Category Archives: Home Health News

Home Health News

What LHC, Almost Family Merger Means for the Home Health Industry

A $2.4 billion merger between two powerhouses in the home health field is expected to create a new industry giant and set in motion significant long-term consequences for the home health field, according to Home Health Solutions Owner and President J’non Griffin.

In a deal set to close in 2018, Kentucky-based Almost Family, Inc., and Louisiana-based LHC Group, Inc, have announced their plans for an all-stock merger of equals, creating a company with a starting roster of more than 30,000 employees nationwide.

“This merger is a huge development, with the potential to shore up confidence in the future of home health, impact stocks and rejuvenate an industry feeling the weight of an increasing regulatory burden,” J’non said.

But she warns that the move could have some negative consequences – especially for smaller agencies.

“The new company created by this merger will be poised to set the professional tone and standards in the entire industry regarding delivery of well-coordinated, patient-centered care,” J’non said.

“Smaller agencies struggling to meet quality expectations may find it increasingly hard to compete in the evolving marketplace. Coupled with increasing regulations, the evolution of a faster-paced, coordination-intensive market with much bigger players could squeeze some smaller, struggling agencies into selling or going out of business,“ she added.

Expect more buyouts and partnerships

The merger between LHC and Almost Family reflects a dramatically shifting turf in the industry, as agencies increasingly look at strategic partnerships, joint ventures and other consolidation efforts to buffer the challenges presented by mounting regulatory burdens.

“Buyouts and partnerships are a growing trend,” J’non said. “We can expect to see increasing numbers as agencies work out innovative answers to the demands for quality outcomes, expedited turnarounds, increasing care coordination, and value-based reimbursement.”

So far this year, LHC Group had acquired more than 35 home health, hospice or community-based locations, as well as six long-term acute care hospital operations, before it announced plans for the merger with Almost Family.

2018: A ‘transformative’ year ahead

Next year is shaping up to be a transformative year in many ways for the home health field, according to J’non. In January, agencies will implement new Conditions of Participation set by the Centers for Medicare and Medicaid Services (CMS), requiring extensive operational, administrative and clinical changes.

“Meeting the demands of the new CoPs is expected to be a watershed moment for some agencies which have been struggling to stay afloat under the compliance burden, and simply may not be able to adapt quickly enough to the new round of regulations,” she said.

Does your agency
need CoPs training?
Click here to read about
J’non’s Dec. 16 seminar
in Vegas!

In addition to new CoPs requirements, agencies throughout the country are expected to be required to transition soon to the value-based reimbursement model already under demonstration in nine states.

Coming soon: Value-based purchasing

Officials at Almost Family and LHC have made no bones about positioning the giant company created by the merger to become the industry leader in value-based reimbursement.

Although a value-based purchasing model is only active in nine states right now, many home health experts believe CMS may have recently signaled its readiness to soon expand VBP to all other states.

“CMS did not really make many adjustments to the value-based purchasing in the 2018 Payment Rule, and the changes that were made were not really significant changes,” J’non said. “That may well indicate that CMS believes the model is ready for a full-scale release.”

The VBP model has largely been considered a success because the nine states participating in the demonstration have seen improvements in outcomes at a faster rate than states which were not included in the program, J’non said.

Home Health News

Will HHGM be delayed?

House bill would delay new payment model until 2020,
but agencies still have work to do. Here are 3 priorities.

It’s been a year of remarkable regulatory suspensions and delays for the home health industry – sometimes at the last minute  – and home health agencies are wondering whether another regulatory reprieve could be in the works.

A bill introduced late last week in the U.S. House of Representatives would postpone the costly and controversial overhaul of the Medicare payment system known as the Home Health Groupings Model (HHGM) which CMS proposes to implement in 2019.

Agencies would not see implementation of the proposed HHGM until 2020 under HR 3992, the bill introduced last Friday by Rep. Kristi Noem (R) of South Dakota.

“But it is important to note that the bill in its current form will not address expected losses of as much as $950 million in the first year of implementation due to reduced payments to home health agencies,” said J’non Griffin, owner and president of Home Health Solutions.

