Issue date: November 04th 2022

November is National Home Care and Hospice Month!!

AMITY’S NEWS

Home Health ICD-10 Coding and Clinical Documentation Review

With OASIS-E and Home Health Value-Based Purchasing (HHVBP) coming just around the corner, take advantage of the professional assistance to ensure accurate clinical documentation, improved quality measures standing, and optimal reimbursement.Outsourcing coding and clinical documentation review to dedicated professionals is one of the most effective strategies to strengthen and enhance documentation from regulatory, payment, and legal perspectives.

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
Quality Trends Analysis and QAPI Development

Are you OASIS-E ready? We are! Let Us Help You!

For more information or a free trial, please contact us at 303-690-2749 or email at ig@amityhealthcaregroup.com

NATIONAL NEWS

Quarterly Credit Balance Reports Are Due Soon

The CMS Final CY 2023 Home Health Rule has been at the center of attention this week. The entire industry was in anticipation of the final decision related to the proposed cuts.

As you know, CMS originally proposed a 7.69% permanent rate adjustment based on the conclusion that HHAs were overpaid in 2020 and 2021 due to provider behavior changes in coding and services provided. The Final Rule finalized a 2023 rate reduction at 3.925%. This represents one-half of the 7.85% rate reduction that CMS calculated as warranted under its methodology. CMS explains lower adjustment rate being implemented due to “we [CMS] recognize the potential hardship of implementing the full -7.85% permanent adjustment in a single year.”

The National Association for Home Care and Hospice (NAHC) has been detrimental in advocating for the entire industry and intends to continue the advocacy efforts in the future. According to William Dombi, President of the National Association for Home Care & Hospice, “We now turn to Congress to correct what CMS has done and prevent the impending harm to the 3.2 million highly vulnerable home health patients that depend on this essential Medicare benefit annually. Even with the limited phase-in of the rate cut, with significantly rising costs for staff, transportation, and more, home health agencies across the country cannot withstand the impact of rate cuts.”

As we dive into the details of the rule, we will be sharing more information with you in the next couple of the newsletters, but for now, we would like to provide a summary of the key components of the Final Rule.

The Final Rule includes the following:

A net 4.0% inflation update (4.1% Market Basket Index – 0.1% Productivity Adjustment).
CY2023 adjustment of 3.925% Budget Neutrality permanent adjustment “related to provider behavior changes triggered by PDGM.
Recalibration of the 432 case mix weights.
- The outcome of the payment rate changes on 30-day period base rates is as follows. HHAs that failed to provide required quality data have these rates reduced by two percent.

Modification of the LUPA thresholds.
- Institution of 5% cap on negative changes in the area-specific wage index effective CY 2023. The Final Rule applies the cap prospectively on a permanent basis to prevent provider financial instability. It does not affect those geographic areas that had significant declines in their wage index in 2022 without the protection of a five percent cap.
Home Health Quality Reporting Program (HH QRP)
- CMS finalized the decision to end the suspension of OASIS data collection on Non-Medicare/Non-Medicaid HHA patients and requirement for HHAs to submit All-Payer OASIS Data for Purposes of the HH QRP, beginning with the CY 2027.
- CMS finalized the decision that the new OASIS data reporting will be required beginning with the CY 2027 program year, with data for that program year required for patients discharged between July 1, 2025 and June 30, 2026.
Expanded Home Health Value Based Purchasing (HHVBP) Model
- CMS finalized the change to the HHA baseline year to CY 2022 for all HHAs that were certified prior to January 1, 2022, starting in the CY 2023 performance year. CMS is also making conforming regulation text changes at §484.350(b) and (c).
- CMS is finalized the proposed amendments to the model baseline year from CY 2019 to CY 2022 starting in the CY 2023 performance year to enable CMS to measure competing HHAs performance on benchmarks and achievement thresholds that are more current.
CMS established three new G-codes for use on home health claims to capture home health services delivered via telecommunications.
- CMS reiterates that the collection of information on the use of telecommunications technology does not mean that such services are considered “visits” for purposes of eligibility or payment, such data will not be used or factored into case-mix weights or count towards outlier payments or the LUPA threshold per payment period.
- CMS will establish G-codes for identifying when home health services are furnished using
  - synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system;
  - synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system; and
  - the collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (remote patient monitoring).
- Data collection using the G-codes would begin voluntarily by January 1, 2023 and become mandatory on claims by July of 2023.

For a complete CMS Final CY2023 Home Health Rule, please go to: HERE

Quarterly OASIS Q&AThe October 2022 CMS Quarterly OASIS Q&As are now available. Please note that there are some questions and answers on OASIS-E items that are included in Q&As.

