AMITY HEALTHCARE GROUP NEWS

Did you know that Amity Healthcare Group provides ICD-10 coding and clinical documentation review for home health providers?

If you are seeking to outsource your clinical documentation review and/or ICD-10 coding process and gain accuracy and efficiency, please reach out to us for assistance.

Our services include:

• ICD – 10 Coding
• OASIS Review + ICD – 10 coding
• OASIS Review + POC (Plan of Care) Review
• OASIS Review + ICD – 10 Coding + POC (Plan of Care) Review
• Episodic documentation review

For more information, please visit us at https://amityhealthcaregroup.com/services/coding-and-documentation/.

With questions, please contact us at 713-564-5011 or email at ig@amityhealthcaregroup.com.

OASIS -E Corner

In this issue we would like to bring your attention to the following OASIS related items/ questions:

OASIS-E Item A1250: Transportation

Question: If a patient uses an interpreter to provide the responses for the OASIS item A1250 -Transportation, does this mean the patient is unable to respond, and both Code X – Patient unable to respond and the information obtained from the interpreter should be coded?

Answer: When a patient responds in their preferred language with the use of an interpreter, this is considered a patient response. You would not code X – Patient unable to respond. Patients may respond to questions in English, or in their preferred language with the assistance of an interpreter.

NATIONAL NEWS

CMS Home Health Final Rule

Below, you will find a summary of the final rule for your review.

Home Health Conditions of Participation

CMS finalized a new standard at § 484.105(d) that will require Home Health Agencies (HHAs) to develop, implement, and maintain an acceptance-to-service policy that is applied consistently to each prospective patient referred for home health care.

The policy is expected to, at a minimum, address the following criteria related to the HHA’s capacity to provide patient care:

• The anticipated needs of the referred prospective patient
• The HHA’s case load and case mix
• The HHA’s staffing levels, and the skills and competencies of the HHA staff

The HHAs will also be required to make available to the public accurate information regarding the services offered by the HHA and any limitations related to types of specialty services, service duration, or service frequency.

The HHAs will be required to review the information included in the policy as frequently as the services change but no less often than annually.

Please note that the final rule does not prevent HHAs from maintaining their existing acceptance-to-service policies; rather, it is intended to complement them.

Financial Implications

The Final Rule includes the following:

• A net 2.7% inflation update (3.2%% Market Basket Index — 0.5% Productivity Adjustment)
• A base PDGM 30-day payment rate of $2057.35 for 2025 (compared to the 2024 base rate of $2,038.15)
• A 1.975% Budget Neutrality permanent adjustment (- 1.975%)
• Recalibration of the 432 case mix weights that leads to a separate budget neutrality adjustment in the payment rates of 1.0039%.
• Modification of wage index weights and wage index area designations leading to a budget neutrality adjustment of 0.9988%.

Overall, CMS estimates that Medicare payments to HHAs in CY25 would increase in the aggregate by 0.5%.

Home Health Quality Reporting Program (HHQRP)

New Assessment Items – Social Determinants of Health (SDoH)

CMS finalized its proposal for HHAs to collect four (4) new items as standardized patient assessment data elements under the SDOH category using the Outcome and Assessment Information Set (OASIS):

• One item for living situation
• Two items for food
• One item for utilities
• CMS also proposed to modify the transportation item

HHAs will be required to report these new assessment items beginning with patients admitted on January 1, 2027, for purposes of the CY 2027 HH QRP program year.

OASIS Data Collection

OASIS data collection will be required for patients with all payer sources on or after January 1, 2025, for the phase-in (voluntary) period or on or after July 1, 2025, for the mandatory period.

All-payer data collection is to begin with the Start of Care (SOC) OASIS data collection timepoint. The SOC is the first assessment that can be submitted for a non-Medicare/non-Medicaid patient, either on or after January 1, 2025, for the phase-in (voluntary) period or on or after July 1, 2025, for the mandatory period, as noted above.

Other updates:

Payment amount for disposable negative pressure wound therapy (dNPWT) device for CY 2025

CMS finalized the separate payment amount for a dNPWT device. The final CY 2025 separate payment amount for a dNPWT device will be $276.57 (compared to CY 2024 payment amount of $270.09).

Provider and supplier enrollment requirements

CMS is adding providers and suppliers that are reactivating their Medicare billing privileges to the categories of new providers and suppliers subject to a provisional period of enhanced oversight (PPEO). CMS may impose a PPEO for 30 days to one year for new providers and suppliers. The goal of a PPEO is to reduce and prevent fraud, waste, and abuse. During a PPEO, CMS may, among other things, conduct prepayment medical review and cap payments. CMS can apply a PPEO to new providers or suppliers, which are defined as providers or suppliers that are: (1) newly enrolling; (2) undergoing a change of ownership under 42 CFR § 489.18; and/or (3) undergoing a 100% change of ownership via a change of information.

Are You Compliant With Non-Discrimination Notice?

As you may remember, on May 5, 2024, the U.S. Department of Health and Human Services (HHS) issued in the Federal Register a final rule implementing Section 1557 of the Affordable Care Act (ACA), which prohibits discrimination on the basis of race, color, national origin, sex, age, and disability in certain health programs and activities.

In addition to a general prohibition on discrimination, on the basis of race, color, national origin, sex, age, and disability, there are several procedural requirements that covered entities, including home health agencies, must implement (please refer to table below).

According to the above timetable, providers were required to be in compliance with the notice of non-discrimination requirements and designation of a Section 1557 Coordinator (the notice of non-discrimination must include the contact information for the designated coordinator) effective November 2, 2024.

