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Latest Issue of CARING Focuses on Health IT for Home Care & Hospice

 

The latest issue of CARING magazine will soon be available. The in-depth subject this month is heath information technology and how it is changing the home care and hospice landscape.

For the issue, Richard Brennan, Executive Director of the Home Care Technology Association of America (HCTAA) – a NAHC affiliate - served as Guest Editor. Below are his introductory notes to the issue reprinted in their entirety.

What if we could envision the future of health care delivery and determine the fundamental components of the new standards of care that will be needed to support patient-centered, personalized, empowered health care in America? What technologies will drive the delivery of health care to the home? What business and clinical practices will be leveraged to support value-based longitudinal care coordination? And how will technologically sophisticated home care agencies interact with other providers in the spectrum of care to coordinate care and support new models of care? In this issue of CARING, we provide readers with a series of articles and case studies – stepping stones to innovation – to determine a path forward.

Chris McGurn starts our technology coverage with our cover story. Several members of Congress got a hands-on telehealth demonstration when representatives from NAHC and its affiliate Home Care Technology Association of America (HCTAA) visited them in their offices on Capital Hill. NAHC President Val J. Halamandaris stressed the benefits and cost-saving potential. “Once you see how this technology works, we hope you will become an advocate of it,” said Halamandaris. “There’s a real premium in keeping people out of the hospitals, which these devices help to do.”

Our overview of the issues surrounding health IT implementation within the home health and hospice community includes advancements in health information technology and other technologies. The integration of health IT into health care is a challenging subject, but our primer article focuses on the challenges and opportunities for home care providers to consider in navigating the complex landscape of developing health IT standards.

We also included case studies from home health agencies and their vendor partners on technologies that support improved referral and communications, telehealth for improved clinical outcomes, efficiencies, and reducing hospital readmissions, mhealth technologies for electronic documentation for mileage reimbursement and more accurate scheduling, and also data mining to unlock problems in clinical protocols and service delivery.

We asked agencies to tell us how they have implemented technology to change the way they do business and enhance the services they offer. In this issue, you’ll find six case studies:

  • Health Resource Solutions of Illinois used a customizable EHR to raise standards of care, improve communications and lower administrative costs.
  • Centura Health of Colorado merged their call center and telehealth to decrease 30-day hospitalization rates and increase the quality of life for their older adult patients.
  • Ambercare of New Mexico used technology to manage costs, improve the quality of care, and give patients the care they need at home.
  • Pardee Home Care of North Carolina used analyses of their agency visit and OASIS data to improve Outcome scores.
  • Lee Memorial Health System of Florida implemented telehealth solutions to lower readmissions and save an estimated $5.3 million.
  • Bristol Hospice selected an electronic medical record that was flexible yet supported their six sites across the country even in times of a disaster.

As the executive director of the Heath IT Now Coalition, Joel White has one of the best perspectives on how technology is radically changing the face of home healthcare and the challenges we face in the field, in our back offices, and on Capitol Hill.

The Coalition he manages is a diverse group of organizations representing patients, health providers, health insurers, employers and unions that have come together to help integrate information technology into healthcare. He shares his own personal insights on home care as seen through his mother’s experience and recommends that home care agencies leverage their advanced use of health IT to participate in new models of care established by the Affordable Care Act and also make the case to Congress that technology is invaluable in delivering quality home care.

Our quest for innovation in health care – for a revolutionary new approach to the delivery of home care – will employ advancements in technologies, changes in payment policies and methodologies and the mustering of organizational resources on a wide-ranging scale. Since this will have to be a unifying process of innovation, we also hope that the successes of pioneering home care agencies in this endeavor will offer us clear examples of excellence in care delivery and a path forward.

Please enjoy, discuss, and share our technology issue with your colleagues, friends and also the decision makers in your community.

To view a digital version of CARING, please click here.

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Companionship Services Exemption in Home Care

 

On September 16, 2013, the U.S. Department of Labor issued the Final Rule that significantly modified the longstanding “companionship services” and “live-in domestic services” exemptions from minimum wage and overtime compensation. The rule changes take effect on January 1, 2015.

NAHC has developed a series of strategies to address the impact of the rule in home care. These strategies include a series of defensive measures through Congress, litigation to invalidate the changes, and a strategy to make the rule change livable for home care providers.

