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More changes ahead for home health this fall

summer shoreup art for solutions 2

What’s on your summer calendar?
Priorities should be internal audits,
reviews and self-assessments

Editor’s note: This post first appeared in a longer article in the June 9 issue of SOLUTIONS,  the monthly e-newsletter from Home Health Solutions LLC. Click here if you’d like to subscribe to SOLUTIONS.

Summertime, and the livin’ is easy. Unless, of course, you’re in the home health field.

From backyard barbecues to long and lazy afternoons at the beach, this is the time of year when leisure time is foremost in our hearts and minds. But this summer, smart home health agencies are looking beyond the distractions of summer to the fall, when the change of season will usher in a new round of major adjustments.

Home health agencies in Illinois won’t even have to wait until fall; the Centers for Medicare and Medicaid Services (CMS) announced last week  that it will move forward with preauthorization requirements despite opposition from the home health industry. CMS will roll out the first preauthorization program in Illinois Aug. 1.

Four more states will follow throughout the fall and winter, with Florida scheduled for Oct. 1, Texas for Dec. 1, and both Michigan and Massachusetts for Jan. 1.

Rollouts in those states will require home health agencies to perform prior authorization before processing claims for services. The procedure would be similar to the Prior Authorization of Power Mobility Device (PMD) Demonstration, which CMS implemented in 2012. It requires prior authorization for scooters and power wheelchairs within seven states where fraud and errors have been prevalent in the past.

Nationwide, this autumn was already shaping up to bring a round of new challenges to home health agencies. In October, when CMS removes a three-year partial code freeze, some 2,500 changes are expected to become part of the ICD-10-CM classification set. At least 1,900 new codes will be added, 351 codes will be revised and 313 codes will be deleted. The tabular list will change as well.

A few Excludes Notes will shift and some others will disappear completely in this first reworking of the code set since its implementation at the start of 2016.

Exactly how these changes in codes will impact the home health field still isn’t clear, as the complete list of revisions has not yet been provided.


Be prepared; coding guidelines are likely to change frequently during the adaptation process to the revisions.

Guidelines already change so often with new interpretations that it can be difficult for coders to keep pace. Major re-interpretations just in the past couple of months had coders scrambling this spring to rethink the way diagnoses and comorbidities can now be linked, and how certain heart failure diagnoses can now be coded without further specification by the attending physician.

Many areas of ICD-10 implemented this year have given rise to questions, and as those issues are reviewed and addressed, coding guidance will continue to evolve rapidly with new interpretations and even reversals. It is crucial for agencies and the coders they employ to stay abreast of every change to reduce compliance risks.    And the changes in the ICD-10 set are just Round 1. On the heels of those changes, the Outcome and Assessment Set generally known by its acronym, OASIS, will undergo its own revisions. OASIS C-2 is scheduled for implementation Jan. 1, 2017, and will add new items, renumber some items, and make other changes in how data is collected.

How can home health agencies and home health coders prepare for all these major changes beginning Aug.1 and continuing through early 2017?

“There’s never been a more critical time to shore up your agency’s operation,” advises J’non Griffin, owner of Home Health Solutions LLC.

Addressing and correcting existing compliance risks this summer will better position agencies to handle problems likely to occur during the adaptation process in the fall, reduce the likelihood of home health professionals feeling overwhelmed by constant change, and provide an extra layer of insulation against potential losses due to claims denials, according to J’non.

She recommends agencies prioritize internal audits, quality reviews and other self-assessment measures between now and Labor Day.

“This summer is the time for agencies to take a proactive approach, identifying and addressing the need for quality clinical documentation and code specificity – and then follow up with extra training measures and education efforts in every area where there is any confusion or performance issue,” she says.

In many cases, it may prove more cost-effective and time-expedient for agencies to streamline operations by partnering with a consultant to develop and implement corrective measures, or to outsource some services.

Home Health Solutions is making it easier than ever to get help with a Summer Shore-Up Package, offering limited-time discounts on new services.

Now through Labor Day, the Summer Shore-Up Package from HHS will offer a 10 percent discount off any standard rate of new services. In addition, agencies contracting for coding services under the Summer Shore-Up Package will receive 5 free OASIS analyses with pre and post-HHRG (Human Health Resource Group) values.