Home health providers will be required to issue the notice of non-discrimination as follows:

• On an annual basis to participants, beneficiaries, enrollees, and applicants of its health program or activity;
• Upon request;
• At a conspicuous location on the covered entity’s health program or activity website, if it has one; and
• In clear and prominent physical locations, in no smaller than 20-point sans serif font, where it is reasonable to expect individuals seeking service from the health program or activity to be able to read or hear the notice.
• A covered entity may combine the content of the notice with other nondiscrimination notices if the combined notice clearly informs individuals of their civil rights under section 1557, so long as it includes each of the elements required by the rule.

The OCR provided a sample notice of non-discrimination that providers may use to comply with the non-discrimination notice requirement.  The website also includes samples of other resources that will assist providers to comply with the notice of availability of language assistance and policy and procedure requirements with future compliance dates.

If you are required to complete a Beneficial Ownership Information (BOI) report, just a reminder to file the BOI with FinCEN by January 1, 2025, electronically at FinCEN’s website: www.fincen.gov/boi

Remember that a company is required to complete BOI if it is:

• A corporation, a limited liability company (LLC), or was otherwise created in the United States by filing a document with a secretary of state or any similar office under the law of a state or Indian tribe; or
• A foreign company and was registered to do business in any U.S. state or Indian tribe by such a filing.

FinCEN began accepting reports on January 1, 2024.

• If your company was created or registered prior to January 1, 2024, you will have until January 1, 2025 to report BOI.
• If your company is created or registered in 2024, you must report BOI within 90 calendar days after receiving actual or public notice that your company’s creation or registration is effective, whichever is earlier.
• If your company is created or registered on or after January 1, 2025, you must file BOI within 30 calendar days after receiving actual or public notice that its creation or registration is effective.
• Any updates or corrections to beneficial ownership information that you previously filed with FinCEN must be submitted within 30 days

For the list of entities exempt from filing a BOI report, please go to https://www.fincen.gov/sites/default/files/shared/BOI_Small_Compliance_Guide.v1.1-FINAL.pdf

Non-Compliance Letters for CY 2025 APU for Home Health Agencies

The Centers for Medicare & Medicaid Services (CMS) provided  notifications to home health agencies that were determined to be out of compliance with the Home Health Quality Reporting Program (HHQRP) requirements for calendar year (CY) 2025 Annual Payment Update (APU). Non-compliance notifications were distributed by the Medicare Administrative Contractors (MACs) and were placed into Home Health Agencies (HHA) My Reports folders in iQIES on October 21, 2024. Please be sure to check iQIES for non-compliance letters if you have not done so yet.

Agencies that received a letter of non-compliance may submit a request for reconsideration to CMS via email no later than 11:59 pm, November 27, 2024. If you received a notice of non-compliance and would like to request a reconsideration, see the instructions in your notification and on the Home Health Quality Reporting Reconsideration and Exception & Extension webpage.

Start Planning 2025 Home Health Education with ACHCU Academy annual event. 2025 event held under the title Achieving Excellence will take place in Dallas, March 3-5, 2025.

We are excited to announce that Amity’s Kelly Pineda and Irina Gorovaya will be speaking at the event on multiple topics (to review event’s agenda, please go HERE)

Do not forget to REGISTER for the event!

TEXAS NEWS

Upcoming Change in Emergency Communication System for HCSSA Providers: Please note that the emergency communication system, Blackboard Connect, will be replaced by a new system called AlertMedia.

The transition to AlertMedia is anticipated to go live on December 1, 2024.

Providers who are currently enrolled in Blackboard Connect should receive a message through Blackboard Connect that the system will be terminated.

Once AlertMedia goes live providers will have to re-register in the new system. All HHSC requirements that are in place for Blackboard Connect will remain in place for AlertMedia.

Once AlertMedia is in place, HHSC will issue a separate communication on how to use the new system. Providers will be required to register in AlertMedia as defined by their Texas Administrative Code rule.

COLORADO NEWS

HCPF identified potential improper billing for Electronic Visit Verification (EVV)-required services with place of service (POS) 99, indicating an EVV Live-In Caregiver (LIC) exemption when an LIC does not exist.

Refer to the following resources to address these concerns and ensure compliance:

• Operational Memo (OM) 20-051 – EVV Live-In Caregiver Exemption (HERE)
• EVV Manual (HERE)

HCPF strongly encourages ALL providers to review the applicable billing manual to confirm the correct POS code being billed and is reminding ALL providers that utilization of POS 99 for LIC-exempted services requires completed LIC documentation.

Please remember that HCPF implemented multiple opportunities for Colorado Home Health stakeholders to allow providers to interact with HCPF home health program team.

The stakeholder engagement includes:

• LTHH Office Hours – second Tuesday of each month from 1:00 to 2:30 p.m.
• LTHH Rule Revision Workgroup
• PAR Restart Workgroup

For more information, dates, and meeting links, please visit Home Health Program web site.

Amity’s newsletters will be archived on Amity’s Healthcare Group website at https://amityhealthcaregroup.com/resources/ under Resources/ Our Newsletter section.

Please do not hesitate to reach out for any assistance or questions via email, phone, or website at https://amityhealthcaregroup.com/resources/.

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Thank you,
Irina Gorovaya, RN BSN, MBA
Amity Healthcare Group, LLC
Home Health Consulting, Education and Outsourcing Services
713-564-5011 (Houston Office), 303-690-2749 (Denver Office), 720-398-6200 (fax)
https://amityhealthcaregroup.com/