HAP Comment Letter to CMS on Medicare Program; Expedited Determination Procedures for Provider Service Determinations 4 Page(s) / 115.65 Kb - Download time approximately 33.8 secs on a 28.8k connection Adobe Acrobat - Download a viewer for this attachment - How to Download

TO:                Council of Home Health Agencies of HAP

FROM:           Lynn Gurski-Leighton, Director, Clinical Services

SUBJECT:     Summary of Information

Attached is a summary of information that was either addressed at the council meeting in June or was released shortly thereafter that is of importance to home health agencies in Pennsylvania.

Specifically, the summary addresses,

• the published reimbursement updates to the PPS System for home health agencies for FY 2002;
• the American Hospital Association letter to the Secretary of Health and Human Services addressing the regulatory burdens experienced by home health agencies asa result of the implementation of PPS;
• changes to consolidated billing edits to allow for conditional payment of outpatient therapy services following a home health admission;
• the Department of Health Home Health Agency and Hospice Deficiency and Corrective Action Reports; and
• the Pennsylvania Office of Rural Health draft questionnaire to study the impact of the home health PPS on rural home health agencies.

This summary, along with related attachments, is posted on the HAP website under the main menu heading Continuum of Care, Current Issues and then Home Care.

Medicare Program: Update to the PPS System for Home Health Agencies - FY 2002 - The relevant notices on the reimbursement updates to the home health agency PPS were published in the Federal Register on June 29, 2001 and July 3, 2001.  A few of the key update provisions are as follows:

• An increase in the standardized 60-day episode amount from $2,115.30 in FY 2001 to $2,274.17.  The Federal Register outlines the manner in which the adjustment was calculated, taking into consideration the one-time adjustment for costs associated with the implementation of PPS, the mid-year full market basket rate restoration, and the market basket adjustment rate less 1.1 percent for FY 2002.  A published rate of $2,051.59 applies to the 60-day episode amount in FY 2002 for beneficiaries who reside in a rural non-MSA area to account for the 10 percent add-on required under the Benefits Improvement and Protection Act (BIPA) of 2000.
• Modest increases to the various discipline per-visit rates for episodes with four or fewer visits.  As in the standardized episode calculation, the per-visit rate adjustments were impacted by the mid-year full market basket restoration and then the market basket adjustment rate less 1.1 percent for FY 2002.  The rate increases for the various disciplines are as follows as well as the 10 percent adjustment to the per-visit rates for beneficiaries who reside in a rural non-MSA area.

• An addendum that lists the applicable wage index for rural and urban areas for FY 2001 and the expected additional Medicare home health expenditures resulting from the provisions in BIPA that include the additional year delay of the 15 percent reduction, the restoration of the full market basket in FY 2001, the 10 percent rural add-on for Medicare home health services furnished in a rural area, and the 2.5 percent market basket update for FY 2002.  To read the update notice in the Federal Register, go to www.access.gpo.gov/su_docs/aces/aces140.html  The notices are posted in pdf on the hap website.

American Hospital Association (AHA) Proposal to HHS on Regulatory Burdens - A copy of the proposal to reduce the administrative burden of the Outcome Assessment and Information Set (OASIS) for home health agencies that was reviewed at the council meeting by Brian Ellsworth, senior associate director, advocacy and representation, AHA has been shared with Tommy Thompson, Secretary, Health and Human Services (HHS) and forwarded to HAP.  In brief, the proposal outlines the following:

