Home Health & Hospice Week

Retroactive add-on adjustments likely will take a while longer.

The Bipartisan Budget Act of 2018 may have included some dubious provisions for home health agencies, but one welcome one was the reinstatement of a rural add-on.

In the Centers for Medicare & Medicaid Services' Feb. 28 Home Health Open Door Forum, a CMS official informed listeners that revised pricing software implementing the 3 percent add-on will be implemented April 2. All home health agency claims with through dates in 2018 received on or after April 2 and eligible for the add-on will receive it correctly under the update, he said.

Adjusting 2018 claims received before April 2 may take a while longer, the CMS source acknowledged. BBA 18 contains a variety of provisions requiring Medicare to adjust claims under multiple other benefits. CMS and its contractors are still trying to figure out the timeframe for all those. The CMS staffer hopes the add-on adjustments will start "shortly" after the April 2 pricer software change, he said. Claims will be adjusted by the HHH Medicare Administrative Contractors and won't require any provider action, he added.

Agencies will be notified of the adjustments via remittance advices.

Reminder: The 3 percent add-on won't last under the current law. BBA 18 reduces the add-on to 1.5 percent in 2019 and 0.5 percent in 2020 for agencies "in the highest quartile of all counties ... based on the number of Medicare home health episodes furnished per 100 individuals" (see Eli's HCW, Vol. XXVII, No. 8). But in areas with "a population density of 6 individuals or fewer per square mile," the add-on will be 4 percent in 2019, 3 percent in 2020, 2 percent in 2021 and 1 percent in 2022, the law says. All agencies not fitting in those two categories will see an add-on of 3 percent in 2019, 2 percent in 2020, and 1 percent in 2021.

Other HHA topics addressed in the forum include:

• Payment reform. BBA 18 is mandating home health payment reform by 2020, and your part in making sure it's a reasonable model starts now.

Reform contractor Abt Associates hosted a Technical Expert Panel on the Home Health Groupings Model Feb. 1. The TEP was comprised mostly of representatives from the major trade organizations. "Abt and CMS will use feedback received today to strengthen the Home Health Grouping Model and/or consider alternative payment models," the contractor said in the slide presentation for the meeting.

View the 149 pages of TEP materials at www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HomeHealthPPS/Downloads/HH-PPSHHGM-TEP-materials.pdf. Then you can send Abt any "questions or comments" about the materials at HomeHealth@abtassoc.com, CMS says on its Home Health Center webpage.

"We encourage everyone to review those materials if you haven't already," a CMS official urged in the forum.

CMS is working to put together a summary of comments furnished by the TEP, the CMS staffer said in the call. In the TEP slide presentation, CMS notes that the summary will not identify which panellists made which remarks. The staffer declined to give a timeframe for posting the summary.

Possible last chance: CMS is still deliberating whether to hold more TEPs on the topic, the CMS official told a caller. If that's the case, this may be the last chance for agencies to furnish input to CMS on a payment reform model before it goes back into official rulemaking.

• Timely initiation of care. A change to the logic for this quality measure should help your quality ratings. "The logic for the process measure Timely Initiation of Care has been modified to align with revised guidance in the Medicare Conditions of Participation ... regarding a physician-order resumption of care (ROC) date," CMS says in a document posted to its website. "This guidance was effective January 13, 2018."

The change: "If physician has specified SOC/ROC date, then SOC/ROC should be on or before that date," CMS says. "If no SOC/ROC date has been specified by physician, then SOC/ROC should be within two days of referral or, if inpatient discharge is later than referral, within two days of inpatient discharge."

However, the logic change won't take effect until September and won't show up on Home Health Compare until January 2019, a CMS official said in the forum. See the logic details at www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/Downloads/Home-Health-QRP-Timely-Care-Specifications-February-2018.pdf.

• CoPs. More than a month after the new Home Health Conditions of Participation took effect, CMS still hasn't issued the final Interpretive Guidelines for the new regulations. And no survey and certification staff were on the forum, so callers asking CoPs questions were asked to submit their inquiries via email.
• BBA 18 implementation. In response to a caller's question about implementing the face-to-face documentation changes included in the Balanced Budget Act of 18, a CMS official said they are "still digesting" the law and plan to include BBA 18 provisions in the HH PPS proposed rule expected this summer.
• Low-Volume Appeals. An education call for the next group of providers eligible for the Low-Volume Appeals option is March 13. The call will cover LVA's "current status, and how the settlement process works," CMS says. "CMS speakers discuss how to identify whether you are eligible, which of your pending appeals may be settled, and upcoming submission timeframes." Register at https://blh.ier.intercall.com.

Tip: Don't miss your window to express interest in the LVA process. "For appellants with National Provider Identifiers (NPIs) ending in an even number (0, 2, 4, 6, 8), EOIs will be accepted on February 5, 2018 through March 9, 2018. For appellants with NPIs ending in an odd number (1, 3, 5, 7, 9), EOIs will be accepted on March 12, 2018 through April 11, 2018," CMS says in a newly updated Frequently Asked Question set about LVA.

See the FAQs and other info at http://go.cms.gov/LVA.