“This discount reflects our sincere commitment to help agencies address areas where they may not be prepared to meet an additional round of challenges,” Jnon says. “We want to take some of the anxiety out of the equation for agencies, providing the guidance and services they need to achieve and maintain success in a fluid and challenging market.”

summer hore up coupon




New coding guidance on “with” changes how coders link diagnoses

art for monday fix may 16Editor’s note: This post appeared in the May 16 issue of “The Monday Fix,” a weekly email from HHS featuring coding tips.  Click here if you’d like to subscribe. 

It may be time to rethink the way you’re coding some stated and assumed relationships in light of new Coding Clinic guidance.

Two back-to-back articles released last week by AHIMA proved to be an eye-opener for many home health coders, updating and replacing previous information about cause-and-effect coding practices.
A Code Cracker Blog post on the Journal of AHIMA website and an article in the May issue of Codewrite, AHIMA’s e-newsletter, both referenced new Coding Clinic advice that reverses much of the thinking among home health coders on the use of subterm conditions listed next to primary diagnoses under the category “with.”

The articles acknowledged Coding Clinic advice that the word “with” should be interpreted to mean a cause-and-effect relationship if:
1.The patient has both diagnoses confirmed by the physician, and
2.There is no other cause provided for the subterm condition.

Examples were offered by AHIMA for a diagnosis of diabetes mellitus, which has some 53 conditions listed under the subterm “with” in ICD-10 coding manuals.
Those conditions may now be coded as complications of diabetes mellitus if the documentation supports both and if no other cause is given.
This means, for example, that coders may accurately assign the code E11.22 (for Type 2 Diabetes with Chronic Kidney Disease) if the physician has separately documented that the patient has both DM and CKD. There is an assumed relationship because CKD appears in the list of conditions associated with DM.
And the new interpretation does not apply only to diabetis mellitus and its 53 subterm conditions; it applies to any diagnosis where the word “with” appears above a list of related conditions.
The one noteable exception is hypertension with heart disease.
For many coders, especially those who trained under a different ICD-9 interpretation, the cause-and-effect assumption will prompt a major shift in thinking.
“Anytime we see the word ‘with’ underneath a diagnosis — except hypertension with heart disease — we are now to assume a cause-and-effect relationship unless the physician indicates another cause,’’ explains Kimberly Searcy, Director of Global Education for Home Health Solutions.
Kimberly joined a group of home health coding professionals for advanced coding training in Houston last week, as the home health coding field was abuzz with questions about the new interpretation, wondering exactly how it will affect their coding.
“This confirmation changed the way we have been coding since the beginning,” Kimberly says. “Coding Clinic states they clarified the original guidance in 2009 when the original update to the coding convention was made. Their clarification, however, was never read the way it was intended.”
Instead, home health coders divided into two camps on the issue. In one camp, many coders assumed it was necessary for documentation from the physician to link the main term listed and any condition under the subterm “with,” while the other camp believed the link was not necessary.

Coding Guidelines:
Here’s what the ICD-10-CM Official Guidelines for Coding and Reporting actually states at 1.A.15:
“The word ‘with’ should be interpreted to mean ‘associated with’ or ‘due to’ when it appears in a code title, the Alphabetical Index, or an instructional note in the Tabular List.
“The word ‘with’ in the Alphabetical Index is sequenced immediately following the main term, not in alphabetical order.”

How will this new interpretation apply to you?

If you have been interpreting the guideline incorrectly, in most cases you will simply need to begin applying the clarified interpretation to your current charts, going forward, without correcting any previous charts. Please check with your employer, however, to confirm that you will not need to update any previous charts.

If you are uncertain about whether documentation supports an association between a diagnosis and conditions due to its complications, it is best to send a query to the physician requesting clarification.

“Updated confirmation will be in print form for release in second quarter, but we are to begin now according to the article released by AHIMA,” Kimberly says. “Coding Clinic has given verbal confirmation along with AHIMA.”

She also offers this bit of sound advice to home health coders about the latest change:
“Don’t get too complacent. Be willing to roll with the changes in ICD-10, which are always on the horizon!”

