Home Health & Hospice Week

Tip: Use this new GG decision tree to help with OASIS-D confusion.

Home health agencies hoping to get news on the Review Choice Demonstration, the Patient-Driven Groupings Model, or potential billing implications of new advance directive requirements struck out on all three counts in the latest Home Health Open Door Forum.

Strike 1: The Centers for Medicare & Medicaid Services is still in the process of seeking Office of Management and Budget approval for the RCD pre-payment review project under Paperwork Reduction Act requirements, a CMS staffer said in the Jan. 16 forum.

“Once we have received that approval,” CMS will update its RCD website with final approval and demo information, as well as instructions for participating agencies on how to select their review options, the CMS representative told attendees.

The path forward for RCD is far from clear, industry experts lament. “We do not know what will happen with RCD,” the National Association for Home Care & Hospice’s Mary Carr tells Eli. “CMS continues to suggest that it will occur eventually.”

Sara Ratcliffe, executive director of the Illinois HomeCare & Hospice Council, says “they have told us it will be ‘soon,’ but no indication what that means.”

Once OMB approves RCD, however, Ratcliffe expects things to move quickly. “I suspect once they announce, there will be a window of two weeks or so for Illinois providers to make their choices before implementation,” Ratcliffe tells Eli. HHAs under the demo can choose between 100 percent prepay review, 100 percent postpayment review, or “minimal” postpayment review with a 25 percent payment penalty.

Getting ready: “We are encouraging all of our providers to make sure they are registered and their passwords are up to date in Palmetto GBA’s eServices system earlier rather than later,” Ratcliffe says. “The only way to make their choice is through eServices.”

On the bright side, “our members were happy that RCD did not start before the holidays,” Ratcliffe notes. CMS originally planned to start RCD in Illinois on Dec. 10.

But Illinois agencies now “just would like to have some clear guidance on what the timeframe is for implementation,” Ratcliffe says.

HHAs can stay tuned to Medicare’s RCD webpage at https://go.cms.gov/homehealthRCD for updated information.

Strike 2: A CMS official also asked attendees to hold any questions about the PDGM payment reform model for the agency’s Feb. 12 call on the topic. The call will offer a “broad overview of the model” as well as some “specific payment adjustments,” the speaker said. The event aims to “give you guys a little more information … as we move toward implementation,” he added.

Registration for the call is at https://blh.ier.intercall.com/details/0f559f0d0f904221b76dd6dd49c14855.

Strike 3: News from NAHC that claims may need to be rebilled and documentation augmented, in light of advance directive plan of care requirements and resulting CERT denials, has left HHAs in confusion. Different messages from HHH Medicare Administrative Contractors on the topic hasn’t helped (see story, p. 19).

In response to an attendee question on the matter, CMS said no one on the call could address the issue.

For now, “agencies should follow their contractor’s instructions,” Carr recommends. “Each has a notice posted on their website.” Other home health topics addressed in the forum include:

• OASIS-D. In addition to new quarterly questions-and-answers addressing OASIS-D items (see story, p. 19), CMS has posted a Section GG decision tree to help home health agencies with one of the most challenging parts of the updated OASIS form.

CMS designed the tool to help clinicians across post-acute settings determine appropriate responses for GG items, an agency staffer said. CMS plans to include the decision tree in the next version of its PAC Guidance Manual.

• Star rating preview report. You no longer have to wonder what the revision to the Quality of Patient Care star rating calculation methodology will do to your Home Health Compare stats. Take a look in the QoPC star rating preview report now available from CASPER, a CMS source said. The report contains the data that will go up in the April 2019 Home Health Compare refresh.

Reminder: CMS updated its star calculation algorithm to replace the Drug Education on All Medications Provided to Patient/Caregiver during All Episodes of Care process measure with the Improvement in Oral Medications outcome measure.

• HH QRP training. CMS will hold a two-day HH QRP in-person train-the-trainer event March 5 and 6 in Baltimore, a rep announced. Registration is not yet open for the session, but should be available in the next two to three weeks, she said. Stay tuned to the HH QRP spotlight webpage for registration information.
• CAHPS. CMS will post updated CAHPS manuals, as well as related training slides, on its CAHPS website later this month, a CMS official said.