Tag Archives: Home health agencies

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.

 

5 ways we can help home health coders

coders need community
Are you a home health coder interested in keeping up with frequent changes to the ICD-10 classification set, and how it’s interpreted? If so, you need a regular source of information to keep you updated.

Maybe you’re new to home health coding, in need of free practice scenarios and study material and eager to sharpen your coding skills as you prepare for your home health exam.

Either way, you need a supportive community of coders to help you navigate the complexities of the field you’ve chosen — and Home Health Solutions LLC has the solutions you need.

Here are five ways we’re in the trenches with you, helping you master all the challenges of the home health coding profession:

 1. Free coding and OASIS tips on Mondays

newsletter 2Our free weekly e-newsletter is filled with coding and OASIS tips as well as other news of interest in the rapidly-evolving home health field. We know you’re busy, so we deliver it straight to your Inbox every Monday.
Recently, we’ve featured an update on new guidance regarding the link between HTN and heart or kidney involvement, a look at a common OASIS error regarding the entry of dates, and a refresher on THE MONDAY FIX 7the use of the 7th character in wounds coding.
We’re working now on a series of helpful tips on fractures coding and more common OASIS errors.

   If you haven’t subscribed, click here to add your name to our list and you’ll begin receiving this helpful free e-newsletter next Monday. It’s a great time to subscribe, as we’ll soon begin highlighting some of the changes to the ICD-10  classification set that will become effective Oct. 1.

 Our web site has some treasures

     Are you looking at the Home Health Solutions web site regularly to discover all the helpful info we post there?
coding errors blog post art smaller 1
Check out the PRACTICE CODING QUIZ  we’ve just posted. It features 6 trauma wounds cases and invites you to choose the correct code, assigning A or D as the 7th Character. New home health coders  — or those who like to review from time to time — will also discover useful blog posts on topics such as “Four Common ICD-10 Potholes and How To Avoid Them.”

Did you know that we keep a CODING TIPS ARCHIVE on our web site, where some of the coding tips from our weekly e-newsletters are featured in case you missed them?
Heart Translation GuideIf you like visual aids, be sure to click here to check out our helpful infographics, such as the one pictured at left. These graphics are designed to pack helpful information into a visual form, and can be printed out for you to keep with other useful tips.
   Your agency may benefit from “Think Like an Auditor,” our free report on the Top 25 Documentation Errors the HHS Team encounters when working with home health agencies, or by taking THE HHS SECURITY QUIZ, a 5-minute tool designed to help you target areas where you may be out of compliance. The Security Quiz highlights many items which will be noted during Survey.
And, speaking of Survey, did you miss our blog post on an often-overlooked but important area: “How Does Your Agency Handle Complaints?” It offers a helpful list to help your agency shore up the way complaints are documented and addressed.  Be sure to share the links to these items with the appropriate person in your agency.

3. Our Code & Coffee Quiz on Facebook

barbershop quartet art 2Whether you’re a veteran or a novice at home health coding, we have a great educational tool for you every Monday on the Home Health Solutions Facebook page.
Our Code & Coffee Quiz posts a home health scenario with multiple-choice coding sequences, inviting coders to tell us in the comments which sequence they like best and why. One of them is rewarded (in a random drawing) with a $10 e-card to Starbucks — but everyone’s a winner on this weekly quiz, because of the learning opportunities it provides.
   Recent scenarios have featured great examples of new coding guidance on presumed relationships and examples of diagnoses that require a step beyond — and then two more beyond that — with regard to specificity.

The Quiz is pinned to the top of our Facebook page each Monday. Click here to check it out.  (While you’re there, scroll down on the Facebook page to review some quizzes from previous weeks.)

Here are just a few of the reasons you should be joining us every Monday for the Code & Coffee Quiz:

  • You’re a new home health coder who needs the practice every week,
  • You’re an established home health coder who wants to see practical examples of new coding guidance in use
  • You’d like to win a $10 e-card to Starbucks
  • You recognize the value of a weekly forum where coders can discuss scenarios with the rationale provided, learning from each other


 4. Our
Online Store has products you need

    We know you need CEUs and training to stay abreast of constant change in the home health field, so we’re constantly working on new online training programs for you.
When
Home Health Solutions owner J’non Griffin isn’t on the road to teach a workshop or take the stage as a featured speaker for an industry event, she’s recording online training classes. She just finished an OASIS C-2 update, designed to address revisions which will become effective Jan. 1. It’s worth 8 CEUs. Check it out in the HHS Online Store.

   While you’re there, browse around a bit — and be sure to take a look at our Absolute Auditor classes. These classes are offered both online and in person.

 5. Get connected to stay in the loop

     At HHS, we’re committed to helping home health coders and home health agencies achieve excellence. After you check out the blog posts, classes, newsletters and tools mentioned here, check back soon to see what other helpful information we’ve assembled for you.
A great way to stay in the loop is to “like” us on Facebook so that our posts will appear in your Newsfeed. There’s a “like” box on the bottom right side of this post, to make it easier.

   You can also follow us on Twitter at:

@hmhealthsolutions

 

    

Do your OASIS scores add up to what’s really going on?