• The total amount of information required by the OASIS form for Medicare patients should be pared down to the 23 items absolutely necessary for Medicare PPS and any information needed to identify patients for the purposes of matching records with other Centers for Medicare and Medicaid Services (CMS, formerly the Health Care Financing Administration or HCFA) required data.
• The pared down OASIS form should only be required at admission to Medicare-covered home health care, upon certain "significant changes in the patient's condition", and at the beginning of each subsequent 60-day interval as defined in the PPS regulations.  The Aha also recommended that CMS design its computer systems to integrate the initial OASIS, 485 form (home health plan of care), and final claim information to develop a profile of a patient that does not require the submission of redundant information.
• The OASIS form should only be required for fee-for-service Medicare PPS patients receiving Medicare-covered home health care.  The requirements for OASIS information on Medicare+Choice  (M+C) enrollees should be left to negotiation between the M+C plans and the home health agencies.  And, there is virtually no justification for the existing requirement for home health agencies to assess non-Medicare patients as part of a condition of participation for Medicare.
• CMS should use explicitly designed research samples instead of collecting OASIS data from all Medicare-certified home health agencies, where the ultimate use and burden of the information collection requirements are not yet clear.
• Home health PPS requires further refinement to reduce the administrative burden of OASIS, improve the PPS clinical relevance, and synchronize reporting requirements with the Health Insurance Portability and Accountability Act (HIPPA).

Payment for Outpatient Physical Therapy Services Following a Home Health Admission - CMS will be making a revision to the consolidated billing edits to allow for payment of outpatient therapy visits.  Currently the edits deny payment if the home health agency has not submitted a discharge notice to the CMS claim system common working file (CWF).  With revision of the edits, the CMS CWF will alert the intermediary or carrier that the therapy claim may be subject to the home health PPS consolidated billing provision, but will allow payment for the outpatient claim.  A new remark code, N-88-this payment is being made conditionally, will appear on the provider's remittance advice to inform the provider that the payment will need to be recouped if it is established that the patient is concurrently receiving therapy treatment under a home health agency episode of care.  The effective date of the change is October 1, 2001.  To see the program memorandum, go to http://www.hcfa.gov/pubforms/transmit/AB0170.pdf

Department of Health Home Health and Hospice Deficiency Reports - Janice Staloski, Director, Division of Home Health, has indicated by written correspondence to home health agencies and hospice organizations of the department's intent to place all home health and hospice deficiency reports on the Department of Health website, which will list all initial and recertification surveys conducted from April 1, 2000 to the present.  Although the letter indicates that the department plans to begin the sharing of this information the week of July 16, 2001, the implementation has been delayed by 30 days to deal with some technical problems and allow for additional response by stakeholder organizations.

The letter further indicates that no report of deficiencies will be posted to the website until the department has received an acceptable plan of correction from the home health agency or hospice.  Following each visit survey, agencies and hospice organizations will have an opportunity to access the department's address to review the deficiency statements as well as type in their plan of correction.  The department will review the plan of correction and electronically notify the agency or hospice when the plan of correction has been accepted.  The entire report (deficiency report and plan of correction) will be posted on the department's web page for viewing by the public once the plan of correction has been accepted and the agency or hospice notified of its acceptance.  If an agency decides not to respond to their deficiency report electronically, the report will indicate that an acceptable plan of correction is on file, but the plan itself will not be posted.

In order to participate in the electronic submission of the corrective action plan, the administrator or director of the agency or hospice must complete, sign, and submit an agreement with the department.  For more information, contact Jan Staloski or Dottie Kraft at the Pennsylvania Department of Health at 717-783-3291.

Pennsylvania Office of Rural Health - Draft Questionnaire to Assess the Impact of the Home Health PPS on Rural Home Health Agencies in Pennsylvania - HAP has been contacted by the Pennsylvania Office of Rural Health and asked to review the questionnaire that will be used to assess the impact of home health PPS on rural home health agencies in Pennsylvania.  HAP is looking for non-rural home health agency administrators to review the questionnaire and participate in a pilot study that will assist in the refinement of the questionnaire before it is used with rural agencies in the actual study.  If you are willing to participate in the review or pilot, please contact Lynn Gurski Leighton at HAP at 717-561-5308.

AHA Proposal to Reduce Regulatory Burdens for HHA - July 2001 22.42 Kb - Download time approximately 6.6 secs on a 28.8k connection Adobe Acrobat - Download a viewer for this attachment - How to Download

Correction to update for Home Health PPS 87.00 Kb - Download time approximately 25.5 secs on a 28.8k connection Adobe Acrobat - Download a viewer for this attachment - How to Download

FY 2002 update to Home Health PPS 63.00 Kb - Download time approximately 18.4 secs on a 28.8k connection Adobe Acrobat - Download a viewer for this attachment - How to Download