The defensive legislative strategies include the introduction of legislation to reverse the rule change. However, this strategy has a very limited chance of success given the veto power of a President who fully supports this rule. Similar measures such as an attempt to defund the rule implementation are likely to face comparable results.

NAHC continues to evaluate and assess a litigation strategy. NAHC has successfully defended the current rule before the U.S. Supreme Court twice, most recently in 2007. However, litigation this time around would aim to invalidate the rule, which is a much more difficult effort. Also, if litigation is pursued, it would require success on both the revised definition of “Companionship Services” as well as the change that excluded third-party employers from the exemption.  All these elements are undergoing a careful review at NAHC.

The latest NAHC strategy is being termed the “lemonade approach.”  The rule-- a “lemon”-- would be turned into “lemonade” by securing federal support for the new costs that the overtime rule would create. With the new funding, home care companies can continue to meet consumers’ needs without resorting to part-time workers, reducing base wages, or other similar measures to control cost growth. Consumers would win by getting experienced staff with reduced staff turnover. Workers would benefit by getting improved wages. Companies would remain stable as the new costs are funded.

The “lemonade” strategy would begin with the concept that the President must find a way to fund the new mandate if he wishes to achieve his intended goals for workers without harming consumers and home care businesses. Funding the new mandate may entail two separate actions. For federal health care and personal care programs, regulatory changes in the benefit programs could include a requirement to adjust payment rates to cover any new costs incurred complying with the overtime rule.

Private pay home care can be addressed in a different way.  Since rates are set by the private businesses in contrast to government funding programs, consumers can be protected from the higher care costs triggered by the new rule through a tax credit program. Current tax law includes several tax credit programs under which individuals receive a tax payment credit when expenses are incurred for a particular good or service. With this approach, the elderly and disabled can qualify for a credit if they purchase home care services. The credit would be payable even where the consumer has no income tax liability.

The “lemonade” strategy would not be an easy or success-guaranteed advocacy effort. It will take hard work and luck to succeed. However, it is the one strategy that will bring the most stakeholders together as consumers, workers, and employers should all be able to support it.

NAHC Report will continue to keep the home care community updated as this advocacy effort unfolds.

NAHC also urges its members to attend this year’s Annual Meeting, October 31 – November 3, to continue its grassroots advocacy on this and many other topics that have a direct consequence on the home care & hospice community.

 

From the NAHC Report article

To register to attend the Annual Meeting, please click here.

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An Update on the Government Shutdown for Home Care & Hospice

 

The partial shutdown of the Federal government is now well into its second week. As reported in a previous NAHC Report article:

“The home health and hospice community likely will be minimally affected since Medicare and Medicaid are entitlement programs that are deemed “mandatory spending” and therefore not part of the government’s discretionary spending negotiations. At this point, it looks likely that Medicare payments to providers would continue unabated, yet slowdowns in payments are still possible depending on how CMS staff or contractors are affected.”

Both Democrats and Republicans continue to blame the other side for the impasse, yet negotiations appear to be slowly taking shape – a group of Democratic lawmakers met with the President at the White House earlier this week. Another meeting was held at the White House between the President and Republican lawmakers.

At this point, it appears likely that negotiations to fund the government will get tied to the looming debate on raising the debt ceiling. If the debt ceiling issue is not resolved by October 17, the U.S. Government will default on it loan payments as well as other obligations - which would be both unprecedented and potentially disastrous for the economy as well an entitlement programs such as  Medicare, Medicaid, and Social Security.   

Earlier this week, House Speaker John Boehner proposed a six-week increase in the debt ceiling – extending it to November 22. This proposal would help to fund the government’s existing obligations while also giving Congressional negotiators time to reach an agreement on a more sweeping “Grand Bargain.”

Under the proposal, the six-week extension would allow for talks on a broader fiscal package that could enact changes to entitlement programs and the Tax Code, fund the government, and lift the debt limit for a longer period of time, according to GOP sources familiar with the Speaker’s plan. The government shutdown would, however, remain in effect and negotiated separately.

Of most pressing concern for the home care and hospice community if such a “Grand Bargain” approach is taken would be any provisions to entitlement reform – particularly to Medicare. During the last round of negotiations for such a “Grand Bargain” – which ultimately faltered - many of the recommendations from the Simpson-Bowles Commission were included.

