Home Health & Hospice Week

CMS reveals PPS details in forum.

The year-end rush to implement prospective payment system changes may not be as frantic as you feared--if the feds can stick to their timeline.

Industry observers have widely expected the Centers for Medicare & Medicaid Services to issue its final PPS refinements rule in October, three months before the Jan. 1 target implementation date. But in the May 23 home health Open Door Forum, CMS' Randy Throndset said the October date "is not accurate."

CMS is already working "feverishly" on the rule and will only intensify those efforts after the comment period ends June 26, Throndset told a whopping 740 forum participants.

"We're well aware that those folks need as much time as possible to make the appropriate changes," Throndset said of software vendors. "We're doing our utmost to ensure that you have that time."

"We'll work to turn that rule around and have it published just as quickly as we can," CMS' Carol Blackford added.

Use these now: CMS already has issued a "toy grouper" and the "pseudocode" software developers can use to start setting up their systems for PPS changes. "While this [toy grouper] tool is not the official grouper software that CMS will add to HAVEN, it is a practice tool that can be used for educational and planning purposes," CMS says at www.cms.hhs.gov/center/hha.asp.

And CMS is working to make sure OASIS and HAVEN will be ready in time for Dec. 27, when home health agencies will have to start collecting the new PPS data such as M0110, CMS' Pat Sevast assured. Because of the five-day window on OASIS assessments, Dec. 27 is the first date agencies can collect OASIS data that must be used for the new PPS that starts Jan. 1, Sevast explained.

Don't hold your breath: But industry veterans are taking a wait-and-see attitude about whether CMS can run on time with the drastic changes included in the PPS refinements proposed rule. CMS admits in the rule that it may stagger implementation of certain items.

Other issues raised in the forum include:

• PPS corrections. CMS issued the PPS proposed rule April 27, but it appeared in the Federal Register May 4. The May 4 notice erroneously stated that the comment period ends July 3, but it actually will end June 26, Blackford emphasized. CMS also issued some technical and formatting corrections to Tables 4, 5 and 12a online at www.cms.hhs.gov/center/hha.asp and in the May 11 Federal Register.

• Episode sequencing. Under the PPS refinements, your episodes will pay differently based on whether they are "early" (first or second) or "later" (third or later). When PPS begins on Jan. 1, episodes will be counted that way based on pre-PPS refinements history, Throndset explained in response to a question from the National Association for Home Care & Hospice's Mary St. Pierre.

In other words, all episodes do not count as first, early episodes just because the payment system change begins, Throndset said. "The clock doesn't start over when we start with this."