Home Health & Hospice

Latest HH ODF covers proposed CoPs, 2015 final rule provisions

Homecare Insider, November 24, 2014

CMS recently hosted an Open Door Forum (ODF) for the home health, hospice, and durable medical equipment communities to address key regulatory updates from recent rulemaking that will affect providers in the coming year and beyond.

Salient home health topics covered during the forum include:
  • Proposed updates to the home health Conditions of Participation, which were released October 9 and are nearing the end of a 60-day open comment period. Comments are due by December 8 and can be submitted here.
  • Changes to home health prospective payment system (HHPPS) rate for 2015. On October 30, CMS issued the final rule for the 2015 HHPPS rate, which will reduce overall reimbursement to home health agencies by 0.3% ($60 million) for the coming year—a figure that doesn’t account for the 2% sequestration reduction currently in effect through March 2015 for all Medicare providers. The new reimbursement rate in part reflects a 2.1% ($390 million) increase in the home health payment update percentage, the result of a 2.6% market basket bump combined with a 0.5% reduction due to the multifactor productivity adjustment. This payment boost is negated by a 2.4% ($450 million) decrease stemming from the second in a four-year phase-in of rebasing adjustments, which will incite (1) marginal increases to the national per-visit payment rates, (2) a 2.82% reduction to the non-routine medical supplies (NRS) conversion factor, and (3) an $80.95 decrease in the national, standardized 60-day episode payment rate, which will consequently be $2,961.38 during CY 2015.
  • Overhauls to HHPPS case mix weights. CMS used OASIS data from 2013 claims to recalibrate the adjustment weights for all 153 case mix categories, positioning 2015 reimbursement rates to better reflect current resource utilization patterns.
  • Changes to Core Based Statistical Area (CBSA) delineations for the 2015 HH wage index. CMS also finalized revisions to the wage index based on the newest CBSA delineations released by the Office of Management and Budget (OMB) in a February 2013 bulletin—a move that will cause the 105 counties that will be shifted to an urban category to lose the 3% rural payment add-on, while 37 counties will gain the add-on. To ease the adoption of these new rates, CMS will implement a one-year transition period during which a “blended” wage index will be used. This means that 50% of the wage index during CY 2015 will come from the current OMB delineations and the other 50% from the 2014 delineations.
  • Changes to face-to-face requirements. CMS finalized three changes to the face-to-face encounter requirements for episodes beginning on or after January 1, 2015. First, CMS will eliminate the narrative requirement currently in regulation. The certifying physician would still be required to certify that a face-to-face patient encounter occurred and document the date of the encounter as part of the certification of eligibility. In place of the narrative, CMS will now require documentation in the certifying physician’s medical records to demonstrate evidence of a patient’s home health eligibility. Second, CMS specifies that if a HHA claim is denied, the corresponding physician claim for certifying/re-certifying patient’s Medicare home health eligibility will also be denied. Lastly, CMS clarifies that a face-to-face encounter will now be required for certifications, rather than initial episodes, and that a certification (not re-certification) is generally considered to occur any time a new start of care assessment is completed to initiate care.
  • Relaxed requirements for therapy reassessment. CMS is finalizing the elimination of the 13th and 19th visit reassessment requirements in favor of laxer, calendar day-driven provisions. For episodes beginning on or after January 1, 2015,  a qualified therapist must perform a functional reassessment on a patient at least once every 30 calendar days.
  • New submission threshold for quality reporting. CMS has established a minimum submission threshold for the number of OASIS assessments that each HHA must submit in order to receive the full annual payment update.  Beginning in CY 2015, the initial compliance threshold will be 70%. This means that HHAs will be required to submit both admission and discharge OASIS assessments for a minimum of 70 % of all patients with episodes of care occurring during the reporting period. CMS will increase the compliance threshold over the next two years to reach a maximum threshold of 90%.
  • Approval of OASIS and Quality Measures. CMS officials also reported that the OASIS C1/ICD-9 has received the OMB’s approval and is posted on the CMS Home Health Quality Initiative website. In addition, public reporting for the claims-based rehospitalization measure on Home Health Compare is scheduled for July 2015. Finally, CMS announced a new email address for questions related to quality measures: Homehealthqualityquestions@cms.hhs.gov
  • Conversion to Assessment Submission and Processing (ASAP) System. Officials reminded participants that OASIS submissions to the state system will discontinue starting at 6:00 p.m. ET on December 26, 2014. At that time, the HHA state submission system will no longer be used for OASIS submissions. New, modification, or inactivation records in the current flat file format must be submitted prior to 6:00 p.m. ET on December 26, 2014. Effective January 1, 2015, providers must submit OASIS data to CMS via the Assessment Submission and Processing (ASAP) system.
  • A change request regarding claims processing. CMS recently issued Change Request 8950, which details a “Correction to Remittance Information When HIPPS Codes are Re-coded by Medicare Systems.” The CR instructs contractors to include remittance advice code pairs in claims that currently include only a remittance advice remark code. In addition, CMS intends the requirements outlined by the CR to ensure the HIPPS code used for payment is displayed appropriately, as currently, HIPPS codes that are changed based on validation with data from the Quality Improvement Evaluation System are not displayed to providers on Direct Data Entry screens, nor are they being sent to the remittance advice.