NAHC has long opposed many of the Simpson-Bowles recommendations – including additional cuts to Medicare funding and the imposition of a uniform 20 percent copay across all Medicare sectors, including home health and hospice.  For home health, this recommendation would mean a copay of approximately $600 for a 60 day episode of care.  For the typical stay in hospice, it would mean a copay of approximately $2,300. 

The President in his budget proposed a $100 copay on home health episodes not preceded by a hospital or nursing home stay, beginning in 2017 for those beneficiaries who become eligible for Medicare in 2017 or later.  The President also has proposed a 1.1 percentage point cut in the inflation update for post acute payments over the next ten years, including home health.

With so many Congressional developments that could impact home health and hospice on the immediate horizon in Washington, it is vitally important that members of NAHC attend this year’s annual meeting in Washington and join in the home care and hospice community lobby day on Thursday, October 31. Please see NAHC Report from October 8 for more details. 

To register to attend NAHC’s Annual Meeting, please click here.

From the NAHC Report article

 

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Proper EHR installation key, KLAS report says

 

The key to effective health information technology in a small, office-based medical practice is to properly install the newly purchased electronic health-record system, according to a new report from KLAS Enterprises.

KLAS's review of 27 vendors' products found that unhappiness with an EHR vendor's installation effort leads to practices switching to another vendor. It also found that such flipping is on the rise.

Orem, Utah-based KLAS, a market research firm, found that “implementation success is a strong predictor of future customer satisfaction.” The report was based on interviews of leaders of practices of one to 10 physicians about ambulatory EHR performance. “Vendors that do a good job of ensuring that clients get up and running as quickly and thoroughly … will likely continue to have happy clients,” it said. “First impressions matter.”

“Overall replacement rates are up for vendors who have failed to live up to providers' rising delivery expectations,” the KLAS report said.

“Providers leaving their current EHR cited poor service and vendor relationships as the primary reasons for replacement.” Also cited by customers as reasons for bailing are poor usability and a sense they are being “nickle-and-dimed” by their vendor.

“We asked the question, is this EHR part of your long term plans, and when they said no, we dug deeper and found out why,” explained research director and report author Erik Bermudez. Between customer support issues and upgrades for Stage 2 and Stage 3 of meaningful use, “We're definitely going to start whittling down” the EHR market, he said.

From the provider perspective, KLAS advises providers to determine which vendors have the most positive implementation experiences and make that a high priority in choosing a vendor, second only to a technical evaluation of a vendor's system.

In addition to failing to meet normal customer satisfaction requirements, a significant number of vendors have not yet prepared their products for the higher testing and certification standards needed to make their health IT systems eligible for use in the federal EHR incentive payment program, a Modern Healthcare analysis of federal program data shows. The federal data points to a looming shakeup in the overcrowded EHR market, industry observers say.

Only four of the top 10-ranked vendors in the KLAS survey in terms of company performance, product satisfaction and value for the money have a product tested and certified to the new, 2014 Edition standards to enable their customers to meet Stage 2 meaningful-use criteria under the EHR incentive payment program created under the American Recovery and Reinvestment Act of 2009.

From the Modern Healthcare Business Blog

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NAHC President Submits Progress Report to the Board

 

The Campaign for Responsible Rebasing.

The proposed revisions in the Medicare Prospective Payment for Home Health issued by CMS were a major disappointment. They were issued in response to a provision in the ACA requiring “rebasing” which contemplated a top to bottom look at how to make the program better, to increase its efficiency, to create and reward positive incentives, to increase access to care among beneficiaries, and to control costs not only in home health, but in the Medicare program overall.

Our first action was a statement of unity issued on behalf of NAHC, the Partnership for Quality Home Healthcare, and the Visiting Nurse Associations of America. We complained that CMS did not do its job.  There was nothing resembling a comprehensive analysis of the Medicare home care program.  CMS made it only about the money.