HR 3993, or the Rural Home Health Extension and Regulatory Relief Act, does not affect the proposed new 30-day payment episode in the HHGM or the shift away from a therapy-driven payment model to a new system which relies on clinical groupings, J’non said.

“Whether it is implemented in 2019 or a year later, under this proposed bill, the new payment system will still be a coding and OASIS driven payment model,” J’non said. “With that in mind, agencies can begin some important preparations.” She recommends that agencies take the following 3 steps to prepare:

  1. Focus on improved coding accuracy. 

The new HHGM relies heavily on primary diagnoses codes to classify each 30-day episode into one of six clinical groupings. Comorbidities, early or late timing of the episode, admission source and the patient’s cognitive and functional status are also integral to the new classification.

Under the new model, episodes which could not be grouped by primary diagnoses due to coding issues would be considered “questionable encounters” and returned to the provided for more accurate or definitive coding.

Whether agencies rely on in-house coders or outsource coding services, the quality of an agency’s coding will determine its viability under the HHGM, J’non said.

“Some agencies which may have been reluctant to outsource coding services are going to have to make that move, under the new HHGM, to ensure the level of accuracy needed for success, “she said. “And that decision is going to open up new areas of compliance risk, requiring agencies to look beyond cost to determine the credentials of the coders and quality of the services provided. It’s definitely a case of buyer beware in the coding world. If the price seems to be an exceptional bargain, smart agencies should wonder how and ask why.”

2. Provide thorough OASIS C-2 training to all team members.

As part of the HHGM case-mix adjustment, CMS proposes to assign points for each of the responses to certain OASIS functional items. The sum of those points would create a functional score for the period of care. Items to be scored are:

● M1800: Grooming.

● M1810: Current Ability to Dress Upper Body.

● M1820: Current Ability to Dress Lower Body.

● M1830: Bathing.

● M1840: Toilet Transferring.

● M1850: Transferring.

● M1860: Ambulation/Locomotion.

● M1032 (M1033 in OASIS-C1): Risk of Hospitalization.

“OASIS mistakes will be costly under the new HHGM,” J’non warns. “Agencies which may have been reluctant to invest in OASIS training in the past need to make that commitment now. It’s important to note, too, that just because clinicians have had training in the past doesn’t necessarily mean they’re up to speed. Guidance changes frequently in this field – and complete reversals are not unusual. Accuracy requires ongoing training.  Training does pay for itself, directly impacting an agency’s bottom line.”

3. Estimate the HHGM impact on your agency by using a CMS tool.

Determining how the HHGM will impact your agency is a crucial first step in developing plans to stabilize your bottom line. CMS has put together a grouping tool to help agencies understand how the proposed payment grouping parameters would impact payments.

To use it, your agency will need to input several months of data from patients under the current system and see how much of a difference the new payment model would make on payments received.

Click here to access the Excel file available on the CMS web site at http://go.cms.gov/2f12QpC.

Conditions of Participation, Home Health News

CMS announcement did not mention Emergency Preparedness Plans

 Good news, bad news

There’s good news in the home health field this week:

Yes, there is a possibility that the federal Center for Medicare and Medicaid Services will delay the implementation of revised Conditions of Participation, allowing home health agencies extra time to make the many clinical, organizational and administrative changes which will be required.

The bad news is that a possible delay doesn’t mean agencies can afford to wait to begin working on meeting the new requirements.

In fact, Home Health Solutions Owner and President J’non Griffin advises home health agencies to move forward with all changes as if there will be no change in the effective date established under current law.

The need to begin work now on the many changes required under CoPs is especially true for creating Emergency Preparedness Plans, which will likely be one of the more labor-intensive and intimidating new requirements for agencies, J’non said.

Conditions of Participation will require home health agencies to have in place a detailed Emergency Preparedness Plan including hazard risk assessments for their specific communities, communication plans for any natural or man-made disaster and many other specific components.

Under the Final Rule approved in January, agencies have until November 2017 to put together this complex Emergency Preparation Plan, and have in place measures for conducting community-coordinated disaster drills to practice how they would handle their patients and work with other facilities during an actual emergency situation. In addition, the agency’s emergency preparedness program will need to include individual plans for its patients.

