Here are some home health related updates for this week:
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Extension of Medicare Sequestration Moratorium
On April 13, 2021, the announcement was received confirming that U.S. House of Representatives voted 384-28 to extend the suspension of the two percent Medicare sequestration through the end of 2021. The Senate voted 90-2 to approve this measure last month, but full approval in Congress was delayed when the House went into recess. The bill now goes to the desk of President Biden, who is expected to sign it into law.
This is a big WIN for the home health industry and for NAHC members who advocated for extension of the moratorium.
Thank you NAHC for playing a vital role in the efforts to extend suspension of Medicare sequestration!!
CMS revised MLN Matters Article MM111855 on Penalty for Delayed Request for Anticipated Payment (RAP) Submission — Implementation.
The revisions include the following areas:
Principal Diagnosis Code Reporting:
For “From” dates on or after January 1, 2021, the RAP may contain any valid diagnosis code, in order to facilitate timely submission. Since these RAPs aren’t paid, the accurate principal diagnosis code that supports payment is needed only on the claim for the period of care.
Service Date Reporting
For initial episodes/periods of care, the HHA reports on the 0023 revenue code line the date of the first covered visit provided during the episode/period. For subsequent episodes, the HHA reports on the 0023 revenue code the date of the first visit provided during the episode/period, regardless of whether the visit was covered or non-covered, unless the HHA submitted the corresponding RAP using the first day of the period of care as the service date on the 0023 line. In that case, the HHA reports a service date on the 0023 revenue code line that matches the date submitted on the RAP. This is necessary to make sure Medicare systems can correctly match the claim to the RAP during processing.
For a complete article, please go to https://www.cms.gov/files/document/mm11855.pdf
CMS updates on Claims Processing Issues
On April13, 2021 CMS held the Home Health, Hospice, and Durable Medical Equipment Open Door Forum and provided the following update related to Claims Processing Issues.
Three claims processing issues discussed in the January 26, 2021 Open Door Forum have been resolved. Since then CMS has identified three additional claims processing issue that are now resolved as well:
- Home health claims spanning 2020-2021 were applying the incorrect 2021 payment amount.
- Late RAP penalties were not being applied to outlier claims.
- Applying the late RAP penalty incorrectly to HHVBP claims.
CMS shared information on two ongoing claims processing issues:
- Low utilization payment adjustment (LUPA) visits that fall between the From date and RAP receipt date are being paid at zero whether the RAP was late or not. CMS will be instructing the MACs on a workaround and should correct claims paid in error.
- RAP payments for 2020 claims are not paying correctly. Only the labor portion is being applied. However, the final claim is paying correctly.
Home Health Quality Reporting Program Updates
On April13, 2021 CMS held the Home Health, Hospice, and Durable Medical Equipment Open Door Forum. During the Forum, CMS announced that five measures will be removed from the HH QRP with the July, 2021 refresh.
The measures are:
- Depression Assessment Conducted.
- Multifactor Fall Risk Assessment Conducted for All Patients who Can Ambulate.
- Diabetic Foot Care and Patient/Caregiver Education Implemented during All Episodes of Care.
- Pneumococcal Polysaccharide Vaccine Ever Received.
- Improvement in surgical wounds.
In addition to the HH QRP reporting, CMS reminded Home Health providers of rules and expectations related to Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS)
To receive the annual payment update for calendar year (CY) 2023, all Medicare-certified home health agencies that served 60 or more patients between April 1, 2020, and March 31, 2021, who meet Home Health Care CAHPS (HHCAHPS) Survey eligibility criteria, MUST contract with an approved HHCAHPS Survey vendor and have that vendor administer the HHCAHPS Survey on a continuous monthly basis from April 2021 through March 2022. This rule was included in the Home Health Prospective Payment System (HH PPS) Update Final Rule for CY 2021.
