Home Health & Hospice Week

Surveys, M0175 also addressed in forum. Home health agencies will face sometimes-crippling changes to their metropolitan statistical area designations in the new home health prospective payment system rule, which is due to be issued any day.

The Centers for Medicare & Medicaid Services published the new MSAs, taken from the Office of Management and Budget's redesignations last year, in a hospital payment regulation in the May 18 Federal Register, says the National Association for Home Care & Hospice.

The most significant change will be dividing areas that are currently one MSA, such as Boston, into multiple areas. Some areas that were formerly in a high-wage index MSA will find themselves in lower ones, cautions NAHC's William Dombi.

In its hospital reg, CMS said affected hospitals could apply to maintain their current MSAs for a three-year period to mitigate the lower wage index effect. In the May 26 Open Door Forum for home health, the Visiting Nurse Associations of America's Bob Wardwell asked whether CMS will grant the same courtesy to affected HHAs.

CMS is publishing its proposed rule on home health PPS any day, and that rule will spell out whether the transitional period will apply to agencies as well as hospitals, CMS officials said in the forum. "We are aware of the issue," a staffer promised.

The rule also should spell out whether CMS will make HHAs' wage index changes at the same time it makes the hospital ones, now that reimbursement updates will take effect Jan. 1 instead of Oct. 1, agency officials said.

Currently, HHAs' wage indices are one year behind the hospital wage indices because of the calendar year-versus-fiscal year disparity.

Callers Protest Assessment Time Points

Another document CMS soon will issue is a clarification to its survey memo on OASIS and comprehensive assessment requirements for non-Medicare, non-Medicaid patients, officials promised in the forum (see Eli's HCW, Vol. XIII, No. 15).

Home care providers calling into the program protested the brand new requirement to perform comprehensive assessments on non-skilled-care, private pay patients at OASIS time points. "This is an administrative as well as a paperwork burden," one caller said.

CMS maintains the home health conditions of participation always have required the assessments at those time points. But the callers insist they never were required before the April 8 memo.

CMS will issue a clarification on the memo soon -- probably within a few weeks, a staffer estimated.

Other issues addressed in the forum include:

Beneficiary notices. A Notice of Exclusion from Medicare Benefits designed exclusively for HHAs will hit the Federal Register soon. CMS will take comments on the new forms for 60 days initially, and then have another 30-day comment period down the line, an official explained. CMS plans to consumer test the beneficiary notices [...]