Last week’s announcement by CMS that it will consider a delayed start date for CoPs, pushing the current effective date from July 13 2017 to January 13 2018 made no mention of a new time frame for the Emergency Preparedness Plan requirement.

Until otherwise notified, agencies must assume that the November  2017 deadline stands, according to Home Health Solutions LLC Owner and President J’non Griffin.

There is no guarantee that CMS will approve any delays, despite last week’s announcement, and agencies could be risking non-compliance if they do not move forward with changes, J’non said.
“CMS has opened a 60-day public comment period to solicit information it will use in making the determination about whether to delay the start date for CoPs,” J’non said. “But it is important to remember that if the start date is not delayed at the end of the 60-day period, agencies which have not begun to make the necessary changes will not have enough time to do so by July 13.”

Need help with your Emergency Plan?

A complete Emergency Preparedness Plan Assembly Kit is one of the resources and products Home Health Solutions has created to help agencies meet the new CoPs.

The Assembly Kit and other products are featured in our new CoPs Success Catalog.  Click here to see the catalog now.

Other helpful products:
   – A complete video library overviewing new CoPs
  –  A 4-Volume Reference Guide
   – Tutorials for Home Health Aides on new requirements
   – An innovative new Patient Orientation Package which is customized for your agency 
   – Complete, done-for-you policy manuals

  You’ll find all the tools you need to meet the new CoPs in our catalog. And with our CoPs Success Bundle, you can buy EVERYTHING you need for success at one great price, without having to spend the time to pick and choose. We’ve done all the work for you! 
Home health agencies, Home Health News, Pre-claim reviews

What’s next for home health? Experts at conference admit they’re baffled

In a week of intense debate in the nation’s capital over efforts to repeal and replace Obamacare, the future of myriad home health regulations remains as uncertain as other health care issues. 

But one thing IS certain, according to Home Health Care Solutions owner J’non Griffin, who joined other home health experts at the 2017 Illinois Home Care and Hospice Conference & Exhibition near Chicago this week. Whether lawmakers change, repeal or leave in place existing Medicare requirements, agencies must continue to streamline their processes and focus on quality improvements to remain profitable in the increasingly challenging home health  field. 

Agencies in Florida hoping for a reprieve from an April 1 rollout of pre-claim reviews by the Centers for Medicare and Medicaid Services are likely to be disappointed, according to keynote speaker William Dombi, who serves as The National Home Care Association’s Vice-President  for Law. 

The eyes of the nation remain fixed on the D.C. debate over replacing the Affordable Health Care Act with an as-yet-unnamed plan which has been alternately dubbed Trumpcare,  Ryancare and Obamacare Lite. How the proposed replacement would impact home health has not yet been determined.

Meanwhile, the clock ticks inexorably toward the April 1 deadline in Florida, leaving little time or attention for NACH’s efforts to derail PCRs.

“The Washington perspective is that we are all crazy at this time. No one knows at all,” Dombi told hundreds of home health professionals attending the Illinois conference. “My concern is that day after day, hope of something in Florida diminishes.” 

NAHC has prioritized stopping the PCR process in additional states, including Florida, and curtailing the process in Illinois, which became the first state to undergo a PCR demonstration in August, 2016. Dombi said NACH is petitioning CMS to allow agencies which have had consistently high affirmation rates to opt out of the PCR process without being penalized financially. 

But NAHC’s efforts to get lawmakers to support the repeal of PCRs have been largely overshadowed by the bigger repeal efforts on Capitol Hill, and the political fallout. Republican lawmakers unveiled the replacement health care act promised by the Trump administration this week to major discord in Washington D.C., with condemnation from Democrats, the American Medical Association, the American Hospital Association, and even some Republicans. 

What will happen next is anyone’s guess, Dombi told conference attendees. He describes the situation as “very chaotic.” 

As federal lawmakers grapple with complex issues such as the extent of individual rights to health care, whether responsibility for health care is a federal or state priority and whether the role of the government in health care should be as partner or provider,  Dombi sees some areas of hope on the horizon for home health. 

