Thursday, August 1, 2013

More About Proposed Payment Changes
for Medicare Home Health Agencies

Earlier this week, I discussed CMS’ proposal to rebase the payment rates for home health services. Here I will discuss CMS’ other proposed changes to home health payment.

Coding Changes
According to CMS, there are several ICD-9 codes that are resulting in “inaccurate overpayments” through their inclusion in the home health prospective payment system. CMS is suggesting removal of two specific ICD-9-CM codes:

(1) those that are too acute for the home health setting; and
(2) diagnosis codes for health conditions that do not require home health intervention, do not impact home health plan of care, and/or would not result in the use of additional home health resources.

ICD-10-CM codes will be included in the payment system starting in October 2014.

Quality Reporting
CMS’ proposal seeks to add two claims-based quality measures:

(1)  re-hospitalization during the first thirty (30) days of home health stay; and
(2)  ER use without readmission during the first thirty (30) days of home health stay.

These measures will allow home health agencies to make reduction of hospital readmissions a high priority.

Cost Allocations for Home Health Agency Surveys
Another proposed home health payment change is that Department of Medicaid Services’ responsibilities for home health surveys would be explicitly recognized in the State Medicaid Plan. Additionally, CMS seeks to use the cost allocation methodology used for dually-certified nursing homes, assigning Medicare and Medicaid 50% of the actual costs.

Home health providers and stakeholders should review the proposed rule and its effects on home health services. Remember that comments are due by August 26, 2013.

Emily M. Hord
ehord@mmlk.com
McBrayer, McGinnis, Leslie & Kirkland, PLLC
Lexington, Kentucky

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