Home Health & Hospice Week

Most affiliations are harmless, CMS official assures forum attendees.

Home care providers worried about the impact of the recently released program integrity enrollment final rule got some good news in the latest Open Door Forum for home health agencies and hospices.

A Centers for Medicare & Medicaid Services official ran through the major provisions of the new rule, including what constitutes affiliations and disclosable events (see Eli’s HCW, Vol. XXVIII, No. 32 for more rule details).

The CMS staffer offered an affiliation scenario. John Smith is the owner of home health agency No. 1, which has its enrollment revoked for billing programs. John Smith is also the owner of HHA No. 2. CMS would find HHA No. 2 an affiliate of HHA No. 1 due to John Smith’s ownership, and would investigate HHA No. 2 for possibly posing “an undue risk of fraud, waste, or abuse.”

Keep in mind: CMS and its contractors will not deem the “vast majority” of affiliations as undue risks, the CMS official took pains to point out. Medicare will be “focusing on egregious behavior” with the new PI enrollment procedures, he assured.

The CMS source also clarified one thing that won’t count as a disclosable event for affiliates when it comes to payment suspensions. Suspensions that occur due to a late-filed cost report or credit balance report won’t fall into the disclosable event list, he said.

Other home health topics addressed in the forum include:

• Home Health Compare. Medicare will refresh the data on the outcomes website next month as scheduled, a CMS staffer said. It will be the last quarter for public display of two measures — Rehospital­ization during the First 30 Days of HH (NQF #2380) and Emergency Department (ED) Use without Hospital Readmission during the First 30 Days of HH (NQF #2505). Those measures will be removed in January and replaced with other measures that better capture data, CMS says (see Eli’s HCW, Vol. XXVII, No. 26).
• Quality payment update. You’ll get a notice next month if you failed to comply with quality data submission requirements in 2018, thus lowering your 2020 payment rate. HHAs desiring to request a reconsideration of the decision must submit the request via email only within 30 days of receiving their notification, a CMS staffer explained.

CMS will supply its decisions on the reconsiderations by mid-December, the CMS source said.