The new administration’s Secretary of  Health and Human Services, Tom Price, has a sound grasp of many home health concerns and a history of support for many of them, Dombi said. 

Price has indicated some support for delaying new Conditions of Participation for Medicare which are scheduled to become effective July 13, Dombi said.  The new CoPs will require many operational changes for home health agencies, and there is some concern within the industry that there is not enough time for agencies to fully implement all the changes.

With no interpretive guidelines released four months away from the implementation,  NAHC believes surveyors aren’t ready for new CoPs and has been lobbying for a delay. Word in D.C. is that Price is “seriously considering” NAHC’s position, according  to Dombi.

However, it is important to note that no delays of PCRs or CoPs have been approved at this time. Industry experts at the Illinois conference strongly encouraged agencies to proceed as if new Conditions of Participation, Pre-Claim Reviews and Value Based Purchasing initiatives (in which agencies are rewarded or penalized depending on how well they make improvements) are inevitable. 

No one knows if or when or where CMS will expand Value-Based Initiatives beyond the nine states in the current trial, whether PCRs will proceed to other states after the Florida rollout, or exactly what will happen next in home health, but agencies must be prepared anyway, PPS Plus educator Jennifer Warfield told her conference audience.

“Even if the actual term Value Based Purchasing goes away, the future of your agency is always going to be tied to its improvement processes,” she said. 

Joyce Ryan Boin with Strategic Health Care  Solutions encouraged agencies to redirect their focus toward education and ongoing strategy for measurable improvement. 

“We’re not in Kanas any more,” she said. 

 EDITOR’S NOTE:  Check out HHS Owner J’non Griffin’s four-part webinar series on the new Conditions of Participation, providing an overview and highlighting compliance strategies for agencies to develop a QAPI program. The series begins March 15 at 10:30 a.m. CT, and will continue March 29, April 11 and April 25. 
For details or to register, click here.

 

 

 

home health documentation, Home Health News

The value of a Mock Audit: Why home health agencies need to do this


It may be the season for goblins and gremlins, but in an era of unprecedented regulatory scrutiny for the home health field, it’s the glitches home health agencies really need to worry about.
solutions-october-main-artErrors, oversights, and inconsistencies are the hobgoblins of the home health industry, carrying high price tags in the form of claims denials – or, even more frightening, fraud investigations and hefty fines.
And, to frame things in the spirit of the season, the  scary shadow of scrutiny is looming larger.
The future of home health is filled with quality improvement requirements that have not yet been fully determined to be either tricks or treats, but home health professionals know they’re coming, sooner or later. From value-based purchasing to pre-claim reviews and a proposed new Condition of Participation for Medicare, agencies are feeling the squeeze to reduce errors and improve performance.
There’s pressure to become faster as well as better. While the Centers for Medicare and Medicaid Services has temporarily delayed rollouts of pre-claim reviews to give agencies more time to prepare, home health experts agree, by and large, that the eventual implementation will force agencies to speed up as well as fine-tune their processes.

Let’s go glitch hunting

This season, Home Health Solutions owner and president J’non Griffin recommends agencies who are serious about success take a broom, figuratively speaking, to the cobwebs and shine a light into every dark nook and cranny, to ferret out the vulnerabilities in the operation and take corrective action.
“Smart agencies are doing everything they can right now to mitigate risk,” J’non says. “They’re honing in on the quality of their documentation, reviewing clinical notes made by nurses and therapists, prioritizing internal audits and quality reviews, and following up with extra training measures to address any shortfalls.”
Done well, self-assessment takes extra time, and for an agency already struggling under clinical and operational demands, creating the time for self-evaluation can seem like an overwhelming task. It’s hard to remain objective and easy to overlook crucial details that surveyors won’t miss.
Many agencies are finding the solution is to rely on outside firms to provide the thorough and objective assessment needed to identify compliance risks and provide a plan of remedy.

What does a Mock Audit entail?

