Home Health & Hospice Week

In addition to payment rates, the home health prospective payment system final rule for 2012 addresses these regulatory issues:

• Face to face. As proposed, the Centers for Medicare & Medicaid Services has finalized a change that will slightly improve the burden associated with the physician face-to-face encounter rule that is bedeviling home health agencies. When a facility-based physician performs the F2F visit, she now has the option of completing the F2F documentation and home health certification herself or communicating her clinical findings to the community physician, who may then do the F2F and cert.

CMS also clarifies that it will allow an HHA to "facilitate" communication between the facility and community physician. And it's taking the "attending" modifier off the facility physician to make clear any hospital doc can conduct the F2F.

And CMS confirms that when a F2F encounter doesn't happen on time, an HHA may start the patient's episode when the F2F does occur and eligibility requirements are met -- as long as the agency completes a new OASIS start of care for that date.

• Therapy reassessments. When counting visits for the 13th and 19th visit reassessment requirement, providers should count only Medicarecovered visits, CMS clarifies in the final rule.

And providers should remember that sometimes, a reassessment visit may satisfy both the 13th or 19th visit reassessment and the 30-day reassessment requirement, the agency reminds HHAs

• CAHPS. CMS can't hold agencies harmless when their vendors mess up their CAHPS data submission, the rule says. "HHAs must monitor their vendors to ensure that vendors submit data on time, by using the information that is available to them on the HHCAHPS Data Submission Reports," the agency instructs in the rule.

CMS is surveying CAHPS vendors for compliance and will notify agencies when "a vendor has significant issues that would put HHAs at risk for not meeting the APU requirements," the rule says.

If you received a notice that your 2012 payments rates will be reduced by 2 percent for failing to submit CAHPS data, you have a right to appeal, CMS reminds providers in the rule. HHAs will receive reconsideration decisions by Dec. 31.

• ICD-10. CMS said it was going to get the ICD-10 code sets out in October 2011, but it has bumped that deadline to next April. The agency will try to get the HHRGs based on the new ICD-10 codes out by April 2013, though; that's three months earlier than it suggested previously.

• Homebound. CMS is clarifying its "confined to the home" definition for purposes of determining homebound status. The home health benefit policy manual will now say, "an individual shall be considered 'confined to the home' (that is, homebound) if the following exist: (1) The individual has a condition due to an illness or injury that restricts his or her ability to leave their place of residence except with: the aid of supportive devices such as crutches, canes, wheelchairs, and walkers; the use of special transportation; or the assistance of another person; or if leaving home is medically contraindicated." If the first requirement is met, "the condition of the patient should be such that there exists a normal inability to leave home and, consequently, leaving home would require a considerable and taxing effort," the manual will say.