Home Health & Hospice Week

Home health agencies are two months into the new therapy reassessment rules, and they have more questions than ever about how the requirements are supposed to work.

Many details of the 13- and 19-visit therapy reassessments have been worked out, but the ins and outs of the 30-day reassessment timeframe are sometimes throwing agencies for a loop.

For example: The Centers for Medicare & Medicaid Services reiterated in its May 25 Open Door Forum for home care providers that the therapy rules began for episodes with starts of care April 1 or later. But for recert episodes beginning after that date, can therapy assessments/reassessments conducted before the episode began count for the 30- day rule? a caller asked in the forum. And if not, does the first visit of the post-April 1 episode have to be conducted by a therapist rather than an aide?

CMS representatives in the forum didn't have immediate answers for those questions.

Mary St. Pierre from the National Association for Home Care & Hospice also asked in the forum whether there were any exceptions to the 30- day timeframe when the missed reassessment visit isn't an agency's fault. For example, if the patient goes into the hospital or refuses visits, there's nothing an agency can do to fulfill the 30-day requirement.

CMS has very little flexibility on that issue due to the wording of the Affordable Care Act provision mandating the new requirements, noted CMS's Randy Throndset in the forum.

HHAs do have one lingering question about 13- and 19-visit timelines, St. Pierre pointed out. What happens if an episode has multiple therapy disciplines involved, but one of the disciplines has no visits scheduled between the 13th and 19th visit? Should the therapist make an extra visit to perform the reassessment for that discipline?

"No, because therapists should visit patients only as ordered in the patient's plan of care," CMS says in a question-and-answer document about the therapy rules posted to its website in May. "If no visit is ordered for one discipline between the 13th and 19th visits, the visit prior to the 19th visit would satisfy the requirement."

Agencies just want to make sure that is true even if the visit prior to the 19th visit is also prior to the 13th visit, St. Pierre said in the forum.

Resource: The therapy Q&As are at www.cms.gov/HomeHealthPPS/Downloads/Therapy_Questions_and_Answers.pdf.

Other issues addressed in the forum include:

• Face-to-face for hospitalists. HHAs are having trouble getting the face-to-face encounter documentation signed by hospitalists, reported a caller from New Mexico. Hospitalist docs there seem to believe that patients being discharged from the hospital are exempt from F2F rules.

Their mistaken belief may come from an exception CMS granted in the PPS final rule publishedin the Nov. 17, 2010 Federal Register. A hospital physician is allowed to make the F2F encounter and document it, initiate orders, and certify the patient for home care, CMS explains in the rule. Then the patient's physician in the community can sign the POC.

However, "in the patient's hospital discharge plan, we would expect the hospital physician to describe the community physician who would be assuming primary care responsibility for the patient upon discharge," the final rule notes.

And the hospitalist's documentation would still have to be up to snuff. "If the hospital physician certifies the patient's HH eligibility and initiates the orders for services, the hospital physician could document that a face-to-face encounter occurred and how the findings of that encounter, which in this scenario would have occurred during the patient's acute stay, support HH eligibility," CMS says in the rule.

The hospitalists the caller described "have certainly read that incorrectly," Throndset observed.

• Reimbursement. CMS's Wil Gehne reviewed the agency's recent releases about newly enrolled agencies submitting OASIS data, outlier corrections, and timely filing for requests for anticipated payment (RAPs).

CMS issued the MLN Matters article about OASIS data submission because a significant percentage of agencies being docked 2 percent for failing to submit data are new enrollees, Gehne explained (see Eli's HCW Vol. XX, No. 20, p. 159).

HHAs that receive notification in May or June of retroactive enrollment back to January or February often mistakenly wait for their whole EDI billing setup to be complete before initiating OASIS submission, which causes them to miss the window for submitting OASIS data for the year, he warned. HHAs have to submit OASIS data by June 30 of their enrollment year to avoid the 2 percent cut.

 "Submitting OASIS data is in no way dependent on getting your EDI claims" process set up, Gehne stressed. New agencies should pursue EDI set-up and OASIS submission simultaneously.

The article is at www.cms.gov/MLNMattersArticles/downloads/SE1115.pdf.

• HHCAHPS. You are free to switch vendors for your Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) data, said CMS's Lori Teichman in the forum. But you'll have to go onto the HHCAHPS website and approve that vendor, or it won't be able to submit the data it's collecting for you.

Remember: Whether you submit HHCAHPS data now affects whether you get a 2 percent reimbursement reduction in 2013.

The HHCAHPS website is https://homehealthcahps.org.