Home Health & Hospice Week

Regulations:

Avoid This Mistake Nearly 7,000 Agencies Are Making

CAHPS, OASIS manuals, PECOS, ABNs also addressed in forum.

Registering only one user to submit your OASIS data and view reports online is a big mistake, yet more than 6,900 home health agencies are currently making it.

Better: You should register one primary user and one backup user so you aren't reliant on a single person for submitting and viewing information, said the Centers for Medicare & Medicaid Services in the Aug. 25 Open Door Forum for home care providers. Then if your primary user leaves, your agency doesn't find itself unable to submit patients' OASIS assessments or view CASPAR reports, CMS's Pat Sevast said. That problematic scenario has happened to "numerous" agencies that have contacted the QIES help desk, she related.

Each agency can have only two registered users -- but that's per site. So if you have three branches, you are allowed six registered users. And if you feel two users aren't enough, you can petition CMS for an additional user, Sevast noted.

Remember: "It is a violation of CMS security policy to share your personal ID and password with others," Sevast reminded agencies.

For more information or to acquire an additional registration, go to http://www.qtso.com or call 1-888-477-7876.

Other issues addressed in the forum include:

CAHPS. Think it's too late to apply for an exemption from participating in the Home Health Consumer Assessment of Healthcare Providers and Systems (HH CAHPS) survey? Think again.

CMS has extended the deadline for exemption-eligible agencies, which includes those that are Medicare-certified and served fewer than 60 unduplicated survey-eligible patients in the 12 months ending March 31, 2010.

However, there is not yet a new deadline for applying for the exemption, CMS said in response to a question from Rachel Hammond of the Texas Association for Home Care & Hospice. "The up-dated deadline will be put into the final rule for the Home Health Prospective Payment System," CMS's Lori Teichman told forum participants.

Agencies that are not eligible for the exemption have only until the end of this month to collect their "dry run" data, which their vendor will submit for them by Jan. 21, 2011, Teichman said. HHAs that fail to submit CAHPS data will see a 2 percent reduction to Medicare payment rates in 2012.

Resources: CAHPS information is at www.homehealthcahps.org. More information about the program, including the steps required to participate, are in an MLN Matters article at http://www.cms.gov/MLNMattersArticles/downloads/SE1025.pdf.

OASIS Manuals. Your wait for the Out-come-Based Quality Monitoring (OBQM) Manual is over. The revised manual is now available on CMS's website.

The updated manual defines and describes agency patient-related characteristics (formerly referred to as case mix) and potentially avoidable events (previously called adverse event outcomes). It also offers instructions on how to use reports for quality monitoring and several hypothetical samples to help agencies best use their own data.

Next up: CMS plans to release the revised Outcome-Based Quality Improvement (OBQI) Man-ual shortly. The agency recently posted a revised version of the Process-Based Quality Improvement (PBQI) Manual.

Resource: Download the new OBQM manual online at http://www.cms.gov/HomeHealthQualityInits/Downloads/HHQIOBQMManual.pdf.

PECOS. CMS is working on a change request transmittal giving instructions on how to handle claims when the referring/ordering physician isn't enrolled in PECOS, reported CMS's Tolla An-derson. The problem is most common for physicians working for the Veterans Administration, Department of Defense, and Public Health Ser-vice, noted one caller.

Starting in January, the Medicare claims system will reject claims when the ordering/referring physician isn't listed in the PECOS record (see Eli's HCW, Vol. XIX, No. 21, p. 163).

CMS requires VA, public health, and other physicians who do not normally bill Medicare to enroll in PECOS in order to refer patients for Medi-care home health services and supplies, notes the National Association for Home Care & Hospice. Such physicians currently must submit the 855I form with a cover letter explaining their affiliation, Anderson said.

ABNs. HHAs should continue using their current advance beneficiary notice form for the time being. The Office of Management and Budget has approved the new ABN form, but CMS doesn't intend to release it until new manual provisions regarding the ABN are also ready for release, CMS said. There's currently no target date for that.

CMS originally proposed issuing the new HH ABN last fall (see Eli's HCW, Vol. XVIII, No. 21, p. 162).

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