Our second point was that the cuts they put forward were draconian and will reduce senior's access to care. On the basis of limited or outdated data for only one year based on only some 700 of the more 10,000 available cost reports, CMS concluded that payments were too high, recommended the maximum possible 3.5 percent cut for each of the next four years or a total of 14 percent which computes to approximately percent $22 billion in cuts. Nor, does there seem to be any embarrassment on the part of CMS for imposing the $22 billion in cuts on top of $78 billion in cuts imposed on the home care patients since 2009. In their proposed rule, they blame Congress for the amount of the cut. We are fighting against these illegitimate rule revisions in order to protect the patients who need care.  It is also our hope to prevent the legacy of this administration from being one known for a reduction of home care, the program most needed to meet the needs of the 78 million baby boom generation by over $100 billion.

Third, NAHC has produced the data which shows that by 2017,  when the full effect of these cuts is realized, only three states will show positive Medicare margins: Connecticut with .3 percent, Georgia with .2 percent and Tennessee with 1.6 percent. Moreover, the percentage of agencies who will be in the red run from Hawaii with 100 percent, New York at 89.9 percent and Oregon at 87.2 percent on the high end to lows of Rhode Island at 38.l percent, Connecticut at 47.l percent, and Tennessee at 51.3 percent. The national Medicare average will drop to - 9.77 percent. We have pointed out that unlike hospitals or nurses homes, home health cannot fall back on passing along higher fees to private insurance, or private payors because this segment of our industry remains very tiny.

Fourth, we have pointed out that CMS did not undertake an analysis of the impact of their rule on small businesses. As defined by the Small Business Administration, this includes organizations with operating revenue of less than $10 million a year.  Small businesses employ 57 percent of the private workforce representing 44 percent of U.S. payroll.  A report produced by Dobson DeVanzo and Associates for the Partnership of Home Health Quality and Innovation concludes that the rule will adversely effect  small agencies to be at a significant disadvantage.  They recommend that the rule be revised to ensure the financial stability of small home health agencies. We have been working with both the SBA and related Congressional Committees. The latter have authority that we put in motion in l997 to set aside any regulations which adversely effect small businesses.

Fifth, working with VNAA, we released their study which shows that the proposed “rebasing” cuts may result in undermining both access to and actual care to patients in rural and underserved agencies. Medicare beneficiaries, especially those who qualify for home care by definition must be homebound. They are older, sicker and poorer than the Medicare population as a whole and a great deal more vulnerable.

Sixth, NAHC has produced data showing: l) that according to the Bureau of Health Statistics, the most needed jobs in America over the next ten years will include home health aides, personal care assistants, and nurses; 2) that there are over 1,140,402 jobs in the home health industry nationwide; 3) that as of 2011, home health had a $4.7 trillion impact on payroll and labor income; 4) in July, home health generated nearly 4,000 new jobs according to the Bureau of Labor Statistics. This was almost two-thirds of all new jobs created in the ambulatory health care services sector last month; 5) increased demand for home healthcare jobs are expected to grow 5.5 times faster than all other non-farm industries for the remainder of the decade. The point is that many new employees will be needed in home health to meet the growing needs of the 78 million

U. S. baby boom generation. Home health has provided a major boost to the economy, but this rate of growth will be jeopardized by the proposed draconian rules which will undermine the infrastructure which meets patient's needs and simultaneously creates jobs.

Seventh, in addition to the collaboration of three national home care organizations who have embraced the goal of blunting the new rule, NAHC had long ago built a strong coalition among consumer and senior citizens organizations. NAHC was the first provider based organization admitted to be part of the consumer based Leadership Council on Aging Organizations (LCAO).

We have been meeting with some 70 members of LCAO who have rallied to our support.  For example, AARP in their August 26, 2013 comments to the “rebasing” rules indicated their support:  “AARP is concerned about the potential impact of the reduced HH PPS payments on Medicare beneficiary access to home health services and on the quality of these services. Home health services are of tremendous importance to Medicare beneficiaries since these services help beneficiaries stay in their homes and avoid more expense skilled nursing facility care. These services can also help beneficiaries avoid hospital admissions or re-admissions and visits to emergency departments, all of which have significant implications for Medicare expenditures.”

Eighth, we have worked together hosting joint press conferences, issuing joint press releases, and educating members of Congress and their staff.  We have joined together in educational meetings, such as those hosted by NAHC for Senators Ron Wyden, Dick Durbin the Deputy Majority Leader, John Cornyn, the Deputy Minority Leader and Pat Roberts.

