On February 28th CMS ended the month hosting their regular Home Health Open Door Forum with some very notable updates to the home care industry. With little fanfare and during the Q&A portion, CMS responded to a question regarding the timing of the new OASIS forms as OASIS-D!
We had pondered this last summer and expected that this naming convention would be necessary given the dramatic changes to the OASIS form set. OASIS-D will eliminate 33 OASIS items (235 fewer data elements collected at specific time points). At the same time, there will be new Self Care, Mobility, Functional Abilities, and Falls codes added, representing 5 new OASIS items with 109 new data elements also collected at different time points. Unfortunately, the draft version of the form will not be made available until July 2018 with final approval projected for November 2018. This will likely add delays in training of your staffs using the new form sets.
Another notable update had to do with an adjustment to the logic for the Timely Initiation of Care process measure, first mentioned in the Final Rule on the Conditions of Participation (CoPs) for Home Health on January 13th, 2017. Retroactive back to January 13th 2018 for Resumptions of Care (ROC), this measure will now be met if the first visit is equal or prior to the Physician-ordered Start of Care Date (M0102). Under the prior calculation, visiting within two days from the hospital discharge was required in order for the measure to be met, regardless of the date the physician ordered.
Also announced in this meeting were corrections to the measure calculation for the outcome: “Percent of Residents/Patients with Pressure Ulcers that Are New or Worsened”. Denominator counts on the Review and Correct reports were calculated incorrectly, causing agencies to see much higher scores than anticipated. The corrected skip logic for this measure will be included in the confidential feedback reports so that agencies can see their current rates in advance of the CY 2019 Home Health Compare reporting of this measure.
Another announcement had to do with the reinstatement of payments for the rural add-on, which was included in the February 6th Continuing Resolution (CR) and will be effective as of April 2nd at 3%, the same as in CY 2017. The good news for rural providers is that they will not have to worry about retroactively billing since Medicare Administrative Contractors (MACs) will be responsible for reprocessing these claims back to January 1st, 2018.
And, last but not least, perhaps one of the most important updates we learned in February was related to the Home Health Groupings Model (HHGM), also included in the CR. Although the details were limited, beginning in CY 2020, CMS will be required to implement payment reforms to include:
- 30-day units of payment
- Budget neutrality
- Eliminating therapy visits from the case-mix calculation
- Adjustments for behavioral adjustments
A Technical Expert Panel (TEP) met on February 1st regarding HHGM, and we have some sense of CMS’ concerns with the release of the TEP notes. Please see below for information on our upcoming webinar on HHGM.
Yes, I think you could say that February was a busy news month.