Home Health & Hospice Week

Get ready for OASIS C-1 revamp.

 Home health agencies will have their hands full with new requirements this year.

 So said Centers for Medicare & Medicaid Services officials speaking at the National Assoc-iation for Home Care & Hospice’s March on Washington conference March 18.

 Watch for these major developments coming in the remainder of 2013:

• Clarification on new physician modifier. CMS has received numerous inquires about how HHAs should use the modifier indicating that a physician other than the certifying physician added visits to a plan of care, as required in Change Request 8136 issued Feb. 1 (see Eli’s HCW, Vol. XXII, No. 6). The CR also explains how to fulfill new site of service code requirements.

CMS will issue a new CR with clarification, said the agency’s Hillary Loeffler at the conference. The new physician modifier and site of service code requirements still will take effect July 1, Loeffler told attendees.

And agencies should soon find out what the actual modifier will be. CMS referred to the modifier only as “XX” in the CR and related MLN Matters article. The modifier will be released with the March 31 HCPCS update, CMS says.

 Resource: The CR is at www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2650CP.pdf and the related MLN Matters article is at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLN Matters Articles/Downloads/MM8136.pdf.

• Alternative sanctions guidance. Survey-ors will have five new sanctions to impose on agencies for deficiencies — civil monetary penalties, payment suspension, temporary management, directed plan of correction and directed in-service training. Medicare also will offer an informal dispute resolution (IDR) process for home care surveys. The temporary management, directed POC, and directed in-service training measures will take effect this July, while the CMP, payment suspension, and IDR provisions will be implemented in July 2014.

CMS has done “internal work” on the interpretive guidance for alternative sanctions, reported CMS’s Pat Sevast at the meeting. Now it’s gone out to the CMS regions for feedback, she told conference attendees.

The guidance is coming “fairly quickly,” Sevast said. And expect to see revised surveyor protocols when the guidance comes out, she added.

Bright side: Currently, the consequence of condition-level noncompliance is termination within 90 days, Sevast noted. Under alternative sanctions, that timeframe can be lengthened to six months.

Resource: Details about the sanctions are in the 2013 home health prospective payment system final rule at www.gpo.gov/fdsys/pkg/FR-2012-11-08/pdf/2012-26904.pdf.

• OASIS C-1. CMS will implement the next version of OASIS when the new ICD-10 diagnosis coding set takes effect in October 2014.

 Many of the changes will relate to the diagnosis code items on the assessment tool, but there will be other changes as well, Sevast explained. CMS will modify several items based on industry feedback and renumber some items. And based on demands from the Office of Management and Budget, CMS also will remove some items at certain timepoints. “Some items that you are used to collecting … might no longer be collected,” she said.

CMS had expected to have released the changes already, but the revision was held up by OMB’s input, Sevast related.

• PPS rebasing. The Affordable Care Act requires rebasing of home health prospective payment system rates starting in 2014. You should get your first look at the rebasing methodology and rates in the 2014 PPS proposed rule due this summer.

CMS is staying mum about its HH PPS rebasing activities for now. But in response to an attendee question, Loeffler said that the rebasing methodology will be “similar” to what CMS used to set up the prospective payment system in the first place in 2000.

• OASIS training. CMS has issued multiple modules of OASIS training, Sevast said. And it still has a few more in development — care management, therapy needs and emergent care, and patient history and diagnosis. The modules will number 12 when they are done.

• COPs. In addition to these changes, the home health conditions of participation are back on the table, Sevast reported. CMS proposed major COP revisions way back in 1997 and never has finalized them, she acknowledged. But “they’ve been dusted off again,” she said.