The second round of probe-and-educate reviews is getting underway, with home health agencies in Florida the first to be affected.
The first additional document requests (ADRs) will be sent to Florida agencies on or around Dec. 27, according to Medicare Administrative Contractor (MAC) Palmetto GBA. As in the first round of probe-and-educate, the MAC will do pre-payment review of a sample of five claims.
Agencies that had five claims reviewed in the first round and had one or zero claim in error will be excluded from this round. All other agencies should expect to receive a probe-and-educate request, Lynn Labarta, founder and CEO of Imark Consulting, told Home Health Care News.
CMS has not specified which states will follow Florida in this second probe-and-educate round, although Texas is a likely possibility, Labarta added.
As they did in the first round, the MAC reviewers will be looking at the claims to ensure that agencies are in compliance with Medicare eligibility and payment requirements.
In Florida, for claims that are denied or partially denied after being reviewed, the MAC auditor will contact the home health agency by phone on the day that the review takes place, according to Palmetto.
“If during a call with a nurse reviewer about a denied service, it is determined the ADR response was incorrectly denied, the provider does not need to request a redetermination. The review contractor will reopen the claim and make the change to the claim,” a Palmetto GBA spokesperson told Home Health Care News. “A corrected decision letter will be sent to reflect the change. However, if it was determined during that call that the claim was denied because something was missing or incorrect with the documentation, the provider will need to request a redetermination.”
Depending on the number of errors detected, the MAC will take different follow-up actions, as outlined in a Dec. 16 Medicare Learning Network memorandum from the Centers for Medicare & Medicaid Services (CMS):
The MACs’ follow-up letters for denied claims were pretty specific in the first round, Labarta said, and the majority of issues for Imark clients involved face-to-face.
Flagging the face-to-face documents and other important documents, such as specific orders for therapy and progress notes, is one best practice for agencies in submitting their ADRs, according to Labarta.
It’s also a good idea to include an outline so that the reviewers know where in the submission to look for various items.
“Sometimes the reviewers miss documentation they’re looking for,” Labarta said. “An outline helps, so the reviewer doesn’t turn around and say, the face-to-face isn’t there.”
Another tip she shared: request a return receipt if mailing the documents to the MAC, rather than submitting them electronically.
While agencies may have a relatively short timeframe to respond to the document requests, and taking these extra steps adds to the burden, it is worthwhile to avoid being dinged for errors and having to do a second-level appeal in order to get paid, she emphasized.
Written by Tim Mullaney
Medicaid currently pays for personal care services through a patchwork of different waivers and other programs, with varying standards for ensuring that beneficiaries are kept safe and billing is above-board. This needs to change, according to a newly released report from the federal Government Accountability Office (GAO).
To compile its report, the GAO evaluated Medicaid-funded personal care in California, Maryland, Oregon, and Texas.
These states all have some safeguards in place to be sure that beneficiaries are receiving quality care and that billing practices are proper, the agency determined. However, there is variation among the states and sometimes within various programs in a single state.
“For example, to track attendants’ work time, two states required beneficiaries to sign paper timesheets for the attendants, and two states used electronic visit verification timekeeping systems for some or all programs,” the agency stated in a summary of its findings.
This lack of harmonization makes it more challenging for the federal government and states to monitor and manage home care, which is seeing a surge in demand, GAO noted.
The Centers for Medicare & Medicaid Services (CMS) can and should be doing more, the report recommended. For one, it should be collecting and analyzing information that states are required to gather for certain programs, such as the Community First Choice program. Also, CMS should take the steps that it can to harmonize requirements across these different Medicaid personal care services programs.
CMS concurred with the recommendations and noted that it already has taken some steps to achieve them. For example, it published a request for information in the Federal Register last month, seeking input on Medicaid home- and community-based services programs, including steps to ensure program integrity and beneficiary health.
Written by Tim Mullaney
Home Health Care News had a record-breaking year for readers and viewership. With all that went on in 2016, we kept readers up to date on breaking news across the industry.
From the implementation of a disruptive, new demonstration to the surprising election of President-elect Trump, here’s our list of the top posts of the year:
Despite strong pushback from the home health industry and lawmakers, the Centers for Medicare & Medicaid Services (CMS) moved forward with a preauthorization requirement—the Pre-Claim Review Demonstration (PCRD).
2. October 21—Top 10 Largest Home Health Providers
Providers across the spectrum tapped into the home health market to expand their services across multiple facets of care, as evidenced by LexisNexis’ 2015 rankings of the leading home health agencies in the United States. The report ranks Medicare-certified home health providers by national market share and aims to map the market landscape for potential merger and acquisition activity.
3. November 7—Kindred to Exit the Skilled Nursing Facility Business
Kindred Healthcare (NYSE: KND), the nation’s largest home health care and hospice provider, has bet higher on this side of its business, after announcing it would entirely cease to own or operate skilled nursing facilities (SNFs). Upon Kindred’s exit from the SNF business, roughly half of its earnings will come from the home health side of the company.