Ninth, NAHC has utilized its Home Healthcare Nurses Association to energize home care nurses to take action in opposition to the new proposed rules. The top 50 nurses, one from each state, were selected.  Ten finalists were selected.  The stories of these heroic nurses which involved their caring for patients were published in a recent issue of CARING Magazine.

Tenth, our mantra is, “It is all about the patients.”  Through our Members and State Association members, we have been collecting stories of patients and their families. The more we can make the case of how important home care is in their lives, the more successful we shall be in getting Congress to reject the proposed rule.  Letters are being circulated by our friends soliciting signatures of members of Congress.  We shall press on until we have the majority of the House and Senate that signs onto this crusade for basic fairness.  Another goal is for us to look back years from now and remember the actions that we took together to avoid the attempted dismantling of the Medicare home health benefit. We have been here before.  We won then and we intend to win this time as well because we know that our cause is just.

For more information on CMS’ flawed rebasing proposal – as well as resources for home health and hospice advocates – please visit NAHC’s Legislative Action Network

From the NAHC Report article 

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“2 Midnights” Rule: What it Means for Home Health Agencies?

 

The Centers for Medicare & Medicaid Services released its controversial “2 midnights” rule in the 2014 Medicare Inpatient Prospective Payment System (IPPS) final rule.

Under the “2 midnights” rule CMS has set both a benchmark and a presumption for when an inpatient satay would be considered appropriate.  If the inpatient stays spans two midnights, CMS will presume that the stay is reasonable and necessary. In addition, admitting clinicians can use the “2 midnight stay” as a benchmark in determining when it is appropriate to admit a patient as an inpatient rather than keeping the patient in an outpatient status in an observation unit.

With this provision, CMS intends to decrease the number of extended observation stays, while decreasing the number of short inpatient stays (less than 2 midnights) billed under Part A that should be billed under Part B as outpatient services. Extended observation stays have a negative impact on beneficiaries since they require a 20 % co-pay for the service and do not count towards the 3 inpatient day stay required for Medicare coverage skilled nursing facility (SNF) admissions. Payments to hospitals for inpatient services provided under Part A that should have been provided as outpatient services billed to Part B are considered Medicare overpayments to the hospital.

CMS will permit physicians to apply the time a patient spends receiving outpatient services, such as an observation unit, to count towards the “2 midnights” stay when considering whether to continue services as an inpatient. 

“…we expect that the decision to admit the beneficiary should be based on the cumulative time spent at the hospital beginning with the initial outpatient service. In other words, if the physician makes the decision to admit after the beneficiary arrived at the hospital and began receiving services, he or she should consider the time already spent receiving those services in estimating the beneficiary’s total expected length of stay. For example, if the beneficiary has already passed 1 midnight as an outpatient observation patient or in routine recovery following outpatient surgery, the physician should consider the 2 midnight benchmark met if he or she expects the beneficiary to require an additional midnight in the hospital.”

 However, the count for a formal inpatient stay begins with the physician’s order for an inpatient admission, and does not include time the patient spent receiving outpatient services. Therefore, only the time the patient actually spends as an inpatient will count towards the 3 day inpatient stay requirement for a SNF admission. 

“We reiterate that the physician order, the remaining elements of the physician certification, and formal inpatient admission remain the mandated means of inpatient admission. While outpatient time may be accounted for in application of the 2-midnight benchmark, it may not be retroactively included as inpatient care for skilled nursing care eligibility or other benefit purposes. Inpatient status begins with the admission based on a physician order.”

CMS will instruct medical reviewers to not focus on inpatient admissions that span greater than two midnights, since these stays will be presumed to be appropriate.  Inpatient stays that span are just two midnights will likely be reviewed to ensure appropriateness of care and that hospitals are not gaming the system. Medical review will be more intensive on claims with inpatient stays that span 1 or less midnights to evaluate whether the services are appropriate to be billed as inpatient services under Part A.

If an inpatient stay that has been billed as Part A is determined that it should have been under Part B, claims adjustment will be made and the hospital will receive a lower reimbursement rate for the care, in addition to having to collect any co-payments due from the Medicare beneficiary.

So what does all this mean for home health agencies? Well, a lot will depend on how hospitals respond to the “2 midnights” provision and the strategies they develop. A hospital that has a high number of short inpatient stays might adjust their admission policy to increase their observation stays.  Conversely, a hospital that has a high number of lengthy observation stays will want to review their admission policies to increase the number of patients that are treated as inpatients.   