From identifying expired items in an agency’s supply closet to revealing inaccuracies in its personnel files, a Mock Audit can be a comprehensive tool for determining exactly where an agency is headed for trouble.
It’s conducted exactly as surveyors would conduct the real thing; once scheduled, there’s no advance notice given to staff.
A team spends 1-3 days on site, depending on the size of the agency being audited, with some team members remaining in the office to audit charts and personnel files while other team members conduct home visits in all disciplines.
An exit interview concludes the process, and the findings are shared with the administrator along with recommendations for improvement so that a plan of correction may be implemented. Education tailored to address specific deficiencies can be arranged.
“A Mock Audit gives the agency staff an opportunity to practice for the real thing so that they will have an idea of the survey process, whether it be state Survey or advanced accreditation,” says Heather Calhoun, Director of Special Appeals and Project Management at HHS.
She recommends agencies schedule an annual Mock Audit to help control compliance risks.
“There’s no better way for an agency to determine areas of weakness and potential risk,” Heather says.
Jason Lewallen, Director of Sales and Marketing at HHS, agrees.
“With the rapid pace of regulatory change, agencies face an uphill battle when preparing for a survey,” Jason says. “This industry is fortunate that there are programs in place that can minimize the risk of penalty before the surveyor arrives.”
Findings can result in financial gain to agencies, because audits often identify specific areas of improper documentation that result in claims denials.
“Mock Audits offer agencies the opportunity to fix errors before the organization is negatively affected by claims denials as well as accreditation or state Survey,” Jason says.
The cost of the audit, like its duration, depends on the size of the agency and a few other variables.  Give HHS a call today to discuss how a Mock Audit can help shore up your operation, and put your agency on the road to success this fall.
   

Documentation, Home Health News, Pre-claim reviews

CMS suspends pre-claim review rollout in Florida

pcr-rollout-delayed
“Whew!”
That’s the word of the day for home health agencies in Florida, where there is industry-wide relief in the wake of a last-minute decision by the Centers for Medicare and Medicaid Services to suspend a pre-claim reviews rollout.
The rollout was set to begin Oct. 1,  but home health industry advocates and state lawmakers have lobbied hard to postpone the program, saying agencies are not prepared to meet the extra burden of preparing and submitting pre-claims.
Opponents pointed to a disastrous six weeks of initial efforts in Illinois, the first state to be included in the pre-claim demonstration, where very few pre-claims were approved on first submission.
The Home Care Association of Florida  was among the industry advocacy groups cautioning that patients needing home care were at risk as agencies scrambled to meet the pre-claims review burden. HCAF officials expressed relief Monday over the decision by CMS to grant agencies additional time.
No new timeline has been provided for the PCR demonstration in Florida or in other states which were previously scheduled to become part of the PCR demonstration over the next few months. Texas, Michigan and Massachusetts were on track to become part of the demonstration by Jan. 1.
CMS has indicated it will provide a 30-day notice before resuming the demonstration.  The demonstration already underway in Illinois is not included in the suspension, and will continue.
   In making the announcement, CMS acknowledged that problems experienced during the initial rollout in Illinois showed additional education will be needed before the demonstration can proceed.

Illinois non-affirmations

In Illinois, the demonstration that rolled out Aug. 1 has been marked by widespread non-affirmations, with an estimated 80 percent of first submissions failing to meet approval.
A large number of non-affirmations were based on the failure of agencies in Illinois to establish homebound status of the patient and medical necessity for home health services.
The National Association of Home Care and Hospice has fought the PCR demonstration, citing numerous problems with electronic submissions. NAHC’s Vice President for Law Bill Dombi called it “a complete mess.”

Use the reprieve to get prepared

“This delay gives home health agencies some much-needed time to better prepare for the pre-claims review demonstration,” says J’non Griffin, owner and president of Home Health Solutions LLC.
“But it is important to note that the process has only been postponed, and not canceled, so agencies will still need to prepare.”

Not sure where to start?

Home Health Solutions has a great DIY Kit to get your agency started, and it’s priced at just $25. Give us a call at 888-418-6970.
Many agencies are also considering outsourcing the preparation and submission of PCRs. Home Health Solutions is working with agencies who need PCR assistance, and will be glad to speak to you about how we can help your agency.

