Home Health & Hospice Week

Don't let major payment and regulatory changes happen without your input.

Home health agencies and hospices have some big blank spots about how new provisions proposed in the PPS 2011 update are going to work, but they won't be getting any clarification for a while.

Callers in the Aug. 25 Open Door Forum for home care providers posed some tough questions for the Centers for Medicare & Medicaid Services about provisions on face-to-face encounters for home health agencies and hospices, and therapy reassessments. The HHA and hospice callers were trying to figure out how the proposed provisions would work, but CMS isn't giving out any more information on the new requirements until the final rule comes out, said CMS's Lori Anderson. Providers should submit concerns and suggestions about the provisions as part of formal rule comments, Anderson urged. Providers have until Sept. 14 to submit their questions and feedback.

The provisions are "still proposed and we're still in the open comment period," CMS's Randy Throndset reminded the 223 callers in the forum. What's outlined in the proposal is all CMS can say during the comment period.

Take the time: The National Association for Home Care & Hospice "urges every home health agency to submit formal comments to CMS," the trade group says.

Resource: Directions for submitting comments are in the prospective payment system proposed rule in the July 23 Federal Register online at http://edocket.access.gpo.gov/2010/pdf/2010-17753.pdf.

Hospices need to remember to submit their comments on the face-to-face encounter requirements during the PPS proposed rule comment period too, CMS pointed out. The hospice face-to-face encounter proposal is in the home health rule, not the hospice rate notice.

Starting with claims dated Oct. 1, you need to use the newest version of the PPS grouper or face extra billing work.

"We highly recommend that vendors and HHAs have downloaded this newest version of the software and are ready to begin using it on Oct. 1," Throndset told agencies. However, if you can't do so by Oct. 1, "it's not the end of the world."

What happens: HHAs using the old grouper for Oct. 1 and later claims can still submit their OASIS data to the state, but they'll receive a warning and submit a blank HIPPS code, Throndset explained. Then agencies have to use the HIPPS code generated by the state to put on claims submitted to Medicare.

These rules apply to claims with a date of Oct. 1 or later in M0090, Throndset said. "Remember that it's the M0090 date that drives the HHRG selection, which in turn drives the selection of the ultimate HIPPS code."