If hospitals have shorter observation stays there will likely be less outpatient physical therapy (PT), occupational therapy (OT), and Speech Language Pathology (SLP) services provided by hospitals that fall under home health consolidated billing rules. In other words,  therapy that was provide as an outpatient would now be provided as an inpatient, the hospital claims will process and agencies will not be pressured  to reimburse the hospital for denied therapy services. 

On the other hand, if a hospital increases observation unit admissions, agencies could see more bundled therapy being provided. However, even though the observation stays might be more frequent, the length of the stays will be short in duration. Further, agencies are not required to reimburse the facility for bundled therapy if there is no arrangement with the facility to provide the service.

For hospital inpatient claims that are denied under Part A and billed to Part B, CMS, in the final rule, agreed that PT, OT, and SLP services could be billed as an Inpatient–Part B claim. The National Association for Home Care & Hospice is waiting to hear from CMS regarding whether therapy billed on an Inpatient–Part B claim will paid if the patient is under a  home health POC or will the hospital claim be edited against the  home health agency’s claim and be denied?   

Another outstanding question is how agencies are to treat hospital transfers for the purpose of completing the OASIS. Regardless of how hospitals react to the “2 midnights rule”, it is expected that there will be an increase in the number of patients that are initially admitted to outpatient observation that will be admitted as inpatients during the hospital stay. Agencies are required to complete the Transfer and Resumption of Care (ROC) OASIS whenever a patient is a hospitalized for 24 hours or more, for reasons other than diagnostic testing. 

Agencies will most likely be required to complete the transfer/ROC OASIS if the patient’s status is changed from observation to inpatient.  In addition, a transfer/ROC OASIS is only required if the inpatient status is greater 24 hours. Tracking the status of these patients could prove to be a challenge for agencies. Currently, the majority of patients admitted to observation units remain in observation until they are discharged from the facility.

Click here  to view the final IPPS rule and to learn more about the “2 midnights” provision.  

From the NAHC Report article 

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National ICD-10 Fall Survey: Home Health Industry Readiness

 

If you haven’t taken the survey, please take the time to do so now. Data collection ends in just one week.

Did you know that CMS expects ICD-10 to double the average national denial rate to 10%? It's usually just 6%. The government knows that most agencies are utterly unprepared, but just how bad is it?

Hundreds of your peers in the industry have taken the survey. We need to hear your voice, too. Knowing where your agency stands will help us assess industry-wide readiness, and give us the data to aid and lobby for your specific concerns.

DecisionHealth and the National Association of Home Care & Hospice are collecting data for the biggest and most comprehensive ICD-10 readiness survey of home health agencies.

Take the National Home Health ICD-10 Fall Readiness Survey now so that the entire industry can understand the scope of ICD-10's impact and so you can benchmark your readiness against an accurate national picture.

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Government Shutdown Affects Homecare Agencies Seeking CHAP Accreditation

 


I'm writing to alert you of recent changes at CMS related to the government shutdown and their efforts to combat fraud and abuse that may affect organizations seeking accreditation with deemed status.

Although Medicare payments to providers are expected to continue during the government shutdown, delays in payments are possible depending on how long CMS staff or contractors are affected.

However, because the CMS Regional Offices (RO) are closed until further notice, there may be a delay in the CHAP accreditation process for organizations seeking deemed status. As part of the accreditation process, after a site visit, CHAP submits all findings and a recommendation for deeming to the CMS RO. The RO then makes the final determination for Medicare Certification. Only after the CMS RO accepts CHAP's recommendation is an organization accepted into the Medicare program.  

Due to the shutdown, initial applicants seeking deemed status may encounter a delay in receiving approval from the RO to participate in the Medicare program as well as being issued a CMS Certification Number (CCN). Because CMS RO personnel are not permitted to work, CHAP recommendations cannot be processed until the shutdown is over.   

For renewing organizations, there may also be a delay in the certification process. Home care organizations who have recently been surveyed or are scheduled to be surveyed in the near-term may find that their deeming dates are set to expire before CMS Regional Office personnel return to work, and can process CHAP's recommendation for those surveys. CHAP is seeking clarification from CMS so that we may provide guidance to the affected organizations.