 

Documentation, Home Health News, Pre-claim reviews

How home health agencies can meet the pre-claim reviews burden

preclaims-reviews-2
Do you know the two primary risk areas?
Here’s a look at what’s being rejected —
and four things agencies need to do

This article first appeared in the September issue of SOLUTIONS,  a monthly e-newsletter from Home Health Solutions LLC.  If you’d like to receive our free newsletter,  click here to subscribe. 

Six weeks into the first Medicare pre-claim review demonstration in Illinois, the rest of the home health field is watching, hawk-like, to assess the damage and determine industry-wide risk.
Uneasy curiosity hinges on three questions:
What’s being denied? How bad is it? How can agencies insulate themselves?
“As a whole, it’s not going well,” reports J’non Griffin, owner and president of Home Health Solutions LLC.
“One agency has reported getting no non-affirmations — and they say they are uploading 80 to 100 different pages to justify the care for each claim.
“The last figure I saw, though, was about an 80 percent non-affirmation rate overall on the first submission.”
J’non’s assessment is backed up by the National Association of Home Care and Hospice. Bill Dombi, NAHC’s Vice President for Law, has called the pre-claim demonstration in Illinois “a complete mess.”
Agencies have reported individual claims taking up to an hour each to submit.
Some say they are unable to stop and save partially uploaded submissions once the uploading process has begun.
Several agencies say they have repeatedly been told their submissions are illegible. Many say their documents were lost during transmission.
The number of disappearing documents prompted CMS at one point to advise agencies to rely on fax submissions rather than electronic.

What’s ahead?

Currently, NAHC is lobbying Congress to suspend the next rollouts planned in Florida, Texas, Michigan and Massachusetts between now and the first of the year. Florida legislators are taking the lead in the opposition, since Florida is next in line with an Oct. 1 rollout.
But the clock is ticking, and despite overwhelmingly negative reports from home health agencies in Illinois, attempts by lawmakers there to suspend the process, and current efforts of Florida lawmakers to delay the next round, it seems likely for now that the pre-claim demonstration will move forward.
How can agencies prepare?
“To successfully meet the new burden of pre-claim reviews, home health agencies need to get much faster, with fewer documentation errors and oversights, expedited turnarounds, and a thorough understanding of exactly what is expected of them,” J’non says.

(For more information about how agencies can successfully handle PCRs,  be sure to check out the detailed recommendations in J’non’s “4-Point Roadmap for PCR Success,“  below. )

Is your agency ready?

Industry experts agree that agencies will almost certainly be forced to hire additional full-time employees to meet the burden of pre-claim reviews. Generally, they estimate that for every 100 to 350 patients an agency serves, an additional one-and-a-half FTEs (one RN and one clerical) could be required.
For many agencies, however, a faster and more cost-effective solution may be to outsource the preparation and submission of pre-claim reviews. Home Health Solutions is now working with agencies needing assistance with PCRs.
“Agencies are discovering, as the requirements placed upon them increase, that it often makes more sense financially to outsource coding, billing and many other services so that they can focus on patient care,” J’non says.

Going it alone?

For agencies choosing to navigate the PCR process on their own, J’non recommends purchasing a helpful tool from Home Health Solutions. Think of the PCR Do-It-Yourself Kit as a $25 compass to point your agency in the right direction to steer through all the necessary paperwork.  A checklist and staff tutorial are included.
To order,  call HHS at 888-418-6970.

Roadmap for PCR success

map-4

J’non also offers the detailed 4-Point Roadmap below to help agencies successfully prepare for the pre-claim review process:

Step 1: EXPEDITE WORK FLOW 
Agencies must streamline their operations, with faster turnaround times for coding, for developing a Plan of Care and getting the physician to sign off on it, and for collecting all documents needed to submit the pre-claim review.
Efficient teamwork will be an essential part of streamlining operations, J’non says.
She recommends agencies:

  • Identify key staffers and their responsibilities, and make certain there is no confusion about who is responsible for each step in the process of completing documents and collecting necessary forms to submit and re-submit claims.
  • Develop a back-up system to avoid delays in the event a key staffer becomes unavailable.
  • Determine who will be responsible for follow-up, and how often.
  • Make certain the person submitting pre-claims has immediate access to all required documentation and billing information.
  • Review the process with the full staff, stressing the need for timeliness and accuracy. Put policies and procedures in writing for easy access to avoid confusion or delays.

