Home Health & Hospice Week

Senior poll shows beneficiary opposition to demonstration program.

Home health agencies’ fears about the preclaim review demonstration being rushed seemed to be confirmed at the program’s outset.

Why? Four days after PCR was supposed to start, the Centers for Medicare & Medicaid Services retroactively delayed its start date from Aug. 1 to Aug. 3. “In order to allow time to resolve an administrative procedural requirement related to the Paperwork Reduction Act, implementation of the Pre-Claim Review Demonstration for Home Health Services in Illinois began on August 3, 2016,” CMS said in a statement issued Aug. 4. “The revised start date does not impact demonstration requirements or processes, and the demonstration will be operationalized as planned for episodes of care starting on or after August 3, 2016.”

Only two PCR requests had been submitted before CMS made its announcement, the agency notes in a Frequently Asked Questions set updated Aug. 4. Those HHAs had the choice of either withdrawing the request or proceeding with them as tests, CMS noted.

The reason there were only two requests in the queue is because “most HHAs plan on submitting to PCR only after they get all the paperwork in order,” notes William Dombi with the National Association for Home Care & Hospice. “That will usually take two weeks or so,” Dombi observes.

Tip: Waiting to submit until the paperwork is in hand is a “smart move,” Dombi tells Eli. The delay isn’t an indicator of how the rest of the program will run, Dombi maintains. “The delay was due to the need to get an additional signature on the Paperwork Reduction Act authorization,” he says. “It was not related to CMS or PGBA limitations.”

But agencies that are nervous about the program anyway may be taking it as a bad omen. “Anxiety remains high,” Dombi notes.

Watch and wait: It will be a few weeks yet before agencies see how the program starts to play out, Dombi says. With most request submissions starting mid-month, and the Medicare Administrative Contractors’ 10-day timeframe to affirm or nonaffirm the request, it will be the end of August before decisions start coming through, he notes.

But one industry group is already trying to get CMS to hit the “pause” button on the program. “A new national poll of nearly 2,000 registered voters over age 65 ... found that a large majority of U.S. seniors oppose a Medicare policy requiring a government contractor to approve claims for physicianprescribed home health care services,” says a release from the lobbying group Partnership for Quality Home Healthcare.

According to the poll conducted July 29-30 by Morning Consult, 80 percent of seniors think it is likely that requiring a government contractor to approve claims for Medicare home health services will result in delayed care for patients in need of prompt care. Similar percentages of seniors polled also believe the program will raise costs for themselves and for Medicare.

“Senior voters oppose policies that allow the government to interfere with physician decisionmaking,” PQHH’s Colin Roskey says in a release.

“Further, while CMS maintains that pre-claim review demonstration will reduce fraudulent Medicare claims in order to protect patients and the Medicare program, a majority of seniors did not agree that fraudulent claims will decrease as a result.”

CMS Pledges To Educate Docs

Meanwhile, new PCR resources can help agencies boost their chances of success for their requests. For example, agencies must include all the HCPCS codes they plan to use on the final claim in their request, MAC CGS says in a new fact sheet about the program.

Another tip: Using an incorrect or missing Unique Tracking Number isn’t the end of the world, although it will delay your reimbursement. If you mis-key or omit the UTN on your final claim, the claim will Return to Provider, said a Palmetto representative in CMS’s July 20 Special Open Door Forum on PCR.

In its forum, CMS promised it’s helping HHAs overcome one of their biggest hurdles to compliance by educating physicians about the demonstration program and home health certification requirements. In addition to providing education in physician ODFs and “reaching out” to professional physician societies, CMS is sending a letter to docs explaining the PCR demo and requirements. (See a copy of that letter on CMS’s PCR website, link in box p. 230.)

Note: A link to the transcript of CMS’s July 20 forum on PCR is in the “Downloads” box at www.cms.gov/outreach-and-education/outreach/opendoorforums/ODFspecialODF.html.