not submitting quality data

2013 Non-Rural / Rural 2014 add on factors Non-Rural /

Rural (PROPOSED)

$95.85 / $98.73 SN – 1.8174 ($226.87 / $233.68)

PT – 1.6841 ($223.24 / $229.95)

SLP – 1.6293 ($234.67 / $241.71)

New Quality Measures

• Add two claims based Home Health Quality Measures

• Re-Hospitalizations• Emergency Department Use

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Removal of Diagnosis Codes

• Remove 170 Diagnosis codes from the Grouper effective January 1st, 2014

Case Mix Changes

• Across the board reduction to case mix weights• Re-calibrated to a 1.0 starting point

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Submitting Comments

• When commenting, refer to file code CMS-1450-P for Medicare.

• To be assured consideration, comments must be received at one of the addresses provided below, no later than 5 p.m. on August 26th, 2013.

• Two of the four ways to submit comments are: • Electronically at http://www.regulations.gov . Follow the

instructions under the "More Search Options“ tab.• By regular mail using the following address: Centers for

Medicare & Medicaid Services, Department of Health and Human Services, Attention: CMS-1358-P, P.O. Box 8016, Baltimore, MD 21244-8016.

Sequestration Still in Effect

• The 2011 Budget Control Act mandates cuts equally over 9 years (2013 – 2021)

• Does not apply to Medicaid

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Audits, Edits and Billing Changes

New 1500 Form

• CMS to being phasing in new form starting in January 2014

• Changes include:• “Social Security number” replaced with “ID#”• Addition of item number 21 to identify the

diagnosis code set being reported

http://www.nucc.org/

http://www.nucc.org/%5Cimages%5Cstories%5CPDF%5C1500_claim_form_change_log_2012_02.pdf

http://www.nucc.org/%5Cimages%5Cstories%5CPDF%5C1500_claim_form_2012_02.pdf

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PECOS

• Edits are for Home Health Providers only

• Edits are currently delayed

• However a Physician is still required by law to be enrolled in order

to order Home Health and Hospice services for Medicare patients.

• Warning Messages for Part A and Home Health providers who

order and refer:

• N272 - Missing/incomplete/invalid other payer attending provider

identifier

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-

MLN/MLNMattersArticles/Downloads/SE1305.pdf

PECOS Cont.

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Widespread Home Health Probe – F2F Documentation

• More comprehensive reviews of claims being instituted

• Encouraging providers to review their internal processes to

ensure that all of the criteria for coverage have been met and

documented in the medical record.

http://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~Jurisdiction%2011%20Home%20Health%20and%20Hospice~Articles~Home%20Health~97VQKU0732?open&navmenu=||

http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/downloads/SE1219.pdf

http://www.cgsmedicare.com/hhh/pubs/news/2013/0613/cope22393.html

http://www.cgsmedicare.com/hhh/coverage/Hospice_FTF_Encounter.html

Widespread Home Health Probe – F2F Doc. Cont.

• National Association of Homecare (NAHC) is looking for

Documentation denial feedback

https://www.surveymonkey.com/s/WJCFY7H

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F2F Clarification

• A Home Health Agency (HHA) is permitted to title the face-to-face

encounter document and add the date they received the signed

document if the physician has failed to title the face-to-face or date

his/her signature. The HHA may not alter the face-to-face encounter

document in any other way. The HHA must ensure the

documentation is complete prior to submitting the final claim.

http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/Downloads/Home-Health-Questions-Answers.pdf

Home Health Widespread Edits

• HIPPS Codes:

• 2CGK*

• 1BGP*

http://www.palmettogba.com/palmetto/providers.nsf/ls/Jurisdiction%2011%20Home%20Health%20and%20Hospice~949N8N6658?opendocument&utm_source=J11HHHL&utm_campaign=J11HHHLs&utm_medium=email

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Home Health Widespread Edits Cont.

• 1BGP* Southeast Results

http://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~Jurisdiction%

2011%20Home%20Health%20and%20Hospice~Resources~Medical%20Review~98R

LL51384?open&navmenu=||

CPT Update in 2014

• 175 new Codes• 107 Revisions• 47 deleted codes

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Medicare Advantage Plans and HIPPS

• Effective July 1st, 2013 Home Health agencies are required to include a HIPPS code on Medicare Advantage (MA) claims• While the requirement is effective in July, CMS will not

reject claims until December• CMS has instructed the MA plans to communicate

directly with Home Health Providers• Make sure you contact your MA plans

CMS Transitioning Eligibility Systems

CMS is in the process of terminating all Eligibility systems other than the HETS 270/271. • PPTN and VPIQ

• Multi Carrier System (MSC) - Discontinued

• ViPS Medicare System (VMS) - Discontinued

• FISS/DDE

• HIQA/HIQH – Currently still active

• ELGH/ELGA – Currently still active

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Other Items on the Horizon

Affordable Care Act Employer Mandate

• Was recently delayed until January 2015

• Bill proposed to change definition of full time employees

"Forty Hours Is Full Time Act."

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Stay in Tune with your MAC

Home Health & Hospice Jurisdictions

Medicare currently has four Jurisdictions assigned for Home Health and Hospice Administrative Contractors.

Jurisdictions A – D are reserved from the HH & H workloads. A map of the regions can be found at: http://www.cms.gov/Medicare/Medicare-Contracting/MedicareContractingReform/Jurisdiction-Maps/HomeHealthHospiceMACJurisdictionMap.pdf

It is important for your agency to be up to date with the instructions from your contractor. So make sure you are signed up for their newsletters and alerts.

You can find links to each of the contractors at the HEALTHCAREfirst Regulatory Blog.

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Palmetto GBA

http://www.palmettogba.com/Palmetto/Providers.nsf/docsCat/Jurisdiction%2011%20Home%20

Health%20and%20Hospice~Articles~Claims%20Processing%20Issues%20Log?

NGS

National Government Services

http://www.ngsmedicare.com/wps/portal/ngsmedicare/AllProductionAlerts

(not all issues are listed here)

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NHIC

Medicare NHIC www.medicarenhic.com

*TRANSITIONING TO NGS*

http://www.medicarenhic.com/pa/parta_fiss_issues.shtml

CGS

CGS www.cgsmedicare.com

(not all issues are listed here)

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MAC Satisfaction Indicator (MSI)

https://adobeformscentral.com/?f=eMRKPqaWpqMxNOmTQpSKDA

Stay in the Loop

Blog.healthcarefirst.com

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Thank you!

For the latest Regulatory News & Updates,visit HEALTHCARE first’s Regulatory Blog at

www.healthcarefirst.com

For more information about HEALTHCARE first, please visit our website or call 800.841.6095