Home Health & Hospice Week

Provisions from the health care reform law are worrying home care providers -- especially the upcoming face-to-face physician visit requirements for home health agency and hospice patients.

Under a Patient Protection and Affordable Care Act (PPACA) provision, physicians who are certifying patients for home health agency care must have a face-to-face encounter with them. An affiliated non-physician practitioner can also make the faceto- face visit, although the doctor still is required to do the actual cert, noted the Centers for Medicare & Medicaid Services' Randy Throndset in the May 26 Open Door Forum for home care providers.

Under another PPACAprovision, physicians must have a face-to-face encounter with patients when recertifying them for hospice eligibility, Throndset pointed out. Again, a related NPP may do the visit, but the physician must certify the patient.

In both cases, the law leaves some leeway regarding the timeframe for the face-to-face encounters, Throndset explained. CMS plans to issue details about implementation, including the timeframe, for both face-to-face visit requirements in the home health prospective payment system proposed rule this summer.

Controversy: PPACAmakes the HHA faceto- face requirement retroactive to Jan. 1, 2010. Agencies fear that CMS will apply the requirement back to that date, noted the Texas Association for Home Care's Rachel Hammon in the call.

Retroactive application is one of the issues CMS is considering in formulating its proposed rule, acknowledged CMS's Lori Anderson. "We are still working through those implementation issues and you'll have to wait for the home health proposed rule to get specifics about our implementation plan." There are lots of problems with the face-toface requirement, the National Association for Home Care & Hospice notes in draft comments about the mandate. For example, delays in getting patients in to see a community physician after a hospital visit may mean longer hospital stays or hospital readmissions. NAHC's draft comments list 17 other problems or unclear areas regarding the new face-to-face requirement.

Other issues discussed in the forum include:

• HHA reform law provisions. CMS ran down a partial list of PPACA provisions specific to HHAs. The HHA market basket inflation update will be reduced by 1 percent in 2011, 2012, and 2013.

After that, it will be reduced by an unspecified "productivity adjustment," Throndset detailed. In 2014, CMS will begin a four-year phasein of a PPS rebasing. Also, payment of outliers will be capped at 2.5 percent of total home health outlays, but 5 percent will be withheld from HHA payment levels for them (see Eli's HCW, Vol. XIX, No. 15, p. 114).

CMS will formulate a value-based purchasing (i.e., pay for performance) plan for HHAs by October 2011. And CMS will initiate a national pilot program on payment bundling across sites of service by January 2013.

On the bright side, PPACA also included the 3 percent rural add-on that already is being applied to your payments.

• Hospice reform law provisions. Hospices also see their share of changes in PPACA. Hospices with a yet-unspecified number of patients over the 180-day length-of-stay mark will see additional medical review, Throndset said. And hospices' market basket inflation update will be reduced by a productivity adjustment starting in 2013. The market basket amount also will be reduced by 0.3 percent starting then.

And CMS will formulate a plan for hospice payment reform, Throndset added. Hospices will be required to submit quality data or face a reimbursement rate reduction as well.

• PECOS. Beginning in July, durable medical equipment suppliers will be able to use the Internet-based Provider Enrollment Chain and Ownership System (PECOS) for enrollment and changes to their own enrollment information. HHAs and hospices are already eligible to use PECOS.

All providers must undergo a two- to threeweek authentication process before being cleared for PECOS use, noted CMS's Jim Bossenmeyer. Suppliers that want to use the system right away should initiate the authentication process in advance of the July 13 start date.

Home care providers can get help in using PECOS by utilizing the "getting started" guidebooks at www.cms.hhs.gov/medicareprovidersupenroll -- click on "Internet-based PECOS" and scroll down  to the "Downloads" section to access them.

Hitch: Many HHAs have checked their information in PECOS and it is incorrect, despite having submitted correct information to their intermediaries, TAHC's Hammon said in the call. They are having trouble getting that information corrected, Hammon told CMS.

• PBQI. CMS has issued the Process-Based Quality Improvement Manual, which is based on process measures introduced with OASIS C, said CMS's Pat Sevast. The manual includes samples of the PBQI-based reports that HHAs will start receiving in September (see related story, this page). To access the 47-page manual, go to www.cms.gov/HomeHealthQualityInits, click on "OASIS  PBQI/Process Measures" and scroll down to the "Downloads" section. Or for a free PDF copy, e-mail editor Rebecca Johnson at rebeccaj@eliresearch.com with "PBQI Manual" in the subject line.

• Rural add-on. The rural add-on contained in PPACA is now being paid to HHAs, confirmed CMS's Wil Gehne in the forum. But a software error is causing all non-routine supplies (NRS)  portions of PPS payments to include the add-on as well.

The good news is that the error usually results in an overpayment of less than $1 per claim, Gehne pointed out. Contractors will implement a fix for the problem "shortly," he pledged. If you're waiting for your add-on funds for claims paid without the add-on because the software wasn't yet in place, you'll need to wait a while longer. "CMS will adjust these claims to pay the add-on amounts later this year, but the final schedule for those adjustments has not yet been decided," Gehne said.

• CAHPS. Don't forget to line up your Home Health Consumer Assessment of Healthcare Providers and Systems (HH CAHPS) vendor so you can submit your first CAHPS data in the third quarter, which starts next month, said CMS's Lori Teichman in the call. If you don't submit some quality data for at least one month in July, August, or September, you'll see reduced PPS payments in 2012, Teichman reminded forum attendees. More information is at www.homehealthcahps.org.