Here’s a case example:

Marti Holthus, a Quality Reviewer and Mentor for Home Health Solutions, provides this example of how the new interpretation might apply in a coding scenario where stated and assumed relationships must be considered:    Your patient has insulin dependent diabetes, hypertensive heart disease, end stage renal disease, and acute on chronic systolic and diastolic congestive heart failure. He goes to the dialysis center 3 times per week. Skilled nursing is ordered for CHF monitoring and teaching.How do you code this scenario when there are assumed and stated relationships between the diagnoses?Assumed Relationships:
You may assume a relationship between hypertension and chronic kidney disease. Per updated guidance from the Coding Clinic, you may also presume a cause-and- effect relationship between diabetes and CKD/ESRD unless the physician indicates another cause. If the patient has hypertensive heart disease, you must select a code for with or without heart failure.Stated Relationships:
As of right now, we may not assume a relationship between hypertension and heart disease. The physician must state the heart disease is due to hypertension or it may be implied (hypertensive).

Focus of Care:
The focus of care in this scenario is the exacerbated heart failure; however, this diagnosis cannot be coded first due to sequencing instructions.

Begin your search by looking in the index under hypertension. Notice that hypertensive heart disease with CKD is listed in the index under hypertension, cardiorenal disease.
From there you must choose between with heart failure or without heart failure. I13.2 is coded because the patient has heart failure and ESRD.
Next locate the code for diabetes with chronic kidney disease E11.22 which must also precede the end stage renal disease code per coding instructions.

The correct coding would be:
Hypertensive heart and chronic kidney disease with heart failure and with ESRD I13.2
Acute on chronic combined CHF I50.43
Diabetes with chronic kidney disease E11.22
End stage renal disease N18.6
Dialysis status Z99.2
Long term insulin use Z79.4

Note that if the focus of care had been diabetes rather than exacerbated heart failure, E11.22 would be listed first, followed by hypertensive heart disease, heart failure, and end stage renal disease.

Don’t get sidetracked by other codes

Editor’s note: Today’s post concludes our four-part series on common home health coding errors. If you’d like to receive more home health coding tips in your Inbox each week, sign up for our free email, The Monday Fix.

Seeing existing codes in a patient’s medical record can sometimes be distracting to home health coders, particularly novice coders who don’t yet feel confident in their own judgment. It’s tempting to look at the codes someone else has assigned, and use those codes as a starting point.

coding errors blog post art smaller 1But those codes can be misleading — especially if they were assigned prior to the patient’s admittance to home health, during treatment in an inpatient facility, where the coding rules may be different.

Home health coders need to be wary of any previously assigned codes encountered in the medical record, focusing instead on assigning new codes directly from the M.D.’s written notes.

Codes from skilled nursing facilities, wound care centers or clinics may have little bearing on the home health episode. Coding guidelines for those facilities can sometimes differ in important ways from coding guidelines for home health — and in some cases, codes from facilities may not be specific enough.

As an example, if a patient with Type 2 diabetes and peripheral neuropathy has been referred to home health, the skilled nursing facility where the patient was treated may have selected E11.9 (Type 2 diabetes without complications) as the code. If documentation from the M.D. during the patient’s hospital stay establishes that the patient has peripheral neuropathy due to diabetes, E.11.9 would not be the correct code. The coder would need to select E11.42.

Written notes from the M.D. supercede any code selected by any facility. Keep your eyes on those written notes, coding only from what has been documented there, and it becomes easier to avoid a coding error.

This was the fourth in a series of blog posts about common coding errors. Did you miss any of these other posts?

Click here to read about coding an uncertain diagnosis.

Click here to read about coding signs and symptoms.

Click here to read about coding previously treated conditions.

Do you need ICD-10 training or review?
Home Health Solutions can help you develop your home health coding skills, whether you are just starting out or an experienced coder needing CEUs.
Our Absolute Beginner course guides you through the basics of ICD-10, while our Absolute Auditor workshops for intermediate level coders offer training in both ICD-10 and OASIS.
HHS is excited to announce that the May 17-20 session of Absolute Auditor in Bessemer, AL, will be available via Live Stream as well.
To register, click here.
To read details about our classes, click here.

Are you a member of our growing community of coders who subscribe to The Monday Fix, a free weekly email delivering home health coding tips to your Inbox? Click here to sign up.


History revisited: To code or not to code?

Editor’s Note: Today’s post is the third in a four-part series on common home health coding errors. The series concludes tomorrow.

Do you know when to code a patient’s previously treated conditions or history?

In many cases, a previous condition which has already been treated and resolved is not relevant to the current home health care treatment and will not need to be coded.

coding errors blog post art smaller 1A diagnosis of pneumonia from three months ago, for example, clearly has no impact on a current home health episode unless there are complications which are being addressed now.

