Home Health & Hospice Week

OASIS-C1, COPs, Value-Based Purchasing also addressed in Open Door Forum.

You can finally give physicians a helping hand when it comes to face-to-face documentation — but know which physician you can assist.

Yay: In the 2015 Home Health Prospective Payment System final rule, the Centers for Medi-care & Medicaid Services did away with the much-hated physician narrative for the face-to-face physician encounter.

Boo: Unfortunately, CMS replaced it with a requirement that the physician’s record must contain documentation proving the patient’s eligibility for the Medicare home health benefit (see Eli’s HCW, Vol. XXIII, No. 39).

Yay again: In the Nov. 12 Open Door For-um for home care providers, CMS confirmed that home health agencies will be able to share information about the patient’s eligibility with the physician. You can provide homebound and other eligibility information “to whoever is signing the certification,” CMS’s Hilary Loeffler clarified in the call. “Then that physician will have to adopt it into his or her medical record, meaning they agree with what you’ve written, and they are signing it and dating it into their medical record.”

Since it is your job to collect the physician record supporting the patient’s home health eligibility, you can collect records from the facility physician or the attending physician in the community to support that, Loeffler said. But it is the certifying physician who will need documentation in her record backing up the eligibility determination.

CMS will be educating docs on this new responsibility, Loeffler reminded agencies in the forum. It will present a 1.5-hour MLN Matters education call that starts at 1:30 p.m. ET on Dec. 16, “Certifying Patients for the Medicare Home Health Benefit.” It a target audience of “physicians who certify patients for the Medicare home health benefit, hospital/Skilled Nursing Facility discharge planners, non-physician practitioners who are allowed to perform Medicare home health face-to-face encounters, and home health agencies,” CMS says in a notice about the call.

You and your referral sources can register for the event at www.eventsvc.com/blhtechnologies.

The call will furnish an overview of certifying patient eligibility for home health, including “a new regulation that requires HHAs to obtain documentation from the certifying physician and/or the acute/post acute care facility’s medical record for the patient that serves as the basis for the certification of eligibility,” Loeffler described.

Resource:  For an overview of the PPS final rule which includes the new F2F requirements, sign up for the Eli-sponsored audioconference, “The 2015 HHA PPS Update: Prepare for More Chal-lenges.” The conference by financial expert Mark Sharp with BKD will take place at 1 p.m. ET Tues. Nov. 25. More details are at www.audioeducator.com/home-health/2015-hha-pps-update-11-25-2014.html.

Other HHA issues addressed in the forum include:

• OASIS. The Office of Management and Budget has finally approved the OASIS-C1/ICD-9 form that HHAs will start using Jan. 1, CMS’s Cheryl Wiseman announced in the forum.

You can download the form at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/OASIS-C1.html — scroll down to the “Downloads” section and click on the first link.

CMS’s Kim Jasmin also told agencies that they will start submitting their OASIS data via the new ASAP system Jan. 1. Your state database will no longer accept OASIS data starting Dec. 26, so you’ll take a five-day break from submitting OASIS data.

Resource: For more information on OASIS changes, subscribe to Eli’s Home Health Coding & OASIS Expert at https://www.aapc.com/codes/.

• COPs. You have only a few short weeks left to submit your comments on the proposed changes to the Home Health Conditions of Participation, CMS’s Danielle Shearer told listeners. The due date for comments on the “complete revision” of the COPs is Dec. 8.

Timeline: When you’ll see CMS’s reaction to agency comments is less clear. The agency has three years from the proposal date of Oct. 9 to finalize the rule, Shearer noted. Expect a final rule to take “a significant period of time,” she cautioned. But “we are most definitely hoping to hit that three-year mark or less,” she said.

• Value-Based Purchasing. While many experts expect CMS to move ahead with a pay for performance model, known as Value-Based Pur-chasing, in 2016, it’s not a sure thing yet. 

“CMS is going to carefully review and consider all the comments received as we move forward toward testing a home health value based purchasing model, potentially in CY 2016,” Loeffler noted in the forum. CMS is still considering a 5 to 8 percent adjustment starting in five to eight states, she repeated from the rule (see Eli’s HCW, Vol. XXIII, No. 40).

Keep an eye out: Watch for rulemaking with  more VBP details to come next year, Loeffler said in the forum.

• Recoding. CMS is trying to help you identify when your early episodes get reclassified as later episodes for payment purposes, noted CMS’s Wil Gehne. If your HIPPS code says the episode you are billing is early, but the Medicare claims system says it is later, you currently see a single code.

New way: Starting in April, the system will use 2 codes for that recoding situation — claims adjustment reason code 169, which states an alternate benefit has been provided, along with remittance advice remark code N69, which states PPS code changed by claims processing system, Gehne explained. More details are in the CR at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3104CP.pdf and the ac-companying MLN Matters article at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R3104CP.pdf.