Federal authorities turned up the heat even more in their battle against Medicare home health fraud. The top targets: More than 500 home health agencies and 4,500 physicians identified as having suspicious practices as compared with most providers nationally.
U.S. Senators Marco Rubio (R-FL) and Bill Nelson (D-FL) called for a controversial home health pre-claim review demonstration program to be delayed in Florida, and they reiterated concerns over how pre-claim threatens providers and patients.
The Centers for Medicare & Medicaid Services (CMS) issued its final rule requiring that physicians conduct and record face-to-face visits with patients in order to receive Medicaid coverage for home health services and medical equipment, similar to regulations already in place for Medicare.
One of the nation’s largest home health care providers has entered into an agreement to acquire a controlling interest in the home health and hospice assets of one of the nation’s largest hospital companies. The result will be the biggest hospital-home health joint venture in the nation, the companies announced Monday.
The Medicare Strike Force has engaged in a three-day execution of the largest fraudulent billions takedown—that includes home health agencies—in the group’s history. Approximately 300 people were charged across 36 federal districts for their alleged participation in a variety of schemes that involved more than $900 million in fraudulent health care billings, according to Attorney General Loretta Lynch.
9. November 9—Home Health Industry Ponders Meaning of Trump Victory
In a year full of new challenges for the home health and home care industry, one outstanding uncertainty has finally been put to rest—Donald Trump has won the U.S. presidency. While America’s next president is decided, the impact to the home health industry and the larger health care system is still largely unknown.
10. September 20—Pre-Claim Review Delayed Ahead of Florida Start Date
Amid reports that the rollout of the Pre-Claim Review Demonstration (PCRD) in Illinois led to a “complete mess,” the Centers for Medicare & Medicaid Services (CMS) delayed the start date in Florida by at least 30 days, the agency announced.
Written by Amy Baxter
Soon, families in at least one U.S. state will be able to secretly monitor home health aides and other in-home caregivers using government-owned micro-surveillance cameras.
The new “Safe Care Cam” program was announced Thursday by New Jersey Attorney General Christopher S. Porrino and the state’s Division of Consumer Affairs. The goal of the program? To address New Jersey residents’ rising concern about caregiver abuse.
Specifically, the program makes micro-surveillance cameras available free-of-charge to any New Jersey resident who thinks their loved one is being neglected or abused by home health aides or other in-home caregivers. Families can keep the government-owned micro-surveillance cameras for 30 days at a time, unless families make a reasonable extension request to the Division of Consumer Affairs.
“Anyone who suspects a loved one is being abused by an in-home caregiver should not be left to feel helpless or without recourse,” Porrino said in a statement on the New Jersey Attorney General website. “Cameras don’t lie, and the abuses they’ve revealed are shocking.”
Quality micro-surveillance cameras can cost as much as $300, and many families can’t afford them, Porrino said.
“We hope that the Safe Care Cam program will provide peace of mind for family members, while at the same time serving as a strong deterrent and reminder to unscrupulous care providers that we will prosecute their cases aggressively,” Porrino added.
In the past 10 years, the number of Certified Homemaker-Home Health Aides (CHHAs) eligible to work in the New Jersey has risen from 26,618 to 43,506, according to the AG’s office. The number of CHHAs that have been suspended, revoked or disciplined by the New Jersey State Board of Nursing totaled almost 300 in 2016. The CHHAs’ alleged crimes included criminal sexual contact, assault, stolen identity and theft.
The problem appears to be getting worse in the state. In 2015, almost 200 CHHAs were disciplined; in 2014, almost 140 were disciplined.
Written by Mary Kate Nelson
It’s Christmas time in the city. That’s what we’ve been singing to stay chipper during the short Chicago winter days. Despite temperatures being lower in Chicago than Mars—yes, really—we were sure to keep readers up to date on the latest happenings in the home health industry.
Most notably, we reported that the Pre-Claim Review Demonstration (PCRD) will start in its second state this coming spring and brought readers news about a major acquisition that could be valued as high as $1 billion.
Here in the newsroom, we were calling out girl power, after a new Harvard study found that elderly patients treated by a female doctor in a hospital were likely to have better results after being discharged compared to male counterparts.
CMS Sets Pre-Claim Start Date for Florida—The controversial PCRD will expand into its second state, Florida, on April 1, the Centers for Medicare & Medicaid Services (CMS) announced. The move comes several months after further implementation of the demonstration was put on hold.
CMS Releases Data on Hospice Quality, Home Health Use—CMS published on Friday new updates to two different hospice data sets—one on the thoughts of consumers, and the other on hospice quality measures. CMS also published the second-ever Home Health Agency Public Use File, which includes 2014 data.
