Home Health & Hospice Week

A cheat sheet can keep you off your intermediary's bad list. 

Come Spring you may have egg on your face - and less money than you thought - if you haven't tightened up your M0175 practices.

Home health agencies that fail to bring their M0175 collection procedures up to scratch may find themselves the targets of medical review, and even fraud and abuse scrutiny, predicts consultant John Gaynor with the Chicago office of Frost, Ruttenberg & Rothblatt.

Once the M0175 edits and ensuing adjustments begin (see story, "Reimbursement"), regional home health intermediaries will be able to track those numbers and see who repeatedly answers the OASIS item incorrectly, instead of getting the information wrong only every once in a while.

No agency will get M0175 right for every patient, Gaynor notes. But HHAs that repeatedly get the OASIS item wrong could earn a bad reputation.

Experts liken it to the question on therapy visits (M0825). It's natural for unexpected occurrences to take place and for patients sometimes not to hit the 10-visit threshold when predicted. But agencies whose patients repeatedly don't hit the threshold when claimed look like they are trying to get more money up front for the episode - an equivalent of a free loan from Medicare.

After the HHS Office of Inspector General announced its inquiry into M0175 in February (see Eli's HCW, Vol. XII, No. 6, p. 44) and issued its first report on the matter in July (see Eli's HCW, Vol. XII, No. 27, p. 210), agencies "asked their nurses to redouble their efforts to get accurate prior stay information," notes Bob Wardwell with the Visiting Nurse Associations of America. "They are doing the best they can," Gaynor adds.

In its July report, the OIG says HHAs should make "every reasonable attempt" to obtain and report accurate OASIS data for M0175. Experts offer these tips for improving your M0175 accuracy:

1) Cheat sheets. Sometimes figuring out whether patients have had an inpatient stay is as easy as determining what facility they were discharged from. HHAs can draw up a "cheat sheet" that lists referring facilities and what types of beds they contain (acute, skilled nursing facility and rehab), recommends OASIS expert Linda Krulish with Home Therapy Services in Redmond, WA.

Then if the facility that discharged the patient has only one type of bed, it's simple to figure out what kind of stay the patient had, she explains.

2) Cue questions. The process becomes more difficult if the patient comes from a facility with multiple types of beds. In those cases, clinicians should ask what floor the patient was on during the stay, which might indicate what type of bed they were in and whether it was a hospital, SNF or rehab stay, Krulish advises.

Staff can also ask if the part of the hospital the patient was in had a distinct name. The cheat sheet can include information such as that a hospital's SNF unit is called "Special Care," Krulish says. A patient who may have no idea what a SNF is or that they were in a SNF unit may be able to tell you the name of the unit, and you can identify it.

Other cue questions that will help get to the bottom of hospital status are those on payor and type of services provided during the stay, she says.

3) Training. HHAs may be tempted to slack off on obtaining hard-to-find prior stay information when they know the claims payment system will automatically correct the item anyway. But smart agencies will err on the side of caution and strive to complete OASIS completely and accurately, experts say.

HHAs should stress in OASIS training that RHHIs and the Centers for Medicare & Medicaid Services will be able to track how often agencies don't get OASIS right the first time, Gaynor advises. Those stats easily could come back to haunt agencies and result in increased scrutiny.

"Management must make sure that thinking doesn't go too far," Gaynor says of falling back on the automatic corrections.