Home Health & Hospice Week

CMS also addresses M0175 takebacks, managed care in Open Door Forum.

Regulators won't be poring over your OASIS submissions to see if you qualify for the full inflation update under the new pay-for-reporting requirement.

Background: Congress enacted legislation requiring home health agencies to report quality data to receive the full inflation update to their 2007 Medicare payment rates. The Centers for Medicare & Medicaid Services issued a final rule last month requiring agencies to submit their usual OASIS data to fulfill that requirement (see Eli's HCW, Vol. XV, No. 40).

The pay-for-reporting requirement is a widely acknowledged first step on the path toward full-fledged pay for performance for HHAs.

Clarification: CMS will require only one OASIS data submission during the time period specified to qualify for the full rate increase, revealed CMS' Mary Weakland in a Nov. 8 Open Door Forum for home care providers.

But don't get too used to the light reporting burden. "That may change in subsequent years," Weak-land warned.

Intermediaries will inform providers if they aren't eligible for the full rate increase due to the pay-for-reporting requirement, CMS explained in the forum that drew 379 participants. CMS Readies P4P Demo Taking another step toward eventual P4P, CMS announced its home health P4P demonstration contractor, Abt Associates, is putting the finishing touches on a preliminary demo design. The demo is in the planning stages now and CMS tentatively expects to begin it in October 2007 and conclude it in 2010, a CMS staffer explained.

Give your two cents: CMS will release details about the demo "a bit later," the staffer promised. And the agency will hold a Special Open Door Forum on Dec. 13 to gather input on the demo from the industry.

Other must-have takeaways from the Open Door Forum include: • M0175 takebacks. If you're having trouble researching your M0175 adjustments for January, you're not alone. Providers don't have any quick way to look up which hospital belongs to the provider number whose bill caused the adjustment related to patients' prior inpatient stays, Bob Wardwell with the Visiting Nurse Associations of America protested in the forum.

Right now, the only way providers have to find out the hospital's identity is to contact their regional home health intermediary to look up the provider number for them, said Wardwell, a former top CMS official. And some intermediaries are limiting such inquiries to three numbers per day, he claimed.

HHAs will have an incredibly tight timeframe to file an appeal (see Eli's HCW, Vol. XV, No. 38). Such a limitation on researching the adjustments means agencies won't be able to file many appeals, Wardwell worried.

Too bad: CMS and the intermediaries released the list of claims to be adjusted a year ago, CMS' Wil Gehne noted in the forum. [...]