Bain Capital Acquires Nation’s Largest Pediatric Home Health Provider—After speculation earlier this year that Epic Health Services could be acquired for as much as $1 billion, a deal has been announced. Epic, a national home health care services and pediatric skilled nursing company, has signed a definitive agreement to be acquired by Bain Capital Private Equity, a global investment firm.
Around the Web
America’s Home Care Agencies: Leading the Way in Promoting Public Health—Marki Flannery, executive vice president and chief of provider operations of the Visiting Nurse Service of New York, pens an essay on how home care continues to play a growing role in the care of the elderly, particularly around flu season.
Three Major Hurdles for Home Care Operations in China—As China’s aging population grows, there are three major hurdles—unclear regulations, lack of trained caregivers and inaccessibility to public funding—to achieving its lofty home care goals, Health Intel Asia reported.
Patients Cared for by Female Doctors Fare Better Than Those Treated By Men—Harvard researchers found that female doctors who care for elderly hospitalized patients were less likely to die or return to the hospital after their discharge, NPR reported.
Written by Amy Baxter
In what has been described as a cruel April Fool’s Day joke, the Centers for Medicare & Medicaid Services (CMS) announced it will be expanding the Pre-claim Review Demonstration (PCRD) to Florida beginning April 1, 2017.
As the controversial program charges ahead to the Sunshine State, providers and industry advocates have prepared, but are still hoping to find a way out. The decision ends a pause that CMS placed on further implementation earlier this year.
Senator Marco Rubio (R-FL), who urged CMS to pause the program earlier this year with Senator Bill Nelson (D-FL), expressed disapointment with the decision.
“We are disappointed with CMS’s decision to move forward and plan to work with the incoming administration to ensure we address fraud in the system while preserving Floridians’ access to quality home health services,” a Rubio spokeperson told Home Health Care News.
There has been some recent good news regarding the program, including higher affirmation rates for pre-claim requests in Illinois, where PCRD has been underway since August 3.
“The Illinois experience has had some positive outcomes,” the National Association for Home Care & Hospice (NAHC) said in a newsletter to its members following CMS’ announcement Monday.
Beyond higher affirmation rates, agencies have started to figure out the PCR processes and can recognize their own documentation weaknesses better, according to NAHC.
However, submitting pre-claim requests has proven to be very time-consuming for agencies, with many dedicating staff to the process full time.
“The Medicare Pre-Claim Review Demonstration has proven to be a costly, burdensome endeavor for Illinois home health care providers,” Bobby Lolley, executive director of the Home Care Association of Florida (HCAF), told Home Health Care News. “In light of federal regulators’ decision to roll out the program in Florida next spring, providers are gearing up to meet this challenge and prove to policymakers once and for all that the patients we serve are eligible for and in need of the high quality, cost effective care that we provide.”
Fortunately, providers in Florida have had time to prepare for the demonstration’s implementation. Thanks to the temporary pause, home health companies in Florida presumably could learn from mistakes coming out of Illinois before they were thrown into the demonstration themselves.
“We have prepared for this,” Andrew Shook, owner of Elite Home Health, told Home Health Care News. “We knew this was coming down the pipeline, and, if it wasn’t this, it would have been the same effort [to deal with] increased audits.”
Elite Home Health is a full service home health organization with multiple locations across Florida.
‘Still a Nightmare’
Despite higher affirmation rates—which reached 87% for pre-claim requests in the program’s 17th week, according to CMS—home health agencies are spending significant time and resources simply executing the submission process. And industry groups have not backed down in their opposition, as not all agencies are experiencing success under the demonstration.
“We are still vehemently opposed to the Pre-Claim Review Demonstration,” the Visiting Nurse Associations of America (VNAA) told HHCN. “While CMS has been able to raise the rate of provisional affirmations, agencies are still struggling with the administrative burden put on them. …This pre-claim review process is still an administrative nightmare.”
NAHC, which recently vowed to file a lawsuit against CMS to put a stop to PCRD, also said it would step up its advocacy efforts, further “aggressively pursuing remedies” for PCRD’s problems. The “vast majority” of improper payments that CMS intends to reduce under PCRD are actually related to issues with the physician certification and face-to-face documentation requirements, NAHC said in a letter to its members.
The Price is Right
While industry groups continue to set their sights on repealing or pausing PCRD, there could be a hands-off solution in the near future in the form of the incoming Trump administration.
Representative Tom Price (R-GA) has been named President-elect Trump’s pick to lead the Department of Health and Human Services (HHS), and he is vehemently opposed to PCRD. With Price in office, a complete dismantle of the demonstration could be on the table.
“Just as I was not surprised [PCRD] came down the pipeline, I would not be surprised if [Price] goes and adds a year of delay or longer,” Shook said. “I’m not going to assume that’s going to happen, but it would not shock me in the least.”