OASIS Scores Add UpEditor’s note: This article originally appeared in the July 25 issue of The Monday Fix, a free weekly email from Home Health Solutions featuring home health coding and OASIS tips.  Click here to subscribe.

In the complex world of home health, where boundaries and guideposts are almost constantly revised and re-interpreted, an agency’s success may well revolve around one crucial skill: the ability to accurately use the data collection tool known as OASIS.
The Outcome and Assessment Information Set (OASIS) is emerging as a critical performance measure for the field in general and for individual agencies.
“It’s hard to overestimate the importance of this data set,” says J’non Griffin, owner of Home Health Solutions LLC. The OASIS affects patient outcomes, reimbursement, STAR ratings, Value Based Purchasing and an agency’s bottom line.
And that’s just in its existing form.
Come Jan. 1, OASIS will ratchet things up a notch. The Centers for Medicare and Medicaid Services (CMS) implements a revised version of OASIS on the first day of 2017, and the new version known as OASIS C-2 will feature the first quality measures from the Impact Act of 2014.
This Act established 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.
Among other data, C-2 items will 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.
This is important information for the home health field, J’non says.      “The overall goal is to collect data necessary to create a vital picture of what’s actually going on in home health care,” she says.
Agencies are tasked with the same goal on an individual level as they complete the OASIS for each patient. But that goal can easily be hindered by hurrying through the process, looking at it as simply additional forms to be filled out, or – perhaps most damaging — limiting its scope by failing to understand the nature and reach of the information it seeks to collect.

The big picture from the details

Accuracy in reporting is requisite for proper use of OASIS to collect necessary information, yet many clinicians struggle to correctly capture  the information.
It’s quicker and easier to create a superficial account, relying on a cursory overview or a patient’s information alone.  But that can be misleading, and J’non believes agencies must train their clinicians to look at how all the information about a patient works together to create a cohesive report.
In some cases, clinicians must look beyond the narrow focus of the question at hand to consider other circumstances which may affect the answer, and carefully weigh what a patient tells them against the realities of a diagnosis by the physician, risk assessments, environmental evidence and more.
Sheena Meeker, a quality review mentor on the HHS team, offers the following example of how it may be necessary to carefully consider all aspects of a patient’s circumstances to make sure OASIS scores add up to a true reflection of what is going on.

EXAMPLE:
Your patient is a 92-year-old male who lives alone in a single-story family home. His daughter assists with some errands, and occasionally meals at home. When you assess your patient’s ambulation status, you note the patient is a high fall risk, and uses walls and furniture to navigate through his home. He has a 2-handed walker in the home which he states he uses more than half the time for ambulation.  His medications are located on the kitchen counter, and he spends more than half his time in the living room. The patient states there is no problem with remembering to take his medications and he does not need any help. You are able to confirm this with his daughter.

How would you score M1860?

a. (0) -Able to independently walk on even and uneven surfaces and negotiate stairs with or without railings (i.e., needs no human assistance or assistive device)

b. (1) -With the use of a one-handed device (e.g. cane, single crutch, hemi-walker), able to independently walk on even and uneven surfaces and negotiate stairs with or without railings.

c. (2) -Requires use of a two-handed device (e.g., walker or crutches) to walk alone on a level surface and/or requires human supervision or assistance to negotiate stairs or steps or uneven surfaces.

d. (3) – Able to walk only with the supervision or assistance of another person at all times.

ANSWER: d  
RATIONALE: Even though the patient uses a walker more than half the time, safe ambulation for this patient requires at least supervision due to a high fall risk score. Safety of the patient is the key consideration in this case, and the high fall risk score directly impacts the correct response here.

How would you answer M2020?

a. (3) Unable to take medication unless administered by another person.

b. (1) Able to take medication(s) at the correct times if:(a) individual dosages are prepared in advance by another person; OR (b) another person develops a drug diary or chart

c. (0) Able to independently take the correct oral medication(s) and proper dosage(s) at the correct times.

d. (2) Able to take medication(s) at the correct times if given reminders by another person at the appropriate times

ANSWER: a
RATIONALE: Since the patient spends the majority of his time in the living room and his meds are in the kitchen – AND he requires assist or supervision for safety with ambulation – this would require someone to assist with medications for safety. The patient’s safety is again the key consideration, and impacts the correct answer.
This example illustrates how easy it can be for inexperienced, untrained and/or rushed clinicians to inadvertently mark the wrong answers on M1860 and/or M2020. The best protection against these kinds of accuracy errors is ongoing training, according to J’non.

What is your agency doing to prepare?   

Smart home health agencies are gearing up for the implementation of C-2 by using the next few months to carefully review how well their clinicians are using OASIS, and provide the training needed to shore up weaknesses, J’non says.
Who should agencies target for OASIS C-2 training?
“Everyone,” J’non says.
She is currently finishing up a brand new recording from HHS offering C-2 training, and will make it available via the HHS online store in the next few days.
In today’s fluid home care climate, where regulations and requirements shift rapidly and the only thing certain is the likelihood of more change soon, J’non  says agencies can’t afford to look at training as “over and done.”
Being serious about providing excellent care means getting serious about providing ongoing training and support to clinicians.

