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. "There was time to [research them] for folks who were interested in it," Gehne contended.

"We were just hoping wiser heads would prevail," Wardwell retorted.

• NPIs. HHAs are also on their own so far in the physician National Provider Identifier predicament.

Starting next May, agencies must have the physician's NPI number as well as their own to bill Medicare. But contacting 800 referring physicians individually for their numbers isn't feasible, one caller insisted. HHAs want a quick way to look up physicians' NPIs.

"This is cruising for a home health meltdown and I hope someone pays a little attention to this," Wardwell added. "All home health agencies need to know how they are going to be able to get NPIs from their physicians efficiently when there may not be a directory available publicly."

Don't forget: Providers must also get their own NPI for each of their subparts, such as separate locations, a CMS staffer said. Information on what qualifies as a subpart is online at www.cms.hhs.gov/nationalprovidentstand/.

• Managed care. The open enrollment period for beneficiaries to choose a Medicare Advantage and/ or Medicare drug coverage plan begins Nov. 15 and runs through Dec. 31, a CMS staffer reminded listeners.

If a beneficiary wants to switch from one plan to another, she should just sign up for the new plan and she'll automatically be disenrolled from the old one. But if she wants to switch from a plan to traditional fee-for-service Medicare, she must use a disenrollment form.

An out: Beneficiaries can't drop their prescription drug plan coverage after Dec. 31, a CMS official said in response to a question from the Texas Association for Home Care's Heather Vasek. But they can opt out of a full Medicare Advantage plan after that date, she explained.

• OASIS. CMS is switching the contractor it uses to answer OASIS questions-and-answers, so the current Q&A email address soon will be kaput, noted CMS' Pat Sevast. The agency will issue a new email address for OASIS Q&As shortly.

Remember: You can download the newest Chapter 8 OASIS Manual's corrections on CMS' OASIS Web site at www.cms.hhs.gov/oasis, Sevast said (see Eli's HCW, Vol. XV, No. 39).

• Bundling. CMS will update its list of HCPCS codes used for home health consolidated billing any day, Gehne said (see Eli's HCW, Vol. XV, No. 39).

This year's changes include codes for both supplies and therapy that agencies must pay for with their PPS rate, he noted.