CMS Proposal: More than Payments to Home Health, Hospice Agencies

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By Terry Miller 
Regulatory Advisor, McKesson

Home Health Agencies CMS AnnouncementWhile the small (0.1%) proposed reduction in Medicare payments to home health agencies in calendar year 2013 has generated headlines, home health and hospice agencies should pay attention to other portions of the CMS announcement.

Here’s a closer look at the main provisions:

  • Public reporting of hospice quality data remains off the table as CMS works toward implementing a standard quality set similar to the OASIS data that home health agencies submit. Nine agencies currently are participating in a data reporting trial, and CMS hopes to have a new standard in place for 2014. Hospices face a 2% decrease in reimbursement for non-participation starting in 2015.
  • A home health proposal allows non-physician practitioners in in-patient settings to document the face-to-face encounter. Some Medicare Administrative Contractors (MACs) have been denying payments on technical grounds regarding how the documentation is titled, and this rule is designed to provide clarity in these instances.
  • Therapy reassessment encounters will need to take place during the 11th, 12th or 13th visit and then again during the 17th, 18th or 19th visit for agencies to continue to receive reimbursement. Some agencies objected to the “close to” wording in the current regulations, which can provide certain challenges. However, greater specificity brings its own challenges, so this one will be interesting to watch.
  • CMS intends to limit the use of OASIS code M1024 for fracture and aftercare (V) codes. Agencies often have used M1024 to supplement M1020 and M1022 codes for complex conditions such as diabetes, skin problems and neurological issues that may qualify for additional reimbursement. The proposal calls for those conditions to be more fully explained in the primary and secondary coding instead.

Comments on proposed changes to the home health prospective payment system (HH PPS) are due Sept. 4.

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