Provider Insights, Inc.

03/14/2023

At the end of March, Provider Insights will have the honor of sponsoring and speaking at IHCA's Spring Quarterly Education Conference! On the second day of the conference, I will be speaking on "The Balancing Game of HHVBP- Five Star, PDGM, OASIS E, Utilization and Productivity." Maribeth Freland will be providing insights into the survey process in Iowa along with how to avoid some of the top survey citations! We're expecting a great turnout! I'm looking forward to the valuable education and the opportunity to make new connections. I'd love to see you there!

Impexium Association Management Software

03/13/2023

I'm so excited for this years virtual "Nuts and Bolts~" This course provides both a great foundation for new and experienced Home Health clinicians alike! Join us this week!

ABOUT THE PROGRAM This program, developed and taught by Corridor, covers the Home Health Conditions of Participation in detail, including the Medicare benefit from a clinical perspective including eligibility, face to face and recertification. The PDGM payment model will be covered including common....

03/01/2023

I had the most wonderful time at the CGS Impact Conference this week! I got to catch up with amazing people like Rochelle Wallace, who is the manager of the CGS Provider Contact Center. And I brought vital compliance information to a room full of dedicated providers! Such a fulfilling experience.

02/28/2023

This week, I had the honor of speaking at the CGS Administrators, LLC Impact Conference in Nashville, Tennessee! The conference featured two full days of Medicare education, covering Part A, B, Home Health, Hospice and DMEPOS. Dozens of esteemed medical professionals in attendance offered advisement on the many facets of Medicare and compliance.

My breakout session focused on the OASIS, and the role it plays in payment of your Home Health claims. We reviewed the HH medical review hierarchy and discussed how within the review, the diagnoses (alongside the FTF) and the OASIS play a part. We explored those items from the OASIS that directly impact payment, and the CMS guidance, with its "bag of tricks". Tools and real-life examples were provided to ensure agencies can apply these lessons in their day-to-day processes.

02/27/2023

I want to take a moment to highlight a valuable member of the Provider Insights team: Maribeth Lee Freland! As an RN and Certified CMS Health Facility Surveyor, Maribeth brings 21 years of expertise as a home health and hospice surveyor for the state of Iowa Department of Inspection and Appeals, as well as CMS State OASIS Education Coordinator. After retiring from the State in 2022, she is opening a new chapter, using this expertise and her love for education in working side by side with agencies in Iowa, and beyond! Maribeth provides mock surveys, documentation audits and education with Provider Insights. She brings so much to the team, and I am so grateful to have her!

- Annette

02/17/2023

Hello Facebook, I'm back! You haven't heard much from me in a while, as my last post was made in 2015. Life's been a little busy! I've been working hard to support my clients and educate home health and hospice providers on Medicare compliance. But I want to make my profile here another touchpoint for you to receive important information and resources. So, stay tuned for our monthly updates and announcements whenever new compliance information is released. It's good to be back!

- Annette

02/08/2023

END OF VIRTUAL FTF VISITS FOR HOME HEALTH AND HOSPICE

CMS just announced an update to the 1135 waiver information, including end dates for each waiver. This will impact the FTF visits for both home health and hospice.

HOSPICE:
Under the PHE waiver, face-to-face recertification visits for all 60-day benefit periods can be completed via telehealth. CMS announced that the PHE will have an end date of 5/11/23. CMS is allowing a grace period after the PHE ends, concluding on December 31st, 2024. This additional extension was made possible due to the Consolidated Appropriations Act (CAA) of 2023. All FTF visits, beginning January 1, 2025, must be in person.

Page 4 of CMS release, found athttps://www.cms.gov/files/document/hospice-cms-flexibilities-fight-covid-19.pdf states: "Face-to-face encounters for purposes of patient recertification for the Medicare hospice benefit can now be conducted via telehealth (i.e., two-way audio-video telecommunications technology that allows for real-time interaction between the hospice physician/hospice nurse practitioner and the patient). The Consolidated Appropriations Act, 2023 extended telehealth flexibilities through December 31, 2024, regardless of the status of the PHE."