Employer Alert: Continue to Use Current Form I-9

Employers should continue using the Form I-9, Employment Eligibility Verification, after its expiration date of October. 31, 2022 until further notice.The Department of Homeland Security (DHS) will publish a Federal Register notice to announce the new version of the Form I-9 once it becomes available.

In addition, the Department of Homeland Security (DHS) and U.S. Immigration and Customs Enforcement (ICE) announced an extension of the flexibility in complying with requirements related to Form I-9, Employment Eligibility Verification, due to COVID-19.

This temporary guidance was set to expire October 31, 2022. Because of ongoing precautions related to COVID-19, DHS has extended the Form I-9 flexibilities until July 31, 2023.Employers are encouraged to begin, at their discretion, the in-person verification of identity and employment eligibility documentation for employees who were hired on or after March 20, 2020, and who presented such documents for remote inspection in reliance on the flexibilities first announced in March 2020.

Employers must monitor DHS‘ and ICE’s Workforce Enforcement announcements about when the extensions end and normal operations resume.

E-Verify participants who meet the criteria and choose the remote inspection option should continue to follow current guidance and create cases for their new hires within three business days from the date of hire. Please see COVID-19 webpage for more information.

Revised Guidance for Staff Vaccination Requirements

On October 26, 2022, the Centers for Medicare & Medicaid Services (CMS) released QSO-23-02-ALL- Revised Guidance for Staff Vaccination Requirements. CMS is revising its guidance and survey procedures for all provider types related to assessing and maintaining compliance with the staff vaccination regulatory requirements.

To learn more, please go here. Please remember that Home Health specific information is included in Appendix G (there are no significant changes impacting Home Health providers in the guidance).

COLORADO NEWSAdministrative Approval for Prior Authorization Requests (PARs) with Private Duty Nursing (PDN) Services

Effective October 26, 2022, the Department of Health Care Policy and Financing (the Department) initiated a Temporary Administrative Approval Process on PDN PARs until December 31, 2022. Please note this is an Administrative Approval Process not a pause. Providers will still need to submit all necessary documentation.This information will be posted to the Department website, shared with home health agencies, providers, and members. Over the coming weeks, the Department will develop additional educational materials and operational guidance for providers and a family-friendly resource for members to better understand their nursing level benefits (including intermittent nursing).

It is the Department’s anticipation that this Temporary Administrative Approval process will allow time to conduct outreach to families, work with providers to ensure they understand PAR documentation and continuation of benefits requirements, and update notices to ensure greater clarity.

Contact Kepro at coproviderissue@kepro.com for help submitting PAR Reconsiderations or new PARs.

Members may contact homehealth@state.co.us.

General PAR Updates

I) Automated AuthorizationWhen submitting prior authorization requests (PARs) with multiple lines of service, it is possible that some lines will automatically authorize, and others will require manual review by a nurse. The lines that are reviewed by a nurse will meet the required timeframe of ten (10) business days or less.

Contact Kepro Customer Service or email coproviderissue@kepro.com with questions about PAR completion regarding automated and manually reviewed lines.

II) Requesting Modifications to Existing PARs

Be sure to include all details when requesting a revision to an existing PAR within the notes section of Atrezzo®, including the dates of service being modified and changes to unit numbers, and records supporting the change(s) being requested.

A new PAR must be submitted for revisions to PARS that have been previously billed, with a description of the reason for the change (e.g., the previous PAR was approved with the incorrect servicing provider), along with a request to end-date the previous PAR (include the case ID of the previous PAR).

Contact Kepro Customer Service or email coproviderissue@kepro.com for questions about submitting modifications to existing PARs.

III) Kepro Atrezzo® System Training

Kepro is holding monthly Atrezzo® system training sessions. The next sessions will be held November 23, 2022, at 8:30 a.m. and 12:00 p.m. There will be announcements with information to sign up.

Email coproviderregistration@kepro.com with questions regarding training.

State OASIS-E Training

State is now offering OASIS -E training as noted below:

CDPHE OASIS Coordinator, Wendy Castro, assembled an OASIS-E virtual training for the local home health providers. There will be a total of six (6) sessions on different days and at varying times, both weekdays and one on the weekend. The first one will take place on 11/8/2022 and the last one will take place on 11/27/2022.

The training will be presented on Co-Train. Just click the link and it will take you to the training for you to register for one of the six sessions. Make certain you are logged into Co-Train prior to selecting the link.

If you do not have a Co-Train account, follow the directions below to create an account.

Click the following link, which will take you to the home screen for Co-Train. Select Log in or Create a Train Account in the upper right corner or along the left side and follow the prompts

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
720-353-7249 (cell) 303-690-2749 (office) 720-398-6200 (fax)
www.amityhealthcaregroup.com

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