Home Health & Hospice Week

Other PPS rule provisions, CAHPs also addressed in Open Door Forum.

Home health agencies might have misgivings about Medicare’s plans to determine patient eligibility based solely on physicians’ records, but they are still overjoyed that CMS plans to ax the hated physician narrative for face-to-face encounters.

In the 2015 home health prospective payment system proposed rule, the Centers for Medi-care & Medicaid Services announced its plans to eliminate the burdensome narrative requirement (see Eli’s HCW, Vol. XXIII, No. 24). But the rule published in the July 7 Federal Register neglects to mention an implementation date for that relief.

In CMS’s July 9 Open Door Forum for home care providers, several callers urged the agency to consider making the change retroactive.

Patrick Conole with the Home Care Association of New York State asked whether CMS might consider issuing instructions to Medicare Administrative Contractors, directing them to disregard the narrative requirement after the assumed January 2015 implementation date — even for periods under which the narrative was in effect.

CMS has already received that question and is “looking into it,” the agency’s Randy Throndset assured listeners. “That is an issue if this proposal would come to fruition, as far as how that would affect claims that are already in the queue.”

Make your voice heard: “I would encourage you to submit that kind of comment through the rule through the formal process,” Throndset added. To submit a comment, go to www.regulations.gov and search for “CMS-2014-0090-0003”. Click on the rule, then click on the blue “Comment Now!” button in the upper right corner. Comments are due by Sept. 2.

Even if the proposal to nix the narrative is finalized, agencies still have six more months under the requirement, pointed out Karen Hart with Palmetto Health HomeCare in South Carolina. CMS shouldn’t forget appeals contractors in their instructions either, Hart said in the call.

“It is something that is being discussed,” Throndset acknowledged. However, “I can’t tell you what actions if any will be taken before 2015,” he said. Agencies will have to stay tuned for the final rule expected in November.

Other home health agency issues discussed in the forum include:

• Certs vs. initial episodes for F2F. Con-fusion has persisted over when the physician face-to-face encounter is required for home care patients. Previous CMS guidance told agencies that F2F was necessary for initial episodes. But now “we are proposing to clarify that the face-to-face encounter requirement is applicable for certifications (not recertifications), rather than initial episodes,” CMS notes in the rule.

How do you know when a patient is getting a cert instead of a recert? When an OASIS start of care (SOC) assessment is used rather than a resumption of care (ROC), noted CMS’s Joan Proctor in her overview of the rule’s provisions in the Forum.

Don’t miss: Keep this tricky scenario in mind when determining cert versus recert status. “If a patient was transferred to the hospital and re-mained in the hospital after day 61 (or after the first day of the next certification period), once the patient returns home, a new start of care OASIS must be completed,” CMS explains in the proposed rule. “Therefore, this new episode would not be considered continuous and a face-to-face encounter needs to be documented as part of the certification of patient eligibility.”

• Value-Based Purchasing. If you feel like CMS’s Value-Based Purchasing segment in the proposed rule was vague, the agency agrees with you. CMS plans to issue a much more detailed model proposal separately, if it decides to proceed with the pay-for-performance initiative, Proctor noted.

• CAHPS. Check out your new Home Health Consumer‑Assessment of Healthcare Providers and Systems‑data shown on Home Health Compare. CAHPS data from all of calendar year 2013 starting displaying on HH Compare July 17.

Remember: You must turn in four quarters’ worth of data for it to show up on HH Compare, CMS’s Lori Teichman said in the forum. 

Note: The 2015 PPS proposed rule is online at https://federalregister.gov/a/2014-15736.