 

Step 2. TARGET TWO AREAS MOST LIKELY TO BE REJECTED
Agencies in Illinois are reporting that a high proportion of pre-claim reviews are being rejected on the basis that the patient is not homebound or the care is not shown to be medically necessary.
J’non recommends agencies look closely at their supporting documentation to make certain they have correctly established both patient eligibility and medical necessity.
A few reminders about documenting homebound status:

  • To be considered homebound, the patient must be unable, due to illness or injury, to leave home without special equipment or assistance from another person. Be sure to document WHY the illness or injury requires special equipment or assistance.
  • Document the impact on the patient from any excursion outside the home, the reason for the trip, and the effort required to leave home.
  • Make certain Face-to-Face documentation specifies why the patient is homebound. The physician’s note must specifically address the reason the patient needs home health services.

 

Step 3:  CLEAN UP DOCUMENTATION
Review, review, review. Agencies can’t do too many in-house reviews and self-evaluations as they attempt to shore up compliance risks, limit oversights and reduce errors.
In particular, J’non recommends agencies focus on:

  • Accurate completion of the OASIS, especially in preparation for C-2 revisions which take place Jan. 1. This data collection tool offers numerous areas where clinicians can become confused. The HHS team frequently sees agencies making mistakes as simple as entering dates in the wrong place on this form, erroneously establishing non-compliance.
  • Proper documentation of Face-to-Face Encounters. Make sure the physician has documented the date of the F2F Encounter and provided the reason home care is necessary. A clinical note from the physician will be required, not just a form, and the content of the note must address the reason the patient needs home health care.The signature of a nurse-practicioner or other provider on the F2F will not suffice unless it is a co-signature with the physician. Even if the nurse-practitioner performed the F2F, the certifying physician’s signature and date will be necessary. Review all F2F dates to make certain there are no discrepancies. Mismatched dates are automatically denied.
  • Collect all necessary information before submitting pre-claims
  • Attach the assigned pre-claim number to all final claims and resubmissions.
  • For re-certifications, be aware that the re-certification statement on the projected length of time the patient will need home care will need to be submitted separately from the Plan of Care.
  • Also note that the projected length of care will shorten each time the patient is re-certified unless there is a documented reason showing why that is not the case. In a recent workshop on pre-claims reviews, Palmetto representatives stated that the re-certification statement is expected reflect a shorter duration for each episode of home health care for which the patient is re-certified. The first re-certification projection, for example, might be six months, but the next re-certification projection would be only four months. Be sure to include supporting documentation showing the need for any change in the projected length of stay.

 

Step 4: INVEST IN TRAINING
Agencies will need to shore up training in many areas in order to reduce compliance risks and achieve success in today’s challenging home health market, J’non says. In particular, she recommend OASIS training and F2F review to prepare agencies to better handle pre-claims reviews.
HHS offers online training for both in its online store, with 8 CEUs offered for the OASIS course.
Click here to shop the online store now.

Home Health News

Home health agencies brace for next 6 months

1 Comment

Main art July SolutionsWith six months of adjustment to the 68,000 new health codes known collectively as ICD-10-CM now under its belt, the home health industry is buckling up for Round 2: six more months of new codes to assimilate, code revisions to integrate and new pre-claim reviews to handle.

More than 2,500 changes to the ICD-10-CM classification set are expected to be implemented Oct. 1: at least 1900 new codes, some 350 revised codes and more than 300 deleted codes.  The Tabular List will change, some Excludes Notes will shift and others will disappear completely in this first reworking of the code set since its implementation at the first of this year.

While home health adapts to this newest version of the new classification set, agencies in at least 5 states will also grapple with rollouts of new pre-claim reviews changing the way they process claims for services.  The Centers for Medicare and Medicaid Services (CMS) will require agencies in the affected states to secure prior authorization before processing claims.