But it isn’t always easy for inexperienced coders to discern “over and done” from the current focus of treatment.

A recent Code & Coffee Quiz (a coding contest and giveaway Home Health Solutions runs on its Facebook page on Mondays) illustrates how easy it can be to run upon this particular “pothole” in home health coding.

Here’s a look at the challenge:

coding challenge art for blog post

 Some less experienced coders might have been inclined, at least initially, to code the gangrene in the scenario described above. Why? Because the amputation was necessitated by a gangrenous ulcer. 

But home health isn’t dealing with this patient for gangrene; the gangrene was resolved when the below-the-knee amputation occurred, and the operative site is documented as “healing nicely.” Home health was ordered for this patient for post surgical assessment and physical therapy for gait.

Home health coders must remain focused first on the reason(s) the patient has been referred to home health, and only on a patient’s previous health history in light of its impact on current treatment. With the gangrenous foot removed, gangrene is no longer impacting this patient’s treatment.   

Sometimes, history does matter  

Sometimes, current care is impacted by the patient’s history or family history. If the history has a bearing on current treatment, some Z codes, in particular History Codes Z80-87, may be used as secondary codes.

Smoking history is one example of a way in which a patient’s history becomes relevant to a current episode of care, and you will likely need to code Z87.89, a history of nicotine dependence, for former smokers.

Some diagnoses, including HTN, MI, CAD, COPD and others, require using an additional code for a patient’s smoking status, history or exposure.

“When reviewing a chart for diagnosis coding, it is important to check the patient’s social history to note if they are an active smoker, or have a history of smoking, or exposure to tobacco smoke, maybe from a spouse who smokes,” says Holly Kolitz, QA manager and one of the team leaders at HHS. 

“Occupational exposure to environmental tobacco smoke is important to record, too. They may have worked in a bar for many years, for example.”

Be sure to visit the HHS blog again Thursday for the fourth in this series of blog posts about common home health coding errors. The HHS team will conclude the series with a post explaining why it’s so important not to become sidetracked by other codes. Did you miss the previous blog posts in this series?
Click here to read advice on coding a vague or uncertain diagnosis.
Click here to read advice on when to code signs and symptoms.

Do you need ICD-10 training or review?
Home Health Solutions can help you develop your home health coding skills, whether you are just starting out or an experienced coder needing CEUs.
Our Absolute Beginner course guides you through the basics of ICD-10, while our Absolute Auditor workshops for intermediate level coders offer training in both ICD-10 and OASIS.
HHS is excited to announce that the May 17-20 session of Absolute Auditor in Bessemer, AL, will be available via Live Stream as well.
To register for our classes, click here.
To read details about our classes, click here.


Are you a member of our growing community of coders who subscribe to The Monday Fix, a free weekly email delivering home health coding tips to your Inbox? Click here to sign up.


When to code signs and symptoms

Editor’s Note: Our four-part series on common home health coding errors continues today, with a look at when home health coders should include codes for signs and symptoms. 

In general, the home health coding rule for signs and symptoms is simple enough:

     Don’t code them if they are integral to the disease or condition with which the patient has been diagnosed; do code them if they are not.

Icoding errors blog post art smaller 1f an asthma patient experiences wheezing, for example, it’s a routine symptom of asthma and should not be coded along with the asthma. If a patient with myocardial infarction experiences chest pain, a symptom routinely associated with MI, coding the MI is enough. Home health coders don’t usually code signs and symptoms, relying instead on confirmed diagnoses: first, the primary diagnosis which is the reason for the encounter, and next all co-existing conditions which have been documented.

     However, there are some limited circumstances under which it may be acceptable to code signs and symptoms. Here are two of them:

 1. There is no specific diagnosis in the medical record. Since you always code to the highest degree of certainty, and there is no certain diagnosis, it may be acceptable to code certain signs and symptoms in lieu of a diagnosis.

      An example might be a patient who has been experiencing shortness of breath and swelling to the lower extremities. The physician has added Lasix to the medication regiment but states that the patient “might have CHF.”

     “In this case, the coder cannot code ‘might haves,’ so the only option left is to code the edema and shortness of breath, as these would be the focus of the home health episode,” says Heather Calhoun, Director of Special Appeals and Project Management at HHS.

     “If a definitive diagnosis cannot be obtained when querying the M.D., or the M.D. will not verify the CHF, that is all the coder is left to do.”