If your agency served fewer than 59 patients between April 1, 2020, and March 31, 2021, you are eligible to submit an exemption from participation for CY 2023. The exemption form can be located on the HHCAHP website at https://homehealthcahps.org/For-HHAs/Participation-Exemption-Request-Form
The exemption form has been available since 4/1/2021.
2021 Home Health and Hospice Medicare Summit
Save the date! NGS, CGS & Palmetto GBA will be hosting a free virtual Home Health and Hospice summit September 15-17, 2021 . The theme of this year’s summit will be Operation Collaboration: We Are All in This Together . The 2021 Medicare Summit attendees will receive education from the HH+H MACs collaborating to address the most current Medicare federal regulations and issues. The 2021 Summit will consist of two full days and one half day of education. Registration will open soon! Stay tuned for more details!
Influenza Immunization Reporting Tips
As we have previously discussed, Annual Health Care Influenza Vaccination Reporting must be completed by all of the facilities by May 15, 2021. CDPHE has previously advised the providers of the two ways to report healthcare worker influenza immunization data for the 2020-2021 Season:
- Health Facilities Portal: (there has been a delay in the creation of the new reporting tool. Once the reporting tool is available, CDPHE will send a message letting facilities know how to access the tool).
Multiple home health providers attempted to complete reporting utilizing NHSN in the leu of the reporting tool via Health Facilities Portal, however, experienced difficulty doing so. One of the messages that was received from NHSN indicated that “NHSN does not currently support reporting by home healthcare providers.”
To assist home health providers with meeting the reporting requirements in compliant manner, Amity Healthcare Group reached out to CDPHE. CDPHE advised us not to proceed with NHSN reporting but await for the Flu Vaccine reporting tool to be available in the Health Facilities portal.
Earlier today, CDPHE also provided the following update: “We are currently testing the updated Flu Vaccination Reporting application that will be released into the Colorado Health Facilities Interactive (COHFI) System. We are working to ensure the application functions properly and is easy to use. Our hope is to be able to release it by the end of the month. We know that this is not allowing you to submit your flu vaccination report on time and we are extending the deadline to 5/31/2021 for submissions if we are able to release the application by the end of April. If you have already submitted via NHSN thank you so much! We are excited to add this much-needed functionality into the COHFI system. We will be updating the user manual with instructions on how to submit when it get published but it will be a very similar process to the previous method if you have submitted in years past. Thank you so much for your patience as we work on getting a non-COVID 19 related system up and running!”
COVID Vaccinations: What Colorado Employers Should Know
Littler, Labor and Employment Attorney group, held a webinar on what Colorado Employers should know about COVID-19 vaccination.
Below, you will find responses to several of the questions addressed during the webinar:
Q:Do Colorado employers need to pay employees for time off to get vaccinated?
A: “Some states have passed laws specifically in response to COVID-19 mandating paid time off for employees to get vaccinated. Colorado has not passed a law specifically addressing COVID-19 vaccines, but its mandatory paid sick leave statute covers the COVID-19 vaccine.
Under Healthy Families and Workplaces Act, employees can use sick time for seeking preventive care (COVID-19 vaccines = preventive care).Employees can use paid sick time to get the vaccine.”
Q: Are most employers mandating vaccination?
A: “Most Employers are encouraging but not mandating the COVID-19 Vaccine. Most surveys show under 10% of employers plan to mandate vaccines. Encouraging vaccine, and providing employees resources for how to access it, may be safer option.”
Q: Should the employer maintain records of employee vaccination status and, if so, how?
A: “An employer can maintain vaccination records, but should safeguard this information. Reasons to maintain vaccination records: proof that no quarantine necessary if vaccinated person exposed to COVID; have on hand if required by third party. Risks in maintaining vaccination records :could constitute breachable data in many states, including Colorado; vaccination status potentially indicates disabilities or religion. Reducing the risks of maintaining vaccination records: maintain as secure and confidential medical records separate from the personnel record; allow access to records only as-needed basis
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