Home Health & Hospice Week

All new codes require more time.

With so many details of telehealth reporting for home health agencies yet to be worked out, a January start date doesn’t seem very wise. But whatever implementation date Medicare ultimately chooses, it should be preceded by loads of training, rule commenters stress.

Reminder: The Centers for Medicare & Medicaid Services suggests a January 2023 voluntary start date and a July 2023 mandatory start date for HHA telehealth encounter reporting in its 2023 home health proposed rule released in June. But with so many complaints about the reporting concept, ranging from codes used to lack of reimbursement to cost reporting inadequacies, those dates may seem shaky.

Many details still need nailing down, commenters point out.

“LeadingAge recommends clarifying the types of remote patient monitoring which will be allowable under the new G-Codes,” the trade group’s Katy Barnett says in its comment letter. That would, for example, “ensure that RPM is adding to the value of care, not simply tracking someone’s steps from a wearable product like a smart watch,” Barnett suggests.

If CMS is going to go with its proposal to implement new G-codes, “it would seem reasonable that a committee be created with equal representation from CMS/Medicare and the industry to hash out what visit types would reasonably be considered allowable/chargeable,” recommends John Reisinger with Innovative Financial Solutions for Home Health in Tampa Florida. “With this kind of cooperation between the industry and CMS/Medicare, we could come up with some reasonable limitations/ allowances while also lessening the chances for fraud and abuse to creep in because of potentially unforeseen circumstances.”

When particulars are set, HHAs want to see plenty of preparation.

Penn Medicine at Home “encourage[s] CMS to provide information and training to ensure that providers are prepared to report this information accurately when mandatory reporting begins,” says CEO Joan Doyle in its comment letter.

The Texas Association for Home Care & Hospice recommends “CMS provide detailed education to providers prior to implementing the voluntary collection of this data on claims on January 1, 2023,” TAHC&H’s Jennifer Elder says in the state association’s comment letter.

Timeline bump: But the American Physical Therapy Association thinks that doesn’t go far enough. “If CMS elects to proceed with the creation of several new G-codes for use in home health, APTA Home Health recommends that the agency provide a full calendar year before requiring reporting of these new codes,” says APTA Home Health President Philip Goldsmith in the association’s letter.

In other words, “voluntary reporting would provide the agency with preliminary data in the first year, while providers would have additional time to prepare before required reporting, which would not be effective until Jan. 1, 2024 (instead of July 2023),” Goldsmith suggests. v