Home Health & Hospice Week

Open Door Forum addresses CoPs, PPS, new OASIS and more.

You could have some extra work to do under the hospice condition of participation regarding background checks.

Those checks have to apply to anyone who works for you or with whom you contract that has access to clinical or financial information about your patients, the Centers for Medicare & Medicaid Services said in the June 25 Open Door Forum for home care providers.

That most likely includes pharmacists who are filling prescriptions for your patients, CMS' Danielle Shearer told Addison County Home Health and Hospice in Middlebury, VT. Anyone who has access to clinical or financial records needs the check, Shearer said in the forum.

The CoPs will take effect Dec. 2, Shearer noted. CMS has not yet scheduled surveyor training on the conditions, CMS' Kim Roche said in re-sponse to a question.

Billing questions: Hospices have been receiving some conflicting information about the new hospice claims data requirements. Some intermediaries are telling hospices they apply to any claims submitted July 1 or later, noted a Massachusetts hospice provider.

That's not true, explained CMS' Randy Throndset. The visit reporting is required only for dates of service July 1 or later, he clarified.

Other issues raised in the forum include:

• M0110. CMS recently put out a transmittal detailing corrections for counting early/late episodes when Medicare doesn't cover the episodes (see Eli's HCW, Vol. XVII, No. 20). Since those changes don't take effect until October, home health agencies have wondered if the fix for counting 2007 episodes toward the later designation would go into place in July as expected.

The 2007-related fix will take place in the July 7 system update, confirmed CMS' Wendy Tucker in the forum.

• Patient outcome changes. Starting at the end of the month, CMS will apply its new risk adjustment methodology to all patient outcomes on the outcome-based quality improvement (OBQI) report, reiterated CMS' Debbie Turkay. All 41 measures will be risk adjusted, Turkay noted.

The new adjustment will show up on Home Health Compare when it refreshes its data Sept. 18, she added.

• OASIS-C. A significantly revamped OASIS assessment tool may be closer than you think. According to CMS' tentative timeline, testing of the new OASIS items and public notice of the new form would take place in 2009, Turkay said in response to a question from the Visiting Nurse Associations of America's Bob Wardwell.

If that all takes place as expected, the new form could take effect as early as January 2010, she indicated.