Home Health & Hospice Week

CMS will combine PPS refinements, 08 update and OASIS changes in one regulation.

You shouldn’t have to wait much longer for the biggest changes to the prospective payment system since PPS began in 2000.

The long-awaited PPS refinements rule is in the final stages of clearance at the Office of Management and Budget, Centers for Medicare & Medicaid Services’ Carol Blackford said at the National Association for Home Care & Hospice’s policy conference April 23. While CMS couldn’t say at the conference when the rule would be out, “we hope it’s going to be soon,” Blackford told a standing-room-only crowd.

Surprisingly, the proposed rule will contain more than major changes to PPS. It will also include the 2008 Medicare payment rate update for home health agencies and possible OASIS changes required by the PPS refinements. “If you’re confused, we are too,” quipped CMS’ Mary Weakland in the same presentation at the Washington, DC meeting. Whether the resulting OASIS changes will be wrapped into the refinements rule will depend on the rule’s timing, Weakland explained.

Expect More Therapy Medical Review

Hint: Blackford wouldn’t say what areas the PPS refinements would address, citing notice and rulemaking restrictions. But she did give a hint when she outlined areas of PPS contractor Abt Associates has been researching--the therapy threshold, long-stay patients, adding diagnoses into the payment system categories and non-routine medical supplies.

Red flag: Changing the therapy threshold may mean a big bump in medical review on therapy services, predicts consultant Tom Boyd with Rohnert Park, CA-based Boyd & Nicholas. If CMS uses a three-tier therapy threshold as speculated with six, 14 and 20 visits, some agencies might start routinely furnishing 14 to 15 visits where they now furnish 10 to 11 visits, Boyd suspects. Medical reviewers will come down hard on HHAs who suddenly increase therapy visits for patients with the same diagnosis and HHRG, Boyd warns.

And HHAs are likely to rue the fact that they haven’t been including the cost of non-routine medical supplies on their claims and cost reports, Boyd adds. CMS probably found little cost data to support paying extra for those supplies because agencies often don’t bother to include it. That’s because under PPS, they don’t receive any extra direct payment for including the supplies costs, he notes.

Watch out: Blackford also highlighted a provision in President Bush’s 2008 budget proposal that would reduce the PPS base rate to compensate for supposed “upcoding.” One reason the PPS refinements rule has been held up so long is because the feds are considering using that rebasing tool to combat so-called case mix creep, industry insiders say (see Eli’s HCW, Vol. XVI, No. 10).

CMS is hoping the rule will be out very shortly, Blackford stressed. “We’re very anxious to get that [proposed rule] published and start getting your feedback,” she told conference attendees. v