Home Health & Hospice Week

Beware a 2 percent reduction to your Medicare payments.

Pay for performance isn't ready for prime time, but a P4P supporting requirement will hit home health agencies--and their pocketbooks--within a year.

The earliest P4P will apply to the entire home health industry is probably 2008. But thanks to a little-noticed Deficit Reduction Act provision, agencies will see a 2 percent cut to their Medicare payments starting Jan. 1, 2007 if they fail to report unspecified quality data to the Centers for Medicare & Medicaid Services.

The law leaves CMS the discretion to decide exactly what data to require, noted Laurence Wilson, director of CMS' Chronic Care Policy Group, in a March 27 session at the National Association for Home Care & Hospice's annual policy conference in Washington, DC.

CMS will issue details on the requirement "later this year," Wilson told attendees.

CMS could decide that current OASIS data collection fulfills the requirement, industry observers note. Or the agency could go a step further toward P4P implementation and require additional data.

Other regulatory and policy issues coming down the pike include:

1. Post-acute demonstration. The DRA requires CMS to launch by 2008 a demonstration project "for purposes of understanding costs and outcomes across different post-acute care sites."

Under the demo, a patient discharged from acute care will receive "a single comprehensive assessment ... of the needs of the patient and the clinical characteristics of the diagnosis to determine the appropriate placement of such patient in a post-acute care site."

CMS is at work on that single assessment instrument that will transcend all post-acute settings, Wilson said. The goal is to develop site-neutral payments for post-acute care.

This demo could give HHAs an opportunity to "get more access to patients," instead of those patients entering a more expensive treatment setting, noted Dexter Braff of The Braff Group in Pittsburgh in the question-and-answer portion of the session.

Wilson acknowledged that possible result, adding that the nursing home industry had "shown interest" in the same results of this provision.

2. PPS refinements. CMS is mulling a number of changes to the prospective payment system, including therapy threshold changes and medical supply compensation (for more details, see Eli's HCW, Vol. XV, No. 12). The current 10-visit therapy threshold is "too much of a jump, kind of like a rehabilitation cliff," Wilson said in the session.

CMS hopes to issue a proposed rule on the changes this year.

3. OASIS lock date change. The seven-day lock date for OASIS data will disappear as of June 21, noted Pat Sevast, former consultant and current CMS Survey and Certification Group staffer. "You can't do it now," but must wait for the implementation date, Sevast reminded agencies in the session.

The new OASIS regulation, published in the Dec. 23, 2005 Federal Register, also puts in place a 30-day deadline for transmitting data and requires branch office ID numbers, Sevast noted (see Eli's HCW, Vol. XV, No. 1). OASIS data transmittal will be required 30 days from the date in M0090, she clarified.

4. CERT. CMS will calculate its provider payment error rate twice a year, up from the current annual calculation, Marie Casey, director of CMS' Program Integrity Group, noted in the session. CMS is also "speeding up" the Comprehensive Error Rate Testing report period by three months to include the most recent data possible, Casey said.

5. CMS 2567. While it's not a done deal, CMS is looking into automating the troublesome 2567 survey form, Sevast revealed. The form, which includes the surveyors' statement of deficiencies on the left side and the provider's plan of correction on the right side, gives home health agencies fits because they must manually place information into the right-hand column of the paper report they receive from surveyors.

CMS hopes to conduct a survey of states' electronic capabilities soon and settle on a way to issue an electronic copy of the report to providers, Sevast said. HHAs can then just enter their information into the document itself.

"That's great news" that CMS is trying to update its "antiquated methods," noted session moderator Mary St. Pierre of NAHC.