Home Health & Hospice Week

Grappling with the new diagnosis codes that took effect this month is a hassle, but a much bigger coding headache soon is coming down the pike -- unless influential doctors and payers get their way.

In an August proposed rule, the Centers for Medicare & Medicaid Services floated a 2011 im-plementation date for the new ICD-10 coding system that will replace the current ICD-9 format (see Eli's HCW, Vol. XVII, No. 30, p. 238). The ICD-10 system will increase the number of diagnosis codes from the current 17,000 to a staggering 155,000.

The "rapid" timeframe CMS had laid out for full ICD-10 implementation is unworkable, says the Medical Group Management Association. "The costs associated with implementing ICD-10 in such a short timeframe are markedly higher than what CMS has estimated," MGMA says based on a study conducted by Nachimson Advisors. The implementation timeframe "will place a major burden on providers, taking valuable time away from their patients and straining other resources needed to invest in health information technology," MGMA insists.

Too hasty: The American Medical Asso-ciation "is deeply concerned that HHS is rushing head-first into the transition to a complex coding system without fully recognizing the impact on the health care system," adds AMA board chair Joseph M. Heyman, M.D.

Providers aren't alone in opposing the deadline. The Blue Cross Blue Shield Association "has severe concerns about the proposed timeline for conversion to the ICD-10 code sets," says a BCBSA spokesperson. The timeline "could cause a healthcare meltdown that would impose a severe burden on patients, providers, states, government programs as well as health plans."

BCBSA wants a five-year transition to the new ICD-10 system, it says.

The other side: But the American Health Information Management Association endorses CMS's timeline. "Obviously the cost of implementation for ICD-10 will only grow the longer we delay initiating that process," AHIMA says. The Nachim-son study MGMA cites is biased, the association contends.

Resource: To sign up for the Oct. 30 Eli-sponsored audioconference, "ICD-10 Preparation: What You Need To Know NOW," go to http://www.audioeducator.com/industry_conference.php?id=1304 or call 1-800-508-2582.

And CMS offers an ICD-10-Clinical Mod-ification/Procedure Coding System Bookmark, which explains the ICD-10 system "including the benefits of adopting the system, recommended steps to be taken in order to plan and prepare for implementation of the system, and where additional information about the system can be found." To place your order, visit http://www.cms.hhs.gov/MLNProducts/01_Overview.asp, scroll down to "Re-lated Links Inside CMS" and select "MLN Product Ordering Page."

• The 36-month oxygen cap that's been on the books since 2005 will start hitting Jan. 1 -- and suppliers still have few details about the new policy, industry representatives complain.

Suppliers are supposed to notify patients starting in just a few weeks whether they will continue to service the equipment after the 36th month, notes the National Association for Independent Medical Equipment Suppliers. But they still don't know much about how billing and payments for maintenance and service would work.

"CMS, having had almost three years to act, has failed to issue policies, codes, and fees to suppliers detailing the rules and expectations of suppliers during the cap," NAIMES criticizes.

The American Association for Homecare submitted a three-page list of detailed questions to CMS in August, but hasn't seen any answers.

"This is much more of a crisis than the restart of competitive bidding since it will affect thousands of oxygen patients in just 60 days," NAIMES insists.

• With flu season here, you may want to check out some new resources from the government. One tool is a new compliance checklist offered by the feds. "'Community Pan-Flu Prepared-ness: A Checklist of Key Legal Issues for Healthcare Providers,' is a scalable tool designed to assist providers along the continuum of care ... in taking concrete steps to prepare for an influenza pandemic," CMS says.

The American Health Lawyers Associa-tion, the HHS Office of Inspector General, and the U.S. Centers for Disease Control and Prevention contributed to the document that helps providers "consider the legal impediments and implementation challenges to community pan-flu preparedness and practical solutions to such challenges," CMS notes.

The checklist is at www.healthlawyers.org/ panfluchecklist.

The CDC has a host of patient education materials available at http://www.cdc.gov/flu. And don't forget to convince your staff to get vaccinations as well. Only 40 percent of health care workers get vaccinated, the CDC notes.

