Home Health & Hospice Week

have to modify the recording of expenses for nursing, physical therapy and occupational therapy on their financial statements as well as the billing systems to generate the new visit statistics.”

Suggestion: “We recommend that the effective date be six months after the finalization of the proposed forms and instructions and publication of the changes to the industry,” NAHC told CMS.

Response: CMS did agree to bump the implementation date back six months, to start in July 2019. But it denied any need for further postponement.“The changes necessary for providers and vendors are less significant than what is described by the commenters,” CMS said in its response to comments.“The majority of the changes were removing obsolete worksheets. The changes to the cost report that require recording expenses for nursing, PT and OT were actually effectuated on the bill based on Change Request 9736 dated November 10, 2016 with an implementation date of January 3, 2017.”

That CR, which implements G codes for LPNs, is not the same thing, Macke contends (see related story, p. 66).

In addition to calculating hourly wage data by discipline, for the first time, HHAs will have to collect and report separate data for LPN visits and patients served, PT assistant visits and patients served, and COTA visits and patients served, says consulting firm The Health Group.

HHAs will also have these new cost centers, The Health Group adds in its electronic newsletter: Nursing Administration, Medical Records, Remote Patient Monitoring, Telehealth, Advertising, Fund-raising, Skilled Nursing Care – LPNs, PT Assistants, and COTA.

“The revised cost report will pose significant reporting issues for home health agencies,” the Morgantown, West Virginia-based firm warns.

Other changes in the cost report include:

• PDGM. Commenters requested some way to separate data reported for 60-day episodes versus 30-day periods under the Patient-Driven Groupings Model.“CMS does not intend on splitting this information in the cost report,” the agency responds.“The claims data with dates of service will be used to differentiate the varying number of days per episode/period.”

Commingling the 30- and 60-day data will be a problem only for the first year, of course, Macke points out.

• Home offices. A new clarification on the definition of a home office versus related party is helpful, Macke judges.“Most chain home offices are separate and distinct headquarters,” CMS explains in its response to comments.“The home office is usually physically and organizationally separate and easily identifiable from the facilities it serves.” More details are in CMS’ response available via a link at www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202002-0938-013.

CMS also responds to comments that there’s no standard form for home offices and there are variations from HHH Medicare Administrative Contractors on the issue.“This comment is outside of the scope of this PRA, however, we will forward the comment to the appropriate division for consid­eration,” CMS says.

• LPNs vs. CNAs. Two worksheets, S-3 Parts II and V, have lines for both “Licensed Practical Nurses” and “Certified Nursing Assistants,” Macke points out. There’s very little guidance on this and it will cause confusion, he asserts.
• FTEs. Worksheet S-3 Part II asks for Full Time Equivalent data for 16 new categories of employees, including “supervisors” for each discipline.“Having supervisors on this worksheet is ridiculous,” Macke blasts.“I don’t know what they’re looking for.”

In fact, the whole FTE worksheet seems “meaningless,” he adds.

• Hospice. Commenters pointed out a number of differences between Worksheet O for HHA-based hospice costs and the freestanding hospice cost report.CMS fixed some of the issues, such as adding a cost center for drugs charged to patients.
• Managed care. A clarification on how to count Medicare managed care and Medicaid managed care patients on Worksheet S-3 Part I is helpful, Macke highlights.“Data pertaining to Medicare Managed Care, Medicaid Managed Care, and all other patients” should go in the “Other” section (columns 5 and 6) on the form, the new cost report instructions say.
• Telehealth/remote patient monitoring. CMS addresses a number of comments on telehealth and remote patient monitoring (see more details in a future issue of Eli’s Home Care Week).
• New cost centers. Worksheet A requires allocations for new cost report centers: nursing administration, medical records, telehealth, advertising, and fundraising. How different agencies allocate costs for remote patient monitoring and nursing administration in particular will vary widely, Macke predicts. And allocating costs for medical records is just “crazy,” he insists.
• Advertising. HHAs will need to make a judgement call for the advertising cost lines on worksheets A-8 and O.“For both HHA and HHA-based Hospice … where the costs (direct and allowable share of general service cost) attributable to any non-allowable cost center are so insignificant as to not warrant establishment of a non-reim­bursable cost center, these costs may be adjusted on Worksheet A-8, Line 11 and/or Worksheet O, Column 6 accordingly,” CMS says in its response to questions on the topic.

In other words: HHAs will have to decide which ad costs count as significant, Macke says.

Note: A link to the cost report form, instructions, and other PRA supporting documents is at www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-1728-19.