Answering the Questions: What about the HH FTF and Hospice Attending NPI on Election Forms?
April 25, 2015
Home Health: FTF Manual Updates
FINALLY! Chapter 7 of the Medicare benefit Policy Manual has been updated with the new therapy and face to face requirements! This includes verbiage to support our "3 step process" discussed in last month's newsletter. Home Health agencies CAN and should provide additional information to corroborate the physician's visit note regarding Homebound Status and Medical Necessity. The manual can be found at: http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R208BP.pdf
In 188.8.131.52, it states: "Information from the HHA, such as the initial and/or comprehensive assessment of the patient required per 42 CFR 484.55, can be incorporated into the certifying physician’s medical record for the patient and used to support the patient’s homebound status and need for skilled care. However, this information must be corroborated by other medical record entries in the certifying physician’s and/or the acute/post-acute care facility’s medical record for the patient."
CMS clarified in CR9112, home health agencies are required to: Maintain documentation by the physician who ordered/certified the home health services and the NPI of the physician for 7 years from the date of service, and Upon the request of CMS or a Medicare contractor, provide access to that documentation. So, what does this mean? Be sure that you request the documentation of the visit note for the "in person", or "face to face" encounter that the patient and physician or NP/PA had to ensure payment.
Seeing STARS? Your agency can review your preliminary "STAR rating" at this time, and ensure it is correct prior to the publication in July. These will be updated quarterly, and in January 2016 will include HHCAHPS data in the computation. Certified HHAs with 20 or more complete quality episodes (SOC/ROC to TRF/DC OASIS) will be included in the STAR ratings, which are based on the following nine measures:
1. Timely Initiation of Care 2. Drug Education on all Medications Provided to Patient/Caregiver 3. Influenza Immunization Received for Current Flu Season
4. Improvement in Ambulation 5. Improvement in Bed Transferring 6. Improvement in Bathing 7. Improvement in Pain Interfering With Activity 8. Improvement in Shortness of Breath 9. Acute Care Hospitalization
Hospice: Election Statement Controversy and CAHPS Deadlines
The attending physician's NPI is NOT mandated to be on the Election Statement but rather only the Notice of Election (NOE) submitted through FISS to CMS to notify Medicare of the Election. CMS will be making that correction to CR9114 soon.
New PEPPER reports are out! This is a great way to see where your agency is at, compared to the rest of the nation. If you are "outstanding" in any area- review the "whys". Recently, I worked with hospice who noted on their PEPPER report that they were extremely high on their percentage of patients being cared for in the SNF. This could be a "red flag" and bring about a provider specific probe. Upon research, it was a simple billing error and mis-understanding about when to use the code for care in a Nursing facility vs a SNF, and this was corrected immediately. Other times, we may see something a little more complex- such as our length of stays as an outlier-- which we will want to review as an IDT with our Medical director to ensure our patients are still appropriate for hospice, and we have good documentation and decisions at the start of care, as well as at each recertification. For more information, go to: PEPPERresources.org
May 1st: Deadline to submit completed Hospice CAHPS Survey vendor authorization form to CMS.