2. If there IS a diagnosis in the medical record, but documented signs and symptoms are NOT integral to or associated with the confirmed diagnosis, it is acceptable to code them.

      An example might be a patient with a diagnosis of CHF who has been seen by the physician after the family reports episodes of “short term memory loss.” If the memory loss is not related to any diagnosis in the M.D. documentation, the home health coder would use “memory loss” as one of the co-morbid diagnoses.

      Note that the “memory loss” would be important to report because it impacts the patient’s ability to improve, and to implement certain interventions in meeting goals.

      Determining whether signs and symptoms are routine manifestations of a disease or condition can sometimes be tricky for coders, and may require researching a disease or condition for clarification.

       When in doubt, online coding forums can be great places to seek the opinions of more experienced coders who are usually happy to share their insight, especially if you query rarely.

       Please note that forum courtesy dictates limiting the number of questions posed, and the frequency of questioning. Keep in mind that other coders are working on their own files, too, and taking time away from their work to answer. Coders who routinely ask for forum assistance with numerous cases often find the number of replies dwindling.

Be sure to visit the HHS blog again on Wednesday, when we’ll review another common home health coding error, discussing when it is appropriate to code a patient’s history. If you missed Monday’s post, click here to read our advice for coding a vague or uncertain diagnosis.

Do you need ICD-10 training or review?
Home Health Solutions can help you develop your home health coding skills, whether you are just starting out or an experienced coder needing CEUs.
The May 17-20 session of Absolute Auditor in Bessemer, AL, a suburb of Birmingham, will offer intermediate level ICD-10 and OASIS review. The workshop will be available via Live Stream as well.
For details on our classes, click here.

Are you a member of our growing community of coders who subscribe to The Monday Fix, a free weekly email delivering home health coding tips to your Inbox? Click here to sign up.

avoid icd potholes 3


Four home health coding errors to avoid

avoid icd potholes 3
Even proficient home health coders sometimes find themselves skidding into ICD-10-CM “potholes,” caught unaware by confusing or misleading circumstances.

The risk can be even greater for beginning or less experienced coders.

The Home Health Solutions team has identified four common trouble spots for inexperienced home health coders. Think of them as ICD-10 “potholes” that novice coders will need to take care to avoid.

We’re reviewing these trouble spots all week long on the blog, in posts specifically designed to help home health coders navigate issues such as handling a vague or uncertain diagnosis from the physician when to code signs and symptoms, when to code conditions that have previously been treated, and how to avoid getting sidetracked by codes from facilities where a patient may have been treated.

Today’s post looks at the uncertain diagnosis, and what home health coders should do if they run up against the lack of a definitive diagnosis in documentation from the physician.

Never code an uncertain diagnosis

Vague, uncertain diagnoses are the unicorns of home health coding. Even if you’re a believer, your coding won’t stand up to scrutiny without “proof” in the form of a specific, documented diagnosis.

Any diagnosis documented as “probable,” “suspected,” “questionable,”  or as “a working diagnosis” is, like the fabled unicorn, still a myth for home health coding purposes, and should never be coded.

This is true even if the physician has prescribed medication almost always prescribed for a particular condition or disease, and even if the patient is experiencing multiple symptoms associated with a  particular disease or condition.

Until or unless the physician documents a definitive diagnosis, it cannot be coded.

For coders transitioning to home health from some forms of inpatient coding, where signs and symptoms are coded, this can be an important change.

In many cases, querying the physician can solve the problem and obtain the necessary documentation. Sometimes, however, a physician isn’t ready or willing to make a definitive call.

Without a specific diagnosis, how should the primary reason for home health care be coded? Guidelines  instruct coders to code “to the highest degree of certainty.”  This means that under circumstances, when there is no specific diagnosis, you may be able to code specific signs and symptoms, abnormal lab results or other problems necessitating home health care.

If a patient has been admitted to home health with physician’s orders to monitor or treat specific symptoms, those symptoms are the focus of care, and may be coded in lieu of a definitive diagnosis.

Remember, however, that this is not the preferred solution, that it is best to query first, and that documentation from the physician regarding signs and symptoms will be required to establish the focus of care. In general, it is always preferable to code a specific diagnosis.

(Our four-part blog series on common coding errors continues Tuesday, when the HHS team will review some of the specific circumstances under which home health coders may be able to code signs and symptoms — and when to avoid coding them.)

Do you need ICD-10 training or review?

