Home Health & Hospice Week

Cutting therapy brings serious compliance risks, industry leader warns.

Home health agencies can’t afford to stick their heads in the sand about the Patient-Driven Groupings Model. Whether you like it or not, a major change in how therapy affects reimbursement is coming Jan. 1.

Almost half of respondents to a recent industry survey expect therapy utilization to decrease under PDGM (see related story, this page). But how you go about reducing therapy services can make the difference in whether you stay in good compliance standing or end up slapped with a punishing claims audit, survey deficiency — or worse.

The National Association for Home Care & Hospice recently surveyed HHAs and found these strategies for PDGM therapy changes topped the list:

• Improved case management (including interdisciplinary planning, decreasing therapy visits, and spreading out therapy visits)
• Rebalancing patient mix through referral relationship/marketing change
• Continuing current practices
• Focusing on coding accuracy and documen­tation management
• Increasing use of PTAs
• Educating staff on PDGM.

“Most of those actions should be considered by HHAs,” says NAHC President William Dombi, who was one of the presenters for a June 4 NAHC webinar reviewing the survey results.

First choice: Physical therapist Cindy Krafft with Kornetti & Krafft Health Care Solutions particularly endorses the steps of improving case management through interdisciplinary planning; rebalancing patient mix through referral and marketing changes; focusing on coding and documen­tation; and educating staff, Krafft tells Eli.

Next, Krafft recommends considering continuing current practices and using more PTAs, but only with certain qualifications. These steps “should only be pursued with confirmation they are appropriate for the agency,” stresses Krafft, who was also a presenter in the webinar.

For example: “I wouldn’t continue current practices without analysis” of those practices, Krafft offers. And she wouldn’t add PTAs or OTAs “unless it was indicated by the patient mix,” she adds.

Strategies to stay away from are arbitrarily decreasing and spreading out therapy visits, Krafft warns. They “do not reflect anything about the needs of the patients and appear more financially than clinically driven,” she says.

“We strongly recommend against an HHA simply reducing therapy visits to achieve cost reduction outcome,” Dombi agrees. “There are many serious risks associated with a financially driven clinical practice,” he cautions.

Dombi tells Eli those risks include:

1. A negative impact on star ratings and Home Health Compare scores.

2. A reduced interest in network inclusion for Medicare Advantage managed care plans, Accountable Care Organization partnering, and other Advanced Payment Models.

3. A claims audit comparing 2017 utilization to 2020 utilization for comparable patients. Such an audit raises the question of overutilization in the pre-PDGM era or underutilization in PDGM, Dombi warns.

4. Condition of Participation and/or accred­itation reviews. “Utilization changes can affect clinical outcomes, raising compliance concerns,” Dombi points out. Those concerns may bring a surveyor to your doorstep.

5. Value-Based Purchasing. Deteriorating outcomes would have a direct effect on an agency’s HHVBP demonstration bonus/penalty, Dombi highlights.

Note: See a recording of the webinar at https://nahc.webex.com/nahc/onstage/playback.php?RCID=103c964f6cdcb4c38b308c3ef31dc933.