(Note: Originally, CMS had published this guidance from the Social Security Act on 2/6/23 stating the telehealth for FTF was ending 151 days after the PHE ended. But the new CAA overrides this with the extension through the end of 2024. This error was corrected on 2/7/23. CMS also seemed to have a typo, as they reported December 3, 2024, but it is in law for December 31st. We expect a correction soon)

HOME HEALTH:
The face-to-face visit, required for eligibility at the SOC for Home Health benefits, has a waiver allowing the visit to be provided remotely as long as there are audio and video components documented. This PHE also has a new end date of 5/11/23. CMS is allowing a 151-day grace period after the PHE ends to continue accepting remote FTF visits. This would conclude the grace period on Monday, October 9, 2023. All FTF visits, beginning October 10, 2023, must be completed in person. See page four of the CMS updated fact sheet for Home Health waivers at:https://www.cms.gov/files/document/home-health-agencies-cms-flexibilities-fight-covid-19.pdf

04/25/2015

April Showers- and CMS updates-- should bring us flowers and better ADR pass rates! Here is this month's newsletter-- to subscribe, please go to www.providerinsights.com

Home Health: FTF Manual Updates
FINALLY! Chapter 7 of the Medicare benefit Policy Manual has been updated with the new therapy and face to face requirements! This includes verbiage to support our "3 step process" discussed in last month's newsletter. Home Health agencies CAN and should provide additional information to corroborate the physician's visit note regarding Homebound Status and Medical Necessity. The manual can be found at:
http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R208BP.pdf

In 30.5.1.2, it states: "Information from the HHA, such as the initial and/or comprehensive assessment of the patient required per 42 CFR 484.55, can be incorporated into the certifying physician’s medical record for the patient and used to support the patient’s homebound status and need for skilled care. However, this information must be corroborated by other medical record entries in the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient."

CMS clarified in CR9112, home health agencies are required to: Maintain documentation by the physician who ordered/certified the home health services and the NPI of the physician for 7 years from the date of service, and Upon the request of CMS or a Medicare contractor, provide access to that documentation. So, what does this mean? Be sure that you request the documentation of the visit note for the "in person", or "face to face" encounter that the patient and physician or NP/PA had to ensure payment.

Seeing STARS? Your agency can review your preliminary "STAR rating" at this time, and ensure it is correct prior to the publication in July. These will be updated quarterly, and in January 2016 will include HHCAHPS data in the computation. Certified HHAs with 20 or more complete quality episodes (SOC/ROC to TRF/DC OASIS) will be included in the STAR ratings, which are based on the following nine measures:
Process Measures:

1. Timely Initiation of Care
2. Drug Education on all Medications Provided to Patient/Caregiver
3. Influenza Immunization Received for Current Flu Season

Outcome measures:

4. Improvement in Ambulation
5. Improvement in Bed Transferring
6. Improvement in Bathing
7. Improvement in Pain Interfering With Activity
8. Improvement in Shortness of Breath
9. Acute Care Hospitalization


Hospice: Election Statement Controversy and CAHPS Deadlines

The attending physician's NPI is NOT mandated to be on the Election Statement but rather only the Notice of Election (NOE) submitted through FISS to CMS to notify Medicare of the Election. CMS will be making that correction to CR9114 soon.
New PEPPER reports are out! This is a great way to see where your agency is at, compared to the rest of the nation. If you are "outstanding" in any area- review the "whys". Recently, I worked with hospice who noted on their PEPPER report that they were extremely high on their percentage of patients being cared for in the SNF. This could be a "red flag" and bring about a provider specific probe. Upon research, it was a simple billing error and mis-understanding about when to use the code for care in a Nursing facility vs a SNF, and this was corrected immediately. Other times, we may see something a little more complex- such as our length of stays as an outlier-- which we will want to review as an IDT with our Medical director to ensure our patients are still appropriate for hospice, and we have good documentation and decisions at the start of care, as well as at each recertification. For more information, go to: PEPPERresources.org
May 1st: Deadline to submit completed Hospice CAHPS Survey vendor authorization form to CMS.
Providing Insights to Home Health and Hospice agencies...
Have a wonderful week,
Annette