In The News

Home Health Proposed Rule Comments Due August 16th

If you have not already done so, please comment on the 2023 Home Health Proposed Rule by Tuesday, August 16th. Comments can be made through the following link:

https://www.federalregister.gov/documents/2022/06/23/2022-13376/medicare-program-calendar-year-cy-2023-home-health-prospective-payment-system-rate-update-home

We have also included a draft comment letter template for you to use for your comments (in the event that you need it). CMS has to review and respond to every comment, so let’s let them know what we think and what the impact of the proposed rule would be should it remain in its current form.

It’s also important that we reach out to our Senators and Representatives and ask them to support the Preserving Access to Home Health Act (S.B. 4605), which would freeze the current payment rate in place, with the exception of annual market basket updates, through 2025. 

Calls and personal messages are best, but if you are short on time, a message has been pre-drafted and can be sent in seconds from the NAHC Virtual Advocacy Center.  

Contact us with any questions – and remember, comments to CMS are due Tuesday!

 

Private Duty Nursing (PDN) Emergency Rule

The Medical Services Board (MSB) met this late last week to consider an emergency rule for Medicaid members who utilize Private Duty Nursing (PDN) who have extraordinary medical needs that require more than the current 16 hour/day to exceed that limit with approval. Under the emergency rule, adult members may now receive up to 23 hours if deemed medically necessary.

During the meeting, HHAC's Advocacy Team member Eliza Schultz, testified, along with others, that this is a good first step to increasing access for patients, but that HHAC is anxious about implementation. We suggested that the rule remove reference to the 16-hour cap all together and simply state that members are allowed up to 23 hours if necessary. We also brought up our serious concerns with Kepro. Adult PDN services must still receive prior authorization through Kepro and are starting to see denials and shortened hours like we saw in the pediatric space. It seems disjointed that on one hand HCPF is looking to increase access, while their UM provider is denying these same services.

Some Board members seems interested in exploring these concerns and has asked HCPF to return at the next MSB meeting to discuss implementation of this rule in more depth.

The MSB approved the emergency rule with one dissenting vote (because of the implementation concerns). We will continue to engage with HCPF on issues with Kepro and will plan to engage at the next MSB meeting.

Full Approved Rule Attached.

 

Another State Invests Millions Into Aging-In-Place Program CAPABLE

Home Health Care News
 
This month, the Colorado Visiting Nurse Association (Colorado VNA) received a $2.3 million grant from the state to expand its CAPABLE program and to provide care for more Medicaid members.

CAPABLE is an interdisciplinary program from the Johns Hopkins School of Nursing that combines nursing care, occupational therapy and handyman services. It stands for “Community Aging in Place — Advancing Better Living for Elders” and aims to prove that with modest investments and short-term interventions, aging adults can stay in their home longer while improving their quality of life.

“It’s very non-clinical in the sense that a clinician isn’t coming in with their knowledge and telling the older adult what to do,” Sarah Szanton, the dean of John Hopkins School of Nursing, told Home Health Care News. “It’s very much centered around what the older adult would like to be able to do in their home. Then the occupational therapist and the nurse will use their experience to help the person brainstorm strategies for doing it.”

CAPABLE started in Baltimore over 12 years ago and has expanded to over 25 cities in 23 states since then. In order to grow the program, the CAPABLE team typically joins forces with other organizations.

Colorado VNA has been providing CAPABLE services in the Denver area since 2017 and has served over 300 clients. This most recent expansion will be dedicated towards Colorado’s Medicaid beneficiaries, also known as the Health First Colorado program…

Read Full Article

 

Why Home Health Insiders Expect Uptick In Audits, Inquiries From Federal Watchdogs

Home Health Care News

Audits from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) can often catch home health agencies by surprise.

And after a slower audit period during the COVID-19 pandemic, experts told Home Health Care News that providers should expect a ramp-up in audits over the next year.

Battling that element of surprise will be key to getting through a successful audit process.

“Having a very healthy, robust compliance program that really challenges the health of a home health agency internally is a good way to be ready for when an outside entity, like the government, does the same,” Bryan Nowicki, a partner at Husch Blackwell, told HHCN.

Home health agencies should be at a place where they aren’t just prepared for audits, but also expect them.

“Don’t be surprised if and when you get an audit,” Husch Blackwell Associate Erin Burns told HHCN. “It’s likely going to happen, and knowing that should help you be more prepared in the long run.”

“The audit process itself is — as we tell our clients — a marathon, not a sprint,” Burns said.

Knowing that audits are coming is part of the battle, Burns said. But knowing what OIG or other federal agencies are looking for is another piece to the puzzle.

Historically, audits done by OIG include the office taking 100 claims at random, evaluating those claims and then coming to an error rate. OIG will then extrapolate that error rate and assess it over the industry.

Other audits — like the ones done by unified program integrity contractors (UPICs) hired by the U.S. Centers for Medicare & Medicaid Services (CMS) — are used to investigate home health agencies for potential fraud.

“We have seen an uptick in UPIC activity across the board for home health this year and I think that relates, in part, to the government relaxing some of the COVID restrictions,” Nowicki said. “I think the audits will focus on the time periods when COVID was an issue and I think that’s something home health agencies will have to address.”

Many in the industry have expected OIG audits to proliferate in home health, like they have in hospice over the last few years. The home health industry could also see an uptick in audits from OIG on provider relief funds as well, Burns said.

Generally, both audit processes will look at financial data for home health agencies, homebound statuses, OASIS compliance and other factors that impact payment.

OIG is likely going to refine what exactly they are looking for on the other side of the pandemic, Nowicki said. However, what that looks like won’t be known for another year or so.

Read Full Article

 

The Home Health (HH) OASIS-E Guidance Training Program

The Centers for Medicare & Medicaid Services (CMS) is offering a virtual training program that provides instruction on the guidance for the Outcome and Assessment Information Set (OASIS)-E. This training is part of a comprehensive strategy to ensure home health providers have access to the educational materials necessary to promote understanding and compliance with changes in reporting requirements associated with the Home Health Quality Reporting Program (QRP). These changes go into effect on January 1, 2023. A major focus of this training will be on the cross-setting implementation of the standardized patient assessment data elements being introduced in 2023 to ensure more consistent reporting and evaluation across post-acute care settings.

The training program consists of two parts:

Part 1  LEARN: Watch the pre-recorded training webinars that deliver foundational knowledge to assist in learning the new items and guidance. These videos are intended to be viewed in advance of the live event and are available now on CMS YouTube .

Part 2 – PRACTICE: Attend the live, virtual workshop sessions that provide practice coding scenarios on the items covered in the Part 1 training webinars. These live sessions will take place on September 13th and September 14th between 1 p.m. and 5 p.m. ET.

Training Materials: Additional training resources are located within a ZIP file in the Downloads section of the HH QRP Training page (2022_September_HH Virtual Training Program – Part 1 (ZIP)). These resources include an Acronym List, Action Plan Worksheet, Resource Guide, Case Study documents, and PDF versions of the Training Webinars.

Registration for the Part 2 live, virtual workshop sessions can be completed online through Zoom Events.

If you have questions about accessing resources or feedback regarding the trainings, please email the PAC Training Mailbox. Content-related questions should be submitted to the HH QRP Help Desk.

 
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