Home Health & Hospice Week

Each shortened period must meet LUPA threshold, CMS clarifies.

In CMS’s latest Home Health Open Door Forum, the vast majority of attendee questions focused on one proposal in Medicare’s 2018 HH PPS proposed rule — the switch to 30-day-period billing.

Reminder: In the Home Health Prospective Payment System rule published in the July 28 Federal Register, the Centers for Medicare & Medicaid Services proposes drastic payment reform under the Home Health Grouping Model (HHGM) system (see Eli’s HCW, Vol. XXVI, No. 28-28). In addition to eliminating therapy utilization as a case mix factor, HHGM would also include a 30-day billing period as opposed to current 60-day episodes.

This proposal has left home health agencies teeming with questions, judging from the question and-answer portion of the Aug. 9 forum. Topics CMS clarified in the Q&As included:

• RAPs. Each 30-day period will still have its own Request for Anticipated Payment, CMS officials confirmed in the call.
• Final claims. Each 30-day period also will still have its own End of Episode claim.
• Sequential billing. HHGM would not require sequential billing, a CMS official told one caller. In other words, home health agencies could submit a RAP for a subsequent episode before billing a final claim for a previous episode. That will be important if an agency can’t secure a physician’s signature, and thus must delay billing an EOE claim, the caller noted.
• Assessments. Regulatory requirements to assess the patient every 60 days will remain unchanged.
• POC. The Plan of Care will still cover 60 days, when indicated.
• OASIS. HHAs will use one OASIS assessment, which covers 60 days, for two 30-day billing periods (assuming a second period is indicated).
• Quality. The change to 30-day billing periods doesn’t affect data collection or outcomes requirements directly, CMS said. However, earlier discharges instigated by the 30-day billing policy will impact outcomes, industry observers note.
• LUPAs. HHAs will have to meet or exceed the Low Utilization Payment Adjustment threshold for each 30-day period, as opposed to hitting the threshold for only one 60-day period now. And remember, different HHGM case mix categories have different LUPA thresholds ranging from two visits to eight visits.
• No-RAP LUPAs. Medicare would still allow no-RAP LUPA claims under HHGM.
• Recerts. Recertifications will continue on the current 60-day basis, a CMS staffer answered. So long-term patients would need a recert in conjunction with every other 30-day period starting with the third.
• Payment. CMS proposes to take a 60-day payment rate for a case mix category, add in the Nonroutine Supplies payment amount, and then divide that amount in half to set the rate for each 30-day episode. But remember, according to CMS data, about one-quarter of current episodes would have only a first 30-day period, not a second one.

Note: The proposed rule is at www.gpo.gov/fdsys/pkg/FR-2017-07-28/pdf/2017-15825.pdf.