Home Health Solutions can help you develop your home health coding skills, whether you are just starting out or an experienced coder needing CEUs.
Our next session of Absolute Auditor, a training workshop for intermediate coders, will take place May 12-20 in Bessemer, AL, and will be available via Live Stream as well.
For details on our classes, click here.

Are you a member of our growing community of coders who subscribe to The Monday Fix, a free weekly email delivering home health coding tips to your Inbox? Click here to sign up.


OASIS-C2: Why your comments matter

oasis c2 changes on the horizon 2Editor’s Note: This article appeared in the April 18 issue of The Monday Fix, our weekly email delivering home health coding tips and news of interest to home health coders.

Feeling comfortable with ICD-10-CM yet?
We thought not.
You’re not sweating alone, though.  Assimilating some 68,000 codes is a huge undertaking, and even the “industry experts” are finding glitches, contradictions and confusing spots within this massive code set.
At last count, some 2,564 changes to the ICD-10-CM classification set are expected to be implemented Oct. 1: at least 1900 new codes, 351 revised codes and 313 deleted codes.
monday fix promo 6A few Excludes Notes will shift and others will disappear completely in this first reworking of the code set since its implementation at the first of 2016. Home health coders are awaiting the changes with a mix of curiosity, anticipation and a bit of apprehension.
Meanwhile, slightly less attention has been paid to some other significant changes coming at the first of 2017, although these changes could have a substantial impact on home health agencies.
The Outcome and Assessment Set generally known by its acronym, OASIS, is undergoing its own revisions, with new items, renumbered items, and some other changes in how data is collected.


Why are these revisions so important to  home health care?

OASIS, implemented as part of the Improving Medicare Post-Acute Care Transformation Act generally known as IMPACT, has a huge impact on home health agencies in numerous areas.

The data from OASIS affects patient outcomes, STAR Ratings, reimbursement, and Value-Based Purchasing.

If an episode of home health care for a patient could be compared to a race to the finish line (quality outcome), collection of the OASIS data might be the pace car, going first to test track conditions, look for obstructions, set the pace and establish the positioning of all other cars.

“The data collection must be accurate and complete,” says Marti Holthus, a Quality Review Mentor on the Home Health Solutions team. “And it is so important, affecting so many aspects of home care, that the accuracy of clinicians completing the OASIS assessment has a direct bearing on the viability of an agency. ”

Proposed changes to OASIS for Jan. 1, 2017, are known as the OASIS-C2 data set. The Centers for Medicare and Medicaid Services has opened a public comment period to solicit input on OASIS-C2 from April 1 through May 31. In soliciting these comments, CMS hopes get a firmer idea about burden estimates from agencies affected. CMS is especially interested in suggestions for how to enhance the quality, utility and clarification of the information to be collected.


” Everyone in the home health industry who will be looking at, completing, educating on, etc., should read the update and comment,” says Kimberly Searcy, Director of Global Education at HHS. “There are changes in wording, numbering, new items,  and these may impact agencies.”

An agency may determine, for example, that revisions will require additional monies for training, that additional time may be required to complete the OASIS, or that  reimbursement to the agency and publicly reported outcomes may be affected.


Specific OASIS C2 revisions include:

– 3 new standardized items (M1028, M1060, GG0170c)

– Renumbering of items (M1311, M1313, M2001, M2003, M2005)

– Consolidating checkboxes from multiple check boxes to a single box for data entry

– Changes the look-back period

– Changes the numbering system used for pressure ulcer staging from a Roman to Arabic numerals


 Here is a link:!documentDetail;=CMS-2016-0047-001

 In the SEARCH box at the top of the page, type OASIS-C2 to go to the appropriate menu.  Look for the Comment Now button and follow the prompts.

Would you like to subscribe to our free weekly email delivering home health coding tips and news of interest to home health coders? Click here to read more about The Monday Fix.



Home Health Solutions LLC announces acquisition

Even More Solutions 2

Home Health Solutions LLC has made a strategic move forward with the acquisition of Transitions Health and Wellness Solutions, an Ohio-based firm serving hospice and home health agencies.

In an announcement made public today,  HHS owner and President J’non Griffin described the acquisition as “another exciting milestone” in a year of significant expansion for the company she founded in 2012.

“Our mission is to provide the extensive resources, guidance, services and support home health and hospice agencies need to navigate the complexities of today’s fluid and challenging home health care market,” J’non said.