Tip: Shoot down myths such as that nurses have stronger immunity against the flu or that the vaccine isn't effective, the CDC advises.

If your patients or staff don't get vaccinated and a flu pandemic does strike, they may be better protected if they already had a milder form of the virus earlier in the season. A new study conducted by the National Institutes of Health found that victims of the 1918 flu pandemic fared much better if they already had the flu that year. They did almost as well as groups that receive vaccines.

For example: "At one [Army] base, a regiment that had transferred in from Hawaii where soldiers were exposed to the spring wave [of flu] had a 6.6 percent incidence in the fall compared to 48.5 percent in a regiment transferring in from Alaska, where soldiers had not been exposed," the NIH researchers found.

• State Medicaid programs are paying for more than 24 hours of personal care services in some cases, the OIG found in a recent report.

In four of the five states studied for the report, the programs in 2005 paid for more than 24 hours of care on 871 claims totaling $873,132. The states were Minnesota, New Mexico, Texas, and Washington.

Confusion arises when Medicaid programs allow personal services billing over a range of days, including days the beneficiary didn't receive services, the OIG contends. The report is at http://www.oig.hhs.gov/oei/reports/oei-07-06-00621.pdf.

• If you're wondering about the definition of "respiratory disturbances" for the new Medi-care coverage policy for CPAPs, you're not alone.

In a correction of the transmittal implementing the new national coverage determination for continuous positive airway pressure devices, CMS clarifies the term. "There is variability in the published medical literature about the definition of the events that constitute a respiratory disturbance," CMS acknowledges in the new transmittal language. "The technology assessment that supported this NCD recognized this variability and defined RDI in the context of the specific sleep test technology under review."

New definition: "For the purposes of this NCD, a respiratory disturbance is defined in the context of the sleep test technology of interest and does not require direct measurement of airflow," CMS now explains. "Local contractors shall, as needed, determine, based on their review of the published, peer-reviewed medical literature, the equivalent test result criteria corresponding to the required AHI or RDI for Type IV devices measuring 3 or more channels that do not measure AHI or RDI directly."

• National Century Financial Enterprises may be long gone, but the legal wrangling about the defunct home care financier continues. NCFE declared bankruptcy in 2002, leaving providers like Amedisys Inc. and now-shuttered Med Diversified high and dry.

In the Oct. 7 fraud trial of former NCFE CEO Lance Poulsen, an FBI agent told jurors that the financier illegally advanced money to six companies partially owned by Poulsen, reports newspaper Business First of Columbus.

And the former CEO of Home Care Con-cepts of America Inc., Craig Porter, testified that his company was overfunded by NCFE, Business First says. Home Care Concepts of America was owned in part by Poulsen and convicted accomplices Donald Ayers and Rebecca Parrett.

• One state is getting closer to adopting a Medicaid hospice benefit. Connecticut Association for Home Care & Hospice reps have been working with state officials on developing hospice regulations, the trade group reports in its member newsletter. "CAHCH has been very pleased with the collaborative tone and approach to drafting of the Medi-caid hospice benefit policies," it says.

• You now have another diagnosis code that will support home health occupational therapy coverage, according to a revision of a Palmetto GBA local coverage determination. You can now use 346.63 (Persistent migraine aura with cerebral infarction, with intractable migraine, so stated, with status migrainosus), which is a new code that took effect Oct. 1, to support OT medical necessity, ac-cording to LCD 02HH-0015-L.

• LHC Group Inc. has entered a new state market that requires a certificate of need (CON). LHC will acquire the stock of HomeCall Inc., in Fredrick, Md. The agency has 12 locations that cover 19 counties, LHC says in a release. HomeCall's annual revenue is $15.6 million.

"This acquisition will serve as a catalyst in our efforts to expand our geographic footprint throughout the mid-Atlantic region," CEO Keith Myers says in the release.

• Akron, Ohio-based chain Cambridge Home Health Care has opened its thirty-first location in the state. The new office is in Mount Vernon, says the company that serves more than 2,400 patients weekly in their own homes and employs more than 1,600 staff.