Home Health & Hospice Week

Plus: Vendors get closer to panicking as they wait for CMS to issue OASIS-E data specs.

In the forum held June 29, the Centers for Medicare & Medicaid Services offered a quick outline of the 2023 proposed rule that it released June 17. Despite the brief overview, forum attendees posed some pointed questions about the regulation.

For example: All-payer OASIS was the focus of one agency’s inquiry. The HHA representative asked how CMS plans to guarantee privacy for patients whose care is not paid by Medicare, but have their data submitted to Medicare.

A CMS representative replied that the agency will clarify those specifics in the final rule, and noted that the agency can’t comment on the issue during the rulemaking cycle.

Another example: In its rule summary, a CMS official noted the rule’s proposal to change the VBP agency and model baseline years from 2019 to 2022. “We believe that updating the baseline years provides home health agencies the opportunity to be scored using the most current measure data available,” the staffer explained.

An HHA asked CMS whether it had truly considered the change’s impact on agencies. “We’ve spent an awful lot of time trying to improve those numbers and make sure we understand where we are, to be repositioned,” the caller told CMS. “That’s a lot of work to have to repeat to catch up with the 2022 numbers,” she admonished.

CMS wants to use data that is the “most current and is not pre-pandemic,” the CMS source told the caller. Using the most current data appears to be what’s best for the majority of agencies, she maintained.

One more example: The HH Quality Reporting Program currently uses Acute Care Hospitalization during the First 60 Days of Home Health (NQF #0171) and Emergency Department Use Without Hospitalization During the First 60 Days of Home Health (NQF #0173), both of which are based on claims data. But come January, CMS will replace them “with the Home Health Within-Stay Potentially Preventable Hospitalization claims-based measures,” CMS said in the 2022 home health final rule published in the Nov. 7, 2021 Federal Register (see HCW by AAPC, Vol. XXX, No. 40-41).

A table in the new 2023 proposed rule lists the old ACH and ED measures, a caller noted. He asked whether CMS still plans to replace them with the PPH measure.

CMS does intend to replace the measures, an official told the caller. CMS will issue technical updates for some tables in the rule, she added.

Comments on the rule are due by Aug. 16, CMS reminded forum listeners.

Other home health topics addressed in the forum include:

• OASIS-E data specs. A number of OASIS software vendors called in to beg CMS to release the OASIS-E data specifications as soon as possible — preferably yesterday.

The version of the OASIS-E data specs available is from back in April 2020, one vendor pointed out. “Vendors rely heavily on those,” she emphasized.

Another vendor noted that it is currently “just manually making changes, which always makes me nervous.” The bottom line: “The sooner we can get the updated draft specifications, the better,” she urged.

A third vendor highlighted that there is about six months left to finish preparations for OASIS-E from a technical standpoint, and for clients to educate their clinicians. “I can’t stress strongly enough how important it is to get those specifications out as soon as possible,” she told the feds. “I really hope you can tell me [they’ll be out] in the next month, so all of this work can be completed,” she said.

• Home infusion therapy and home health. One home health caller asked CMS if a patient gets their infusion therapy at a Part B location, then comes home, whether an HHA could bill to disconnect the infusion at home.

CMS officials on the call seemed confused about the right answer to that question. At first, a CMS staffer said the agency could bill for the service only if it was an enrolled HIT provider. But then Bill Noyes with the National Home Infusion Association pointed out that if the drug was furnished at an outpatient clinic, it would be billed to an A/B Medicare Administrative Contractor and not a DME MAC, and therefore wouldn’t be a HIT drug.

CMS said it would research the issue and report back.

There’s “a lot of confusion about the intersection of HIT and home health,” Noyes noted.

• Care Compare. Preview reports for HHAs’ July refresh data on Care Compare are currently available in agencies’ CASPER folders, a CMS official noted.