CMS has provided guidance on activities that are and are not supported during the shutdown. A summary of this information is available on the CHAP website Breaking News Alerts page. We will continue to provide information and guidance regarding the shutdown as it is available.

Additionally, CHAP is seeing an increased number of Condition level findings and focus visits for both initial and renewing organizations. As a result of the Office of Inspector General (OIG) and CMS efforts to combat fraud and abuse, CMS has recently provided CHAP guidance to more strictly interpret the Conditions of Participation, as it relates to areas such as the Professional Advisory Committee, staff competencies and the plan of care. It is important that all organizations seeking accreditation with deemed status visit the CHAP Breaking News Alerts page and review compliance strategies to avoid frequently cited Standard and Condition level findings in these areas.

CMS has also provided additional guidance for organizations affected by the recent CMS moratoria for new Home Health providers in Illinois and Florida.  This information and frequently asked questions (FAQ) can also be found on the Breaking Alerts page on the CHAP website.

We will continue to update the Breaking News Alerts page as additional information is available. Please make sure you are subscribed to the CHAP eNews Weekly and please forward this email to anyone in your organization involved in the CHAP accreditation process.

As always, should you have any questions, please contact your Customer Relations Representative or Regional Director of Professional Services.

Thank you for your continued commitment to demonstrating quality through CHAP accreditation during this challenging time for home health and hospice providers.

A message from Barbara Muntz, RN, MTS, Senior Vice President of Accreditation

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Home Health Claims to Identify Certifying Physician who Signs the POC

 

The Centers for Medicare & Medicaid Service (CMS) has issued Change Request 8441 which instructs home health agencies to report the NPI and name of the physician who certifies the patient for home health services. The Change Request  also requires home health agencies to report the NPI and name of the physician who signs the POC.

In most instances, the certifying physician will be the same physician who signs the plan of care. However, in instances where the physician who follows the patient in an acute/post acute care facility is physician who completes the F2F encounter document and certifies the patient, the NPI and name of the certifying physician will be different than the physician who signs the POC.

CMS is requiring that the NPI and name of the certifying physician and the physician who signs the POC be reported on the claim even if they are the same physician. Therefore, both the attending physician and the other physician fields will be required to be completed on all home health claims on or after the July 1, 2014 effective date.

The Change Request makes the effective date for claims with dates of service on or after July 1, 2014. The National Association for Home Care & Hospice will be requesting CMS to apply the   effective date to episodes that begin on or after July 1, 2014, rather than dates of service.

To view Change Request 8441, please click here.

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HITECH compliance delayed and HHS updates privacy practices

 

The Office for Civil Rights and Office of the National Coordinator for Health Information Technology have collaborated to develop model Notices of Privacy Practices for health care providers and health plans to use to communicate with their patients and plan members.

The HIPAA Privacy Rule gives individuals a fundamental right to be informed of the privacy practices of health plans and health care providers, as well as to be informed of their privacy rights with respect to their personal health information. Health plans and covered health care providers are required to develop and distribute a notice that provides a clear, user friendly explanation of these rights and practices.

Many entities have asked for additional guidance on how to create a clear, accessible notice that their patients or plan members can understand.  In response, OCR and ONC have provided separate models for health plans and health care providers. 

The three options are:

  • Notice in the form of a booklet;
  • A layered notice that presents a summary of the information on the first page, followed by the full content on the following pages;
  • A notice with the design elements found in the booklet, but formatted for full page presentation.
  • A text only version of the notice.

The models reflect the regulatory changes of the Omnibus Rule and can serve as the baseline for covered entities working to come into compliance with the new requirements.  In particular, the models highlight the new patient right to access their electronic information held in an electronic health record, if their provider has an EHR in their practice.  Covered entities may use these models by entering their specific information into the model and then printing for distribution and posting on their websites.

  • Booklet
  • Layered Notice
  • Full Page
  • Text Only
  • Questions and Instructions

For more information about the HIPAA Privacy Rule and the Notice requirements, see: http://www.hhs.gov/ocr/privacy/hipaa/understanding/coveredentities/notice.html

  • A covered entity must make its notice available to any person who asks for it.
  • A covered entity must prominently post and make available its notice on any web site it maintains that provides information about its customer services or benefits.
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NPP Provider Files -

NPP Health Plan Files -

Instructions - 

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