Home Health & Hospice Week

In just a few short months, you'll need to start submitting patient satisfaction survey data or risk your Medicare payments. The financial hit for not reporting Home Health Consumer Assessment of Healthcare Providers and Systems (CAHPS) data won't take place until 2012. But unless you're willing to give up the 2 percent that will come off your Medicare payment rates if you don't report CAHPS data, you need to do a "dry run" of the tool in the third quarter of this year. "You've got to participate in a dry run" during July, August, or September, urged Elizabeth Goldstein with the Centers for Medicare & Medicaid Services in the March 10 Open Door Forum for home care providers. "The dry run is not optional." The reason it's called a dry run is because the data collected won't be publicly reported, Goldstein explained to the 400 people participating in the call. "It's really an opportunity for you to practice the data collection activities," she said.

Reminder: Home health agencies that participate in the CAHPS program must contract with a third party vendor to conduct patient satisfaction surveys that include 34 core required questions and nine optional ones. Agencies may also add their own unique questions to the tool. (See Eli's HCW, Vol. XVIII, No. 42, p. 322 for CAHPS program details.)

The tool aims to "produce comparable data on patients' perspectives of care that allow objective and meaningful comparisons between home health agencies," CMS explained in the prospective payment system final rule for 2010.

Agencies must target completion of 300 surveys per year regardless of how many patients they serve. However, agencies that serve fewer than 60 survey-eligible patients annually are exempt from the new measure, Goldstein reminded agencies. And new HHAs won't have to submit CAHPS data for their first year, CMS said in the rule. For the first year, patients are counted from March 1, 2009 to April 30, 2010, Goldstein detailed.

Medicare and Medicaid managed care patients count in that tally, Goldstein offered. HHAs will begin reporting CAHPS data in the fourth quarter of 2010. Agencies have complained that the cost of completing CAHPS will be more than the 2 percent hit they'll take for not doing it. But agencies should consider the reputational risk they might incur for not participating in the program, experts warn.

Shop around: CMS has approved 39 vendors for CAHPS so far and is in the process of approving more, Goldstein says. HHAs should compare both price and services offered when selecting a vendor, she suggested. "Use that competition to your best advantage."

More information on the CAHPS requirement is at www.homehealthcahps.org.

Other issues addressed in the forum include:

• OASIS C training. CMS still isn't offering Web-based training for the new OASIS tool that took effect Jan. 1, but the agency may eventually offer you other training modalities. CMS took feedback about what OASIS C topics HHAs need covered in training at the e-mail address oasisctrainingfeedback@cms.hhs.gov  this month, CMS's Robin Dowell noted in the forum.Revamping CMS's Web-based training for OASIS C is most likely prohibitively expensive, said CMS's Pat Sevast in the call.

Response: If agencies have to incur the expense of implementing OASIS C, CMS should have to lay out the cash for Web-based training on it, one caller told CMS officials.

• Home Health Compare. The OBQI and OBQM reports you can access now are the last ones you'll get for a while. The quality measure and adverse event reports are on hold while agencies transition between OASIS B1 and OASIS C data, Dowell said. Expect updated reports based on OASIS C data starting in September. Home Health Compare will get its last update based on OASIS B1 data next month, Dowell added. The Web site also will remain static until the OASIS C data is ready.

• OASIS logins. Each parent or branch of your HHA is eligible for two personal login IDs in the OASIS submission system, CMS's Kim Jasmin said. CMS began the conversion from shared agency login IDs to personal login IDs last month. The switch will take place on a state-by-state basis through July.

You can contact the Quality Improvement and Evaluation System Technical Support Office (QTSO) help desk for assistance in obtaining your second login ID, Jasmin added. See the Web site at www.qtso.com for more information.

Tip: These login changes don't affect your MDCN/AT&T client login ID or password, Jasmin noted in the forum.

• Source of Admission codes. Eliminating Source of Admission codes B and C for home health agency transfers may be some work in the short run, but in the long run it should simplify billing for HHAs, said CMS's Wil Gehne in the call. "Currently our systems rely very heavily on those two indicators to tell us when to create episodes and how to assess partial episode payments directly," Gehne admitted. But new condition code 47 will identify transfers between agencies. And Medicare systems will identify readmission situations and allow overlapping home health episodes as they're needed, he said.

The code change takes effect for dates of service July 1 or later. (More information on the code change is in Eli's HCW, Vol. XIX, No. 7, p. 51.)