Home Health & Hospice Week

Supplies:

KEEP YOUR SUPPLIES CALCULATIONS SIMPLE WITH CMS CONFIRMATION

Each category receives one flat rate add-on.

In the very intricate changes proposed to the prospective payment system, one thing is relatively simple--how the new PPS will pay you for patients' nonroutine supplies.

In the May 23 home health Open Door Forum, one caller expressed confusion about how the Centers for Medicare & Medicaid Services proposes to reimburse home health agencies for supplies, following industry reports of NRS being tied to case mix.

As Eli's Home Care Week has reported, CMS will pay a flat rate for each of the five NRS severity levels, CMS' Randy Throndset confirmed in the forum.

"It's simply an add-on at the end of the calculation," Throndset said of the levels that pay from about $13 to $367 per episode.

Further explanation: CMS has unbundled the supplies cost that is evenly distributed across all ep-isodes in the current PPS base rate, explains consultant Mark Sharp with BKD in Springfield, MO. Instead, the agency will take that supplies cost and distribute it in different levels for different acuity patients.

Under the proposal, CMS wants to slot the patient into one of five NRS severity categories based on the answers to nine OASIS questions: diagnosis coding (primary and other), wounds (M0450, M0470, M0476, M0488), ostomies (M0550), IV therapy (M0250) and urinary catheterization (M0520). Those represent 31 skin conditions and eight other clinical factors, Sharp notes.

Lingering problems: The new NRS supplies strategy still will leave some of the worst wound care patients without adequate supplies reimbursement, protested one caller in the forum. Patients who have severe decubitus ulcers that are obviously Stage III or IV, but can't officially be staged on OASIS due to eschar, are left in the lowest-paying category.

Long way off: CMS is working on the issue of better measuring pressure ulcer severity levels, including non-stageable ulcers, as part of its 2009 OASIS revamp, promised Doug Brown of CMS' Office of Clinical Standards and Quality. OCSQ soon will field test revised pressure ulcer OASIS items and will work with CMS on setting appropriate payment for newly developed items, Brown pledged.

Not enough: CMS could fix some supplies pay-ment inadequacy problems by redistributing the NRS payment amounts, suggests consultant Pat Laff with Hilton Head, SC-based Laff Associates. Instead of taking the $12.96 in the 0 severity level and redistributing it to all the other levels as Eli's HCW reported in Vol. XVI, No. 17, CMS should take that amount and create a whole new severity level 5 for patients with 100 or more points scored from the OASIS NRS items, Laff urges.

Although the $12.96 amount is rather low, it is distributed over many patients--63 percent of PPS episodes in 2003. If CMS took that amount and instead gave it to the very small number of patients exceeding 100 NRS points, it would add up to a much larger supplies payment for those patients who have extremely high supplies costs. Such a change "would accumulate significant dollars for those limited number of patients in that category," Laff explains.

Note: The NRS severity categories and payment amounts, OASIS items and their point values, and diagnosis codes and their point values are on p. 212-215 of the proposed rule at
www.cms.hhs.gov/HomeHealthPPS/downloads/CMS-1541-P.pdf.