Click here to browse the HHS online store to see which online courses are available to help your agency. 

Home health agencies brace for next 6 months

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

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

 

 

 

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 IT MATTERS

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.

WHO SHOULD COMMENT?

” 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.

WHAT’S CHANGING

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

HOW TO COMMENT

 Here is a link:

www.regulations.gov/#!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.”

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.”

 

 

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.

F2F REQUIREMENTS

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.

TRAINING CAN CLEAR THINGS UP

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 5 ESSENTIALS

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

HOW DOES YOUR AGENCY HANDLE COMPLAINTS?

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.

ACCOUNTABILITY

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.

COMMON COMPLAINTS

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.

8-POINT CHECKLIST 

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.

Think like an auditor

imageSeven times on a single day last week, Home Health Solutions Director of Appeals and Special Projects Heather Calhoun opened a case file and looked for proof of medical necessity.
Six of those seven times, she couldn’t find the proof she needed anywhere in the file before her.
“This is without question the No. 1 mistake I see agencies making in their day-to-day documentation, and the ramifications are enormous,” Heather says. “Without evidence that it’s needed, any care provided to a patient is not considered medically necessary and the agency may not be reimbursed for it.”
As home health agencies scramble to shore up the quality of their documentation practices under this month’s new wave of Centers for Medicare and Medicaid Services regulations, Heather and other HHS team leaders are working with agencies across the country.
Their goal is to teach home health care professionals how to think more like auditors — a skill that could be worth many thousands of dollars to an agency’s operational costs by preventing claims denials of specific services, visits or entire home health episodes of treatment.
“Documentation is an integral piece of the regulatory compliance required for agencies to succeed in today’s home health market,” HHS Owner J’non Griffin says. “We are working with agencies of all sizes to help them develop quality initiatives for meeting their regulatory burden.”

What auditors look for

To stand up to scrutiny, an agency’s documentation must be thorough. It will need to establish cause and intent for each aspect of care. That means agencies must record their delivery of patient care in clear and brief detail, beginning with the initial referral by a physician.
It isn’t enough just to note each pill, each dressing and each service provided to the patient; documentation must also show a comprehensive care plan coordinated among caregivers, with care goals specific to the patient.
But many agencies aren’t meeting all those requirements. Staffs busy with the delivery of patient care can get distracted from properly completing files — and HHS team members find that some of the same errors, omissions and inconsistencies show up routinely in the records of agencies of all sizes.

“Proper documentation is imperative for agencies,”  HHS Quality Assurance Manager Holly Kolitz says.  Even with time constraints and many competing demands,  agencies will need self-policing to  avoid costly errors and make sure documentation makes the grade.

 

Red Flag Checklist

     The HHS team has compiled the following checklist of some of the most common red flags almost guaranteed to catch the attention of auditors:
INCOMPLETE DOCUMENTATION:
— Missing physician orders
(Agencies need physician orders for each service, medication and treatment, including each change made to a patient’s medicine or treatment.)
— No evidence face-to-face physician requirement met
— No evidence of coordination of services
— No evidence of routine re-evaluation of patient care needs
— No explanation included for missed visits
— No documentation showing the physician was notified of a missed visit and why
ERRORS
– Careless mistakes due to lack of adequate proofreading 
INCONSISTENCIES: 
– OASIS, clinical notes, progress summaries, etc. fail to align, or in some cases even directly contradict each other.
— Clinicians provide conflicting information in their reports

“If a wound starts out being identified as one type of wound at the beginning of treatment, but is repeatedly identified in later documents as a different type of wound, auditors are certainly going to notice,” Holly says. “The legitimate question to be raised is whether we even know what kind of wound we’re dealing with.”
Agencies must provide documentation showing the initial diagnosis was changed or maintain uniformity throughout the treatment records, cross-checking to make certain later records support the wound identification in OASIS.
One of the most common mistakes Heather sees agencies make involves discrepancies in reporting between nurses and therapists.  A nurse, for example, may provide a highly functional score for a patient, because the nurse isn’t necessarily evaluating the same criteria as a  therapist. When a therapist evaluates the quality of the same patient’s gait,  stride or ease of transition from chair to walker, and reports lower functionality, the resulting discrepancy can become a red flag.

“Sometimes, it’s the simple mistakes that bog things down,” Holly adds. “Agencies can sometimes miss the obvious in recording details, and the results can create real issues.”
From copying a medical code wrong to identifying the wrong site for an injection or mistakenly substituting “right” for “left” on a record of a limb amputation, careless errors can sometimes cost an agency thousands of dollars.
The HHS team strongly recommends self-evaluation  in agencies, with frequent reviews of all documentation for accuracy.

One other area likely to generate red flags in an agency’s documentation is a lack of specificity. Tomorrow’s post will focus on strategies to better capture the important details needed for quality documentation.

Wednesday: The Mechanics Of Specificity 

Did you see our companion post on the four elements of quality documentation?  Read it here