Home health agencies in other states, expecting to soon be under the same requirement,  will pay close attention to next month’s initial rollout in Illinois, as well as similar implementations in Florida on Oct. 1, Texas on Dec. 1, and both Michigan and Massachusetts on Jan. 1.

Don’t even think about muttering a “whew” under your breath — at least not yet. There won’t be any rest for the weary at the end of these next six months.

In fact, what’s in store next could possibly have one of the largest impacts yet on home health.

THE IMPACT OF OASIS C-2

It’s hard to overestimate the importance of the Outcome and Assessment Information Set, the CMS data collection tool known by the acronym OASIS, to a home health agency’s operation. This intake of information can affect patient outcomes, reimbursement, STAR ratings, Value Based Purchasing and an agency’s bottom line.

And it’s about to become even more important.

The revised version known as OASIS C-2 becomes effective on Jan. 1, 2017, ratcheting things up a few notches with the implementation of the first quality measures from the Impact Act of 2014. This Act establishes some standardized measures for easier reporting and sharing of data between skilled nursing facilities, long-term care hospitals, inpatient rehabilitation facilities and home health.  The goal is to facilitate coordinated care and improve patient outcomes, providing better post-acute care for Medicare beneficiaries.

Some OASIS C-2 items, for example, are designed to help capture standardized reports of skin integrity, a patient’s functional status and cognitive function, medication reconciliation, incidence of major falls, transfer of health information and care preferences during a patient’s transition from one facility to another.

“As integral as OASIS has become to the success of home health agencies, it is only going to become more crucial in the future,” says J’non Griffin, owner of Home Health Solutions LLC.  “Moving forward with the Impact Act initiatives in a value based environment, inaccuracy in OASIS reporting will cost agencies not only valuable dollars but also referrals. Providers will only want to partner with agencies that have excellent outcomes.”

In the five states selected for pre-claim review, OASIS C-2 will be one of a triad of components integral to set up patient eligibility and establish medical necessity.  OASIS C-2 data will be used along with the patient’s comprehensive assessment and supporting documentation from the care provider to demonstrate why home health is necessary and support the pre- claim.

Home Health Solutions is offering assistance to agencies in the five initial states for reviewing and submitting those claims, and will expand the services to other states as needed. One of the first efforts the  HHS team undertakes when working with agencies on their pre-claim reviews  is stressing the importance of accurate OASIS completion.

Successful home health agencies, according to J’non, will be those who understand how crucial it is to collect OASIS information accurately, maintain effective and ongoing staff training and review to ensure continuity and efficient adaptation to changes, and develop a reliable system to bridge potential glitches such as those caused during periods of staff turnover.

Every employee needs training, every employee’s understanding of the material needs to be reviewed and every employee’s training needs to be updated regularly in order to maintain quality expectations.

“Because of the complexity and the frequency of changes not only in regulations but in the caregiver turnover in agencies, OASIS training is a continual education process,” J’non says. “Success can’t be achieved with a ‘one-and-done’ type training with clinicians.”

A LOOK AT C-2 CHANGES

The new version of OASIS will add several new items, including a GG-Functional section, and modify how some items are worded or numbered. Five items are revised and clarification is provided with regard to many of the questions submitted to the OASIS Help Desk.  “In addition, there are some major wound guideline changes that could mean a significant decrease in case mix points,” J’non says.

Perhaps the most surprising change for many clinicians has been a startling change in how pressure ulcers are to be reported under OASIS C-2, but there are numerous other changes that will require clinicians to undergo a thorough training session in order to best adapt, J’non says.

She is putting the finishing touches on an all new online training session for OASIS C-2 which, while not yet available for purchase at the time of this post, is expected to be uploaded to the Home Health Solutions LLC Online Store within the next week to 10 days.

Browse all the products on our  online store at:
The HHS Online Store

Documentation, home health coding, Home Health News

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.

A LOOK AT WHAT’S AHEAD

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.

YOUR SUMMER TO-DO LIST
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

 

 

 

Home Health News

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.”

ABOUT TRANSITIONS

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.

NEW RESOURCES

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.

PARTNERING WITH HHS

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.”