Home Health & Hospice Week

Industry Notes:

MEDPAC EXPECTS CODING CHANGES FROM HHAs IN 2008

Growth of Medicare-certified agencies slows this year.

Home health agencies aren't the only ones noticing how important diagnosis coding will be under the prospective payment system refinements.

"The new system substantially expands the role of coding practices in payment," said Evan Christman with the Medicare Payment Advisory Commission during its Dec. 7 meeting in Washington, DC.

"We expect agencies to change their coding practices as a result of the new system," Christman told MedPAC commissioners. That change will result in a 1.6 percent increase in Medicare payment for HHAs in 2008, Christman predicted.

Bad news: That prediction, combined with the projected 15.4 percent Medicare profit margin for agencies, made the commissioners even more disposed to recommend a rate freeze for HHAs in 2008. MedPAC will make its official recommendation in its annual March report.

Meanwhile, Christman noted that the rate of growth of HHAs has slowed so far in 2007. In 2006, agencies had increased by about 7 percent by November. This year, the increase was only 4 percent.

The slowdown is probably due to two main factors, Christman suggested: states such as Texas halting certification of new providers and potential providers waiting to see how the PPS refinements shake out.

The number of HHAs was 8,880 in 2006, up 2.4 percent from the previous year, according to the MedPAC presentation. That's still short of the all-time high of nearly 11,000 agencies in 1997, Christman noted. The number of agencies has grown about 30 percent in the last five years, he added.

CMS instituted a fraud demonstration requiring reenrollment in some of the highest-growth areas in California and Texas (see Eli's HCW, Vol. XVI, No. 37), Christman pointed out.

The HHS Office of Inspector General continues to harp on the M0175 issue, mere weeks before it's rendered moot. In a report released Dec. 10, the OIG reviews whether Partners Home Care in Waltham, MA billed correctly based on patients' prior inpatient stay information in 2004 and 2005.

"The agency improperly coded 231 of these claims as if the beneficiary had not had an acute care stay in the preceding 14 days," the OIG says in the report summary. However, the M0175 edits the Centers for Medicare & Medicaid Services put in place in April 2004 caught 155 of the claims and automatically corrected them. And Partners corrected 28 claims itself, forfeiting more than $13,000 in Medicare payments.

"The 48 remaining unadjusted claims represented overpayments of $16,443," the OIG notes. The watchdog agency calls on Partners to refund the overpayments and train its staff on the OASIS item on prior inpatient stays that led to the billing error.

The rebuttal: The HHA already provided extensive education on M0175, Partners President Christopher Attaya said in a letter responding to the report. "The extremely low percentage of our claims and related billing identified in this audit is evidence of the effectiveness of these controls," Attaya told the OIG.

Partners took all prudent steps to secure a correct M0175 answer, Attaya maintained. "It is well known that 100 percent accuracy with respect to M0175 is not possible," he added. The main culprit is the Common Working File lag on patient data.

Rather than refund the $16,443, Partners tells the OIG to have the fiscal intermediary issue an official determination so it can have the right to appeal. The report is online at
www.oig.hhs.gov/oas/reports/region10/10700503.pdf.

Regional home health intermediary Cahaba GBA is offering a helping hand to agencies. The intermediary has posted three new tools on its Web site on home health administration of parental nutrition; qualifying criteria for intermittent care; and a wound care flow sheet.

The new materials join 15 other home health tools from Cahaba on topics ranging from Advance Beneficiary Notices (ABNs) to the PPS refinements transition. Links to the tools are at
https://www.cahabagba.com/part_a/education_and_outreach/educational_materials/hha.htm.

The medical directors of Medicare's Durable Medical Equipment Program Safety Contractors have OK'd a request to revise the power mobility devices local coverage determination (LCD).

Good news: They will eliminate the requirement that patients receiving rehab power wheelchairs on or after April 1, 2008, be evaluated by a RESNA-certified Assistive Technology Practitioner, reports the American Association for Homecare, which lobbied to eliminate the requirement. The current requirement will remain in place.

An updated OASIS document every home health agency needs to have readily available is on the QIES site at https://www.qtso.com/hhadownload.html.

The October 2007 updated Chapter 8 of the OASIS User's Manual contains the information you need for the new 2008 PPS that takes effect Jan. 1. Appendix D containing new coding examples is not yet ready, CMS says.

Providers hoping the NPI Enumerator can help them with crosswalk and claims problems related to National Provider Identifiers are out of luck. Those are two areas that the NPI Enumerator doesn't address, CMS says in a revised MLN Matters article (SE0751).

The Enumerator also doesn't help with enrollment information or the NPI registry, CMS says. A list of what the Enumerator can and can't do is in an article online at
www.cms.hhs.gov/MLNMattersArticles/downloads/SE0751.pdf.

You can get Spanish-language information on a variety of neurological disorders from a new National Institutes of Health Web site. The NIH's National Institute of Neurological Disorders and Stroke is making available Spanish-language health information for patients featuring topics such as stroke, dementia, Parkinson's disease, epilepsy and more. "The publications can be downloaded or ordered free of charge," NINDS says. The site is at espanol.ninds.nih.gov.

Hospice registered nurses saw their salaries rise nearly 3.5 percent from 2006 to 2007, according to a new salary survey from Hospital & Healthcare Compensation Service in Oakland, NJ. Hospice RNs had a national median hourly rate of $25.86 this year, according to the report that includes data from more than 450 hospices.

Hospice licensed practical nurses saw a smaller 2.78 percent increase to $18.51 per hour during the same time period, the report added.

The national turnover rate was 20 percent for hospice RNs and 22 percent for hospice LPNs, the re-port found. More information is at
www.hhcsinc.com.