“With this acquisition, HHS is even better positioned to partner with agencies seeking clinical, operational and financial excellence, and we extend a warm welcome to all the Transitions clients who will now join the many agencies HHS is already serving. We are poised for additional growth, and remain committed to stay abreast of the many challenges in our field and provide the expertise our clients need.”


Transitions Health and Wellness, founded in 2010, is a North Canton, OH, company providing consulting, coding, chart auditing, training and education materials to home health and hospice agencies.

Former owner Brandi Whitemyer is a well-known industry authority with more than 14 years of direct experience in home health and hospice, and is a frequent contributor to Decision Health’s Diagnosis Coding Pro and other industry materials.

She is currently the active Product Specialist and a full time subject matter expert with Decision Health Professional Services.  In this role she continues to  provide consulting to agencies nationally, as well as develop innovative new products and publications for the home health and hospice industry.


One of the most exciting aspects of the acquisition is its immediate impact on Home Health Solutions LLC’s on-line resource library.

“A priority goal for 2016 has been a major expansion of our resource library, with a focus on offering affordable, quality online courses for CEUs,” J’non said.

The acquisition of Transitions makes available additional training and education materials to supplement the signature CEU Suite  launched this year by HHS. With new coding courses and an array of programs targeting specific problems such as Face-to Face Encounter documentation, HHS is creating a go-to arsenal of training tools agencies can use to streamline their operations, address problems and shore up bottom lines.

“We have even more resources now to insulate agencies from the risk of non-compliance, and set them on track for higher quality performance and better patient outcomes,” J’non said.


J’non reiterated that there has never been a better time to partner with HHS.

“We’re really excited about our growth, and we welcome any other agencies looking to become part of our commitment to help agencies achieve and sustain quality and profitability,” she said. “Contact us, and let’s talk about what we can do for your agency.”



5 Essentials for Your Agency’s F2F Documentation

Can you list the 5 Must-Haves to insulate your home health agency against claims denials based on insufficient Face-to-Face Encounter (F2F) documentation?
Do you know how to incorporate missing elements of the F2F into the medical record?
If you blinked uncomfortably, you’re not alone. These questions are making many home health professionals nervous in the wake of voluminous claims denials after reviews under the Center for Medicare and Medicaid Services “Probe and Educate” Strategy.
Quality Checklist Infographic smaller f2f“It was mind-boggling to  learn early in 2016 that an astonishing 508 of 595 initial claims reviewed under ‘Probe and Educate’ had been denied, ” recalls Home Health Solutions LLC owner and president J’non Griffin.
Over the next few weeks, as reasons for the denials were publicized, it became clear that one of the biggest problem areas for home health agencies consisted of missing, invalid or incomplete documentation for Face-to-Face Encounters (F2Fs) between home health patients and physicians.


The F2F is mandatory for a patient’s home health certification. It ensures that all orders and certification for home health services are based on a physician’s current knowledge of the patient’s clinical condition. CMS requires that it occur within a specific time frame and address specific information about the patient.
Many agencies relying on forms to capture F2F information discovered that the forms they were previously using omitted details necessary under new CMS requirements.  Agencies also ran into trouble by relying on a physician’s verbal acknowledgement that the F2F had occurred, documenting the encounter and asking the physician to sign.
Some agencies did not understand the distinction between a certifying physician and the primary care physician. Others had not adequately established the patient’s homebound status in records submitted.
Correct procedures for F2F documentation require a brief statement by the certifying physician describing the patient’s clinical condition during the encounter, supporting the patient’s homebound status and the need for skilled services.
While it sounds straightforward, obtaining correct documentation from the physician, complete with required dates and signatures, all in a manner meeting CMS expectations, has proved to be an ongoing challenge for home health agencies.


If your agency is struggling with the nuances of F2F requirements, a small investment in training could pay off with major reduction in the risk of claims denials.
Home Health Solutions has just released a recorded training session in which HHS Director of Special Projects and Appeals Heather Calhoun breaks down each component, explaining in detail the five objectives of F2F requirements and specifically how agencies can meet each objective.  During the 90-minute presentation, she outlines three specific ways an agency can incorporate missing elements of the F2F into the medical record, makes clear the homebound status requirements which must be met, and establishes the difference between certifying and primary care physicians.
“You’ll love Heather’s down-to-earth approach to training,” J’non promises. “She has the hands-on experience needed for true peer-to-peer mentoring that goes an extra measure beyond the typical classroom approach.  She delivers all the information you need to understand F2F requirements, and she does it with a practical and engaging style that you’ll appreciate.”

