Home Health & Hospice Week

Proposed PPS rule, OASIS C-1 revamp also addressed in forum.

Hold off on ordering any more copies of the home health advance beneficiary notice form.

The Office of Management and Budget has approved the Centers for Medicare & Medi-caid Services’ Home Health Change of Care Notice, CMS’s Evelyn Blaemire revealed in the July 9 Open Door Forum for home care providers.

How it will work: CMS is replacing the current HHABN (R296) with a combination of the regular ABN (R131) and the new CCN (10280), Blaemire explained. The ABN will replace the HHABN Option Box 1 (in which the patient declines non-covered services or agrees to pay out of pocket for them). The CCN will replace Option Box 2 (for changes due to agency needs) and Option Box 3 (for reduction in services as required by a physician order).

CMS will be releasing the forms "in the near future," Blaemire said. HHAs then will have 60 days to transition to the new forms, although they can use them immediately if they want to.

Earlier this year, the National Association for Home Care & Hospice praised CMS "for taking steps to clarify and simplify the process for informing Medicare beneficiaries of reductions in service by proposing the use of two separate forms" (see Eli’s HCW, Vol. XXII, No. 7).

Watch for CMS to post the new forms at www.cms.gov/Medicare/Medicare-General-Information/BNI/HHABN.html.

Other issues addressed in the forum include:

•  PPS proposed rule. CMS’s Hillary Loeffler summarized CMS’s 2014 proposed rule for the home health prospective payment system, from the rebasing reductions to ratcheting down case mix weights to changes to LUPAs and NRS rates (see Eli’s HCW, Vol. XX, No. 24 for in-depth coverage of the rule).

HHAs have until Aug. 26 to submit comments on the changes, Loeffler reminded attendees. Providers can submit them at www.regulations.gov — search for "cms-2013-0140" in the blue search box and select the "Comment Now" button next to the regulation listing. You can also view other comments submitted in the listing.

• OASIS-C1. CMS is encouraging HHAs to review the changes to OASIS-C scheduled to take effect next year, said CMS’s Kim Roche in the forum. (See Eli’s HCW, Vol. XXII, No. 23 for details of the OASIS-C1 proposal). This is the industry’s chance to comment on the revisions, Roche noted.

For example: "I like that [CMS] clarified the vaccination question to ask if we have determined if anyone gave them the vaccine, rather than if we gave it to them," says Craig Steffel of A Plus Home Health Care Inc. in Highland, Ind.

How to: Click the "Comment Now" button at www.regulations.gov/#!documentDetail;D=CMS_FRDOC_0001-1233 to submit your feedback. Or e-mail editor Rebecca Johnson at rebeccaj@eliresearch.com for a direct link to the comment page — list "OASIS-C1 Comments" in the subject line.

•  Quality measures. CMS has revised technical documentation information on quality measures, Roche noted. Find links to the revised documents at www.cms.gov/Outreach-and-Education/Outreach/OpenDoorForums/Downloads/070913HHHDMElinks.pdf — select the first three links.
•  OASIS Manual. CMS has published its June revisions to the OASIS Users Manual. For example, item M1810 on dressing the upper body now specifies that ability can be limited by the "location where dressing items are stored." A link to the June errata is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIOASISUserManual.html under "Downloads."
•  CAHPS. CMS planned to update the Home Health Compare website July 18 with home health CAHPS data through December 2012, said Debra Dean-Whittaker in the forum.

Changes to patient mix adjustment factors also go into effect July 18, Dean-Whittaker noted. Information on the changes is at https://homehealthcahps.org/PMAandHHCAHPSresults_AprPublicReporting2013.pdf.

Plus: Avoid having your Medicare reimbursement rate docked 2 percent for no good reason. "If your HHA has trouble submitting a monthly patient file to your vendor, be sure to tell your vendor immediately," Dean-Whittaker advised in the call. "Vendors should always fill out a discrepancy notification report for any and all missed months so that CMS is aware of the reason for missed months by home health agencies."