Home Health & Hospice Week

HHAs may be reaching their breaking point.

Medicare is launching the Review Choice Demonstration in its second state very soon, and you can expect the rest of the three demo states to come on line in short order.

In a low-key July 29 announcement on its RCD website, the Centers for Medicare & Medicaid Services revealed that “the choice selection period for HHAs located in Ohio will begin on August 16, 2019 and end on September 15, 2019,” with the demo starting Sept. 30. “All episodes of care starting on or after this date will be subject to the requirements of the choice selected,” CMS explains.

On one hand: Many Ohio providers were surprised they were second to go for RCD, since the state wasn’t even included on the list of five states for the forerunner of RCD, the Pre-Claim Review Demonstration. (That demo instead included Illinois, Florida, Texas, Massachusetts, and Michigan — RCD includes Ohio and North Carolina in place of the latter two states.)

Some in the industry thought Florida would be next on the RCD list, since it was the second state slated for PCR implementation, notes PT Cindy Krafft with Kornetti & Krafft Healthcare Solutions. CMS halted PCR for Florida at the last second, on March 31, 2017 — one day before the program was supposed to begin in that state (see Eli’s HCW, Vol. XXVI, No. 14).

Ohio agencies also hoped their implemen­tation would be later because they aren’t typically seen as one of the high-risk “fraud” states, Krafft muses.

On the other hand: Ohio “was a good guess because of its size in comparison to Texas and Florida,” notes William Dombi, president of the National Association for Home Care & Hospice. It was probably “a toss-up with North Carolina.”

A smaller number of agencies and claims to process should translate to a less burdensome start.

Remember: RCD’s implementation in Illinois, which took place June 1, will not be typical for the other demo states, experts predict. That’s because Illinois underwent nearly eight months of PCR in 2016 and 2017, and thus was better prepared for RCD’s reviews — particularly laying the groundwork for documentation standards and deadlines for ordering physicians.

CMS last reported an affirmation (approval) rate for Illinois agencies under PCR in January 2017. At that time, in week 24 of the demo, it was 91.7 percent.

But that affirmation rate can be misleading, Krafft warns. Illinois providers were sitting on claims that they knew wouldn’t pass review due to documentation deficiencies, which artificially increases the affirmation rate.

Folks saying “it’s no big deal, look how it’s working in Illinois” may be in for a rude awakening when RCD begins in other states, Krafft predicts.

Don’t forget: Payment in Illinois took a major dip under PCR. “Spending in 2017 was reduced by $100 million over 2016,” Dombi tells Eli. “The volume reduction in Illinois is not easy to explain, but it was real,” he says.

Like in Illinois, you can expect to see perhaps a handful of closures in Ohio due to RCD. “It will be difficult for some HHAs to manage the paperwork,” Dombi expects.

The problem is that RCD is layered on top of a number of other major changes, including PDGM, RAP reduction and elimination, and more, Krafft points out. “What’s the breaking point?” she asks.

“We expect the dedication of agencies to serving patients to overcome the challenges,” Dombi says. “Hopefully, agencies from across the country learned from the PCR experience in Illinois and are confident in their ability to support their Medicare claims.”

Next On The List

Now that the second state’s implemen­tation date is scheduled, you can expect the rest to follow soon. “CMS anticipates 60-90 days between beginning the demonstration in the remaining states of Texas, North Carolina, and Florida,” it says in the RCD notice. “CMS and Palmetto GBA will provide at least 60 days’ notice in advance of the demonstration starting in each additional state.”

While there will be a four-month gap between the start dates in Illinois and Ohio, you can probably expect to see a three-month gap between the other states going forward, Dombi forecasts.

Best guess: Dombi favors North Carolina as the next state to undergo RCD, due to its size. “But that is no more than a guess,” he qualifies.

Florida still might be a contender, since it went so far down the path of implementation under PCR, Krafft offers.

In any case, HHAs in the three remaining states should be keeping a close eye on RCD developments and preparing for implementation in fairly short order, experts agree.

Meanwhile, in Ohio, experts recommend agencies:

• Make their selection. “HHAs must sign up to use the Palmetto GBA eServices provider portal now for information and instructions on the selection process,” says the Ohio Council for Home Care and Hospice on its website (see more about choices in story, this page). “HHAs can only make their selection through the eServices portal, and this is also the best way to submit the required documen­tation,” OCHCH’s Beth Foster emphasizes.
• Learn from Illinois agencies. “Attend an education session or two that are provided by Illinois veterans of PCR and RCD,” Dombi urges. “It is the best way to get the right processes in place and to correct any internal deficiencies.”
• Ramp up and enhance self-audits. Among other changes, you might have to tweak your audit tool to emphasize technical claim elements; institute a claim tracking sheet that includes the Unique Tracking Number (UTN); and involve the intake department more heavily in the process, suggested a presentation by Robin Seidman with Blacktree Healthcare Con- sulting and Wayne van Halem with The van Halem Group at NAHC’s 2019 Financial Management Conference earlier this month in Chicago.
• Embrace the change. “Look at the demon-stration as a process improvement project,” Foster recommends. “Hopefully in the long run you will increase the amount of reimbursement, and decrease the amount of money being taken back.”

Note: See the notice and a link to a recently updated FAQ set at www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Choice-Demonstration/Review-Choice-Demonstration-for-Home-Health-Services.html.