Click here to check out the F2F training program now available  in the HHS Online Store.


The HHS  infographic below provides a quick checklist of the 5 essentials which must be in your agency’s F2F documentation.  Each is explained in detail in the HHS training program.

Quality Checklist Infographic F2F Take 5


It’s impossible to please everyone all the time,  and your home health care or hospice agency is no different from any other business with regard to complaints.

In the home health care field, however, the scrutiny accompanying complaints is intense and multi-faceted, involving a lengthy list of both state and federal oversight.  Your agency may be reported to your state licensing and certification division,  entities responsible for accreditation, the U.S. Office of the Inspector General, the Office of Civil Rights — and the list goes on.

Since 2006, the U.S. Justice Department has taken a particular interest in hospice agencies, suing more than a dozen for fraud and scrutinizing many more.

Stringent accountability really is the only safeguard your agency has under such intense scrutiny. Proactive measures will help ensure that your agency handles complaints and grievances in a way that meets not only the Conditions of Participation imposed by the Centers for Medicare and Medicaid Services,  but any unannounced,  on-site  investigations by authorized entities of review.


Agency accountability begins with a set of well-defined policies and procedures regarding complaints and grievances,  according to Home Health Solutions owner and author J’non Griffin.

“The agency must be able to demonstrate that it takes complaints seriously, documenting each in a standard format, responding in a respectful and timely manner, and thoroughly investigating the complaint within a reasonable amount of time,” J’non says.

While it is important to note that different states may have varying requirements and time limitations for how complaints are reported, some general guidelines apply to all.

Policies should be in writing,  clearly spelled out, and the agency should not depart in any way from the procedures it has set forth, J’non says. In her new e-book, “Survey Ahead: Navigating the Guidelines,” J’non explains that one of the crucial points to be evaluated during Survey is how well an agency complies with its own stated procedures for grievance and complaint resolution.

All employees — including new hires — should be familiar with the agency’s complaint process, knowing exactly how and to whom complaints should be reported at the agency.  Identifying this person, and the process to be followed, should be a prominent part of the agency’s written policy. Reviewing the procedures at least annually with staff members will help ensure compliance.

Staff education efforts must also ensure that employees recognize and respect a patient’s cultural, psycho-social , spiritual and personal values, as well as understand the need to show respect for the patient’s property.


Language barriers and cultural differences account for many of the complaints lodged against home health agencies,  and can often be resolved or prevented with proper education and training.

While showing respect for a patient’s expectations of timely visits is not a specific right under the law, it is worth noting that failure to adhere to scheduled visits in a punctual manner also ranks among the most common and easily preventable complaints lodged against home health and hospice agencies.

Some of the other most common complaints against home health and hospice agencies include:
– Lack of notification from the office if a visit must be rescheduled due to the illness/absence of the clinician scheduled to make the visit.
– Confusing communication due to multiple caregivers
-Inconsistent quality of care provided
The patient has the legal right to voice grievances regarding treatment or care that he or she receives (or fails to receive) and/or for lack of respect for property . Agencies must advise patients of these rights in writing and provide the patient with the phone number for the home health reporting hotline in that particular state, its hours of operation and purpose.

It is important to document all steps taken toward resolution of a complaint, even if the complaint cannot be resolved.

“Even if the complaint or grievance was not possible to solve, surveyors will want to see documentation showing the actions that were attempted to resolve it — and the outcomes,” J’non says.


Here’s a quick checklist of 8 points which should be clearly spelled out in your agency’s complaint procedures and policies:

  1. Who in your agency is accountable for receiving,  documenting and resolving complaints?
  2. What is the time frame for documenting/reporting a complaint?
  3. What is the time frame for investigating the complaint?
  4. Does your agency have an intake form for standardizing the information-gathering aspect of documentation?
  5. Does your agency have a standardized means of documenting attempts to resolve the complaint?
  6. How are your employees made aware of your agency’s procedures for handling complaints?
  7. How often are your agency’s procedures reviewed, updated and re-shared with employees?
  8. How does your agency handle any variation from its own written procedures when reporting or investigating a complaint? Are sanctions outlined and enforced? 

If you’d like to read more about the specific items which will be evaluated at your agency during Survey,  “Survey Ahead” is now available on Amazon.  Click here to take a look.