Home Health & Hospice Week

Regulations:

HHCAHPS Data Debuts On Home Health Compare

Medicaid ABNs, observation & assessment billing, and therapy reassessment timing also addressed by CMS in forum.

Get ready for your referral sources and potential patients to check out your patient satisfaction data.

The Centers for Medicare & Medicaid Services is making Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) data available on Medicare's Home Health Compare website starting April 19, CMS's Lori Teichman said in the agency's April 11 Open Door Forum for home care providers.

"This is the first time that Home Health CAHPS data will be reported," Teichman told forum participants. Sharing the CAHPS data gives peoplethe opportunity to see "home health agency patients' perspectives of care," she said.

HHAs that have reported data for an entire year will be included in the public reporting, Teichman explained. The reporting time period for the HHCAHPS data displayed is October 2010 through September 2011.

Other issues addressed in the forum include:

  • ABNs. If you have dual eligible patients whose services are covered by Medicaid, they need to sign an advance beneficiary notice Option Box 1 annually, CMS's Evelyn Blaemire confirmed in the forum. Agencies that fail to have the benes sign theABNs could be liable for the services, Blaemire warned.

HHAs report that dual eligible patients are sometimes reluctant to sign the form because they are afraid they will be billed personally for the services, Blaemire acknowledged. Agencies can explain to beneficiaries that Medicare doesn't cover nonhomebound services but Medicaid does -- but only if the bene signs the ABN, she said. HHAs may insert language explaining that fact on the ABN itself, Blaemire clarified.

Reminder: Also, agencies must issue an ABN Option Box 3 when frequency of services decrease, but only when that decrease is not included in the original plan of care, Blaemire said.

  • Observation & assessment. CMS began requiring home health agencies to use new G codes to bill for certain services in January 2011, including observation and assessment (G0163). Your contractor shouldn't require you to have contacted the physician directly for the visit for which you bill G0163, CMS confirmed in the forum.

Also, there is no three-week limit on coverage of O&A, a CMS rep said. But medical reviewers will require the medical documentation to prove that the O&A is reasonable and necessary for that time period.

Remember: "O & A is considered reasonable and necessary when a reasonable probability exists that significant negative changes may occur in the patient's condition," coding expert Lisa Selman-Holman says on her website. "O & A is not considered reasonable and necessary when there has been no significant change in the beneficiary's condition for a reasonable period of time," says Selman-Holman with Selman-Holman & Associates and CoDR -- Coding Done Right in Denton, Texas.

Resource: For an in-depth discussion of G0163, including case studies and documentation tips, see Selman-Holman's presentation on the code on her website at www.selmanholman.com/webinars/handouts/gcodespart2.pdf.

  • Therapy assessments. Questions about how to handle the timing of the 30-day therapy reassessment continue to hound home health agencies. One HHA caller asked a question about the 30- day requirement and hospitalizations in the last forum, then repeated it in this forum after receiving no answer.

The agency rep wanted to know how to address the 30-day assessment when the patient unexpectedly goes into the hospital and is not at home when the 30-day deadline occurs. The HHA "has heard different things on how to handle it," she said.

Stay tuned: Look for coverage of any CMS clarifications on the 30-day reassessment timeline in upcoming issues of Eli's Home Care Week.

Other Articles in this issue of

Home Health & Hospice Week

View All