Home Health & Hospice Week

PPS 2015, ICD-10 implementation, and more discussed in recent conference.

Home health agencies have a lot on their plates for the coming year. Take a look at what Centers for Medicare & Medicaid Services officials highlighted in a recent industry conference:

• Alternative sanctions. The second slate of alternative sanctions will take effect July 1, and it includes the serious ones — civil money penalties and payment suspensions — plus Informal Dispute Resolution (IDR). The lesser sanctions — temporary management, directed plans of correction, and directed in-service training — took effect last July, although CMS just published surveyor guidance on how to use them.

Resource: CMS issued the revisions to Ap-pendix B of the State Operations Manual with Sur-vey & Certification Letter 14-14 on March 14, pointed out CMS’s Pat Sevast during the National Asso-ciation for Home Care & Hospice’s March on Washington Conference. The guidance to surveyors on how to apply the sanctions is in the letter at www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-14.pdf.

The guidance covers the implementation, basis for, and notification requirements for the individual sanctions, NAHC says in its member newsletter. It also details the IDR process and the formal appeals process when CMP sanctions are imposed.

IJ: And the guidance covers enforcement actions for deficiencies that pose either immediate jeopardy or no immediate jeopardy situations, NAHC adds. “In cases where deficiencies pose im-mediate jeopardy to patient safety, CMS will terminate an agency’s provider agreement no later than 23 days from the last day of the survey, unless immediate jeopardy is removed,” the trade group points out. “CMS may also impose sanctions in cases of immediate jeopardy.” In non-IJ cases, agencies that are noncompliant with conditions of participation and repeat noncompliance with condition and standard-level deficiencies may also be subject to termination and/or imposition of sanctions.

The Appendix B changes are in effect now, due to their publication in the survey & cert letter, Sevast confirmed in the question-and-answer portion. Expect to see the SOM revision containing the changes within a few months.

Stay tuned: CMS will post a surveyor training webinar on alternative sanctions soon, Sevast said. The webinar is one conducted for surveyors last fall. Watch for the post at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/OASIS/Training.html.

The cyclical noncompliance factors will take effect starting with surveys July 1 and later, Sevast confirmed in response to a question.

• 2015 PPS Rule. Don’t expect any big surprises in the payment rule for next year. The prospective payment system proposed rule schedule for the beginning of July should contain the second year of rebasing cuts, a wage index updated with new CBSA designations, and a new productivity factor in the Market Basket Index inflation update, said CMS’s Hillary Loeffler at the conference.

Point: Industry sources have bemoaned that 40 percent of agencies will have negative Medicare margins under rebasing, Loeffler said in the March 24 home health regulatory panel. But 83 percent of that 40 percent were already recording negative margins before the rebasing cuts occurred, she contended at the meeting.

• ICD-10. CMS is going full steam ahead with ICD-10 implementation for Oct. 1. Beta testing on the ICD-10-based home health grouper starts in April, Loeffler said. CMS plans to post the new grouper to its site by July.

The new grouper cuts non-specific diagnosis codes, those eliminated by the coding provisions of last year’s payment rule, and initial encounter codes, she added.

CMS will be adding claims processing edits related to ICD-10 codes, Loeffler said. Watch for a coming CR transmittal with more specifics on the edits.