Home Health & Hospice Week

CAHPS, PECOS problems also addressed in Open Door Forum.

Why? The Office of Management and Budget has not yet approved the OASIS-C1/ICD-9 Manual, nor the OASIS-C1/ICD-9 assessment tool itself, noted Pat Sevast with the Centers for Medicare & Medicaid Services in the Aug. 20 Open Door Forum for home care providers.

Reminder: The original version of the OASIS-C1 data item set was approved by OMB on Feb. 6, 2014 and was scheduled for implementation on Oct. 1, CMS notes on its OASIS website. But on April 1, the Protecting Access to Medicare Act of 2014 (PAMA) was enacted, which mandates that CMS may not adopt ICD-10 prior to Oct. 1, 2015. The ICD-10 delay resulted in two new versions of OASIS-C1 — one with all the changes except the five diagnosis coding items (called OASIS-C1/ICD-9 Version), which will take effect Jan. 1; and one that includes the ICD-10 changes to the five diagnosis coding items (called OASIS-C1 [Original Version]), which will take effect Oct. 1, 2015, or whenever ICD-10 is ultimately implemented.

Don’t Wait On Final Approval To Start Training On OASIS-C1/ICD-9 Version

Even though OMB has yet to approve the tool and Manual, CMS has posted draft versions of both. You can have “somewhat of an assurance that this will be the final,” Sevast said in the forum.

The draft tool is at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/ HomeHealthQualityInits/OASIS-C1.html and Chapter 3 of the draft manual is online at www.cms.gov/ Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HHQIOASIS UserManual.html.

CMS held training on the new tool Sept. 3. But if you missed it, CMS plans to post the webinar online within a few weeks, Sevast said.

Agencies Play Whack-A-Mole With Physicians’ PECOS Enrollment

Other issues addressed in the forum include:

• PECOS edits. Home health agencies continue to struggle with the so-called PECOS edits, which deny claims when the referring physician is not recorded in the PECOS system, or when the physician’s information on the HHA claim doesn’t match his PECOS record.

Revalidation requirements for physicians are throwing a wrench in agencies’ billing, one agency chain rep told CMS officials in the forum. The problem is that upon recertification, HHAs will discover that the physician is no longer in the PECOS system because he requires revalidation. The agencies can’t figure out how to anticipate when physicians will no longer be in PECOS due to revalidation, because the revalidation timelines do not appear to be uniform, the rep complained.

• CAHPS. Watch for new Home Health Compare data on Oct. 16, said CMS’s Lori Teichman. That’s the date when the Home Health Consumer Assessment of Healthcare Providers and Systems data will update.

And don’t forget to notify your vendor ASAP if you have trouble submitting a monthly patient file, Teichman reminded participants. In turn, your vendor will file a discrepancy notification report. “This information is very important to CMS when CMS is considering if an HHA has met the CAHPS requirement or not for payment update purposes,” she stressed.