Similarly, NAHC has been bullish that the incoming administration could result in a rollback of regulations.
Written by Amy Baxter
Integrity remains at the heart of ongoing discussions about home health care reimbursements, and rampant fraud could be cause for further payment cuts.
With overpayments remaining high across the home health industry, more payment reductions are called for, as rebasing attempts to bring reimbursement rates in line with costs, members of the Medicare Payment Advisory Commission (MedPAC) said during a recent meeting.
Home health providers should also be worried that MedPAC members think recent reimbursement cuts are too small. For CY2017, Medicare home health payments will be cut $130 million, or 0.7%.
Fraud and Payment Reductions
Medicare spent $18.1 billion on home health services in 2015, with the program providing about 6.6 million episodes to 3.5 million beneficiaries. There were more than 12,300 home health care agencies. The commission has expressed that reimbursement cuts for home health should be steeper.
Medicare has reportedly overpaid for home health services since the prospective payment system was established in 2000, MedPAC concluded at its December meeting.
“The fact that home health can be a high-value service does not justify the excessive overpayments,” Jon B. Christianson, vice chair of MedPAC, said during the meeting.
The commission noted that there have been several regulations and attempts to curb fraud recently, including the Pre-Claim Review Review Demonstration (PCRD). Yet, the problem persists, and efforts like PCRD may not be making much headway to combat the issue.
“There has been significant recent activity on this front, including a moratorium on new provider enrollment and some areas and efforts to implement a pre-claim review process,” Christianson said. “The Secretary and the Attorney General have made a number of efforts to address fraud in this benefit, but many patterns of unusual utilization suggestive of fraud remain.”
Additionally, “geographic variation and utilization” may contribute to fraud throughout the home health benefit, the committee concluded.
Another area that may be ripe for fraud surrounds therapy reimbursement rates, which incentivize agencies to provide higher levels of care for higher reimbursement rates. This trend has contributed to higher average payment per episode in 2015, according to MedPAC.
Eligibility for home health benefit is “poorly defined,” despite a rapid growth in episode volume, the commission noted. This trend is cause for concern, Christianson said, as providers are rewarded for additional service under a fee-for-service model.
There were some bright spots across the industry, such as the fact that 99% of beneficiaries live in an area served by at least one home health agency, and many live in areas served by five or more agencies. The number of home health agencies also remains near its all-time high reached in 2013, despite a drop of 115 agencies in 2015.
Some of the biggest home health care companies also seem to have adequate access to capital, the commission suggested, hailing recent deals by Almost Family (Nasdaq: AFAM) and LHC Group (Nasdaq: LHCG) as prime examples.
Margins for home health agencies were 15.6% in 2015, with a recent CMS audit showing that costs were overstated by 8%, the commission said. These high margins could be cause to continue reducing reimbursement rates. However, industry association the National Association for Home Care & Hospice (NAHC) strongly disagrees, calling MedPAC’s calculations of costs unreliable.
“NAHC has and will continued to oppose MedPAC recommendations on rate reductions as the MedPAC Medicare margin analysis continues to fail the test of reliability,” NAHC stated on its website. “For example MedPAC does not consider all costs when calculating margins.”
Written by Amy Baxter
GreatCall Acquires Healthsense
Connected health company GreatCall Inc. has announced the acquisition of Healthsense, which provides remote monitoring services for seniors. The acquisition will help GreatCall seniors find connected health services in senior living and health care.
“As GreatCall continues to expand in these key markets, Healthsense is a natural fit—with our mission of increasing independence, reducing total cost of care and improving the resident, family and caregiver experience,” David Inns, CEO of GreatCall, said in a press release.”Acquiring Healthsense brings important capabilities in predictive analytics that dovetail with our deep customer knowledge, expands offerings, as well as increases our exposure in senior living and health care.”
Healthsense’s technology uses wireless sensors to monitor seniors’ activities and then establishes patterns based on daily data. This data can be used by caregivers to review if anything is off and could indicate a larger health problem.
“GreatCall is the ideal partner to take the company to the next level,” A.R. Weiler, CEO and president of Healthsense, said in the press release. “We know that older adults want to age independently as long as possible, and the technology and support that GreatCall can provide will allow more of them to achieve this goal.”
Always Best Care Opens New Location
Provider of non medical in-home care, Always Best Care has opened a new franchise location in Minnesota. This location will be the company’s third in Minnesota and will serve the Saint Paul area and surrounding communities, including Saint Croix Valley.
The franchise was opened by Ken and Erica Crawford, both of whom have years of experience applicable for running a franchise location. Ken has worked as a facility manager for a non-profit organization that helps people with disabilities for 25 years. Erica has 15 years of experience in corporate account management.
“We are thrilled to welcome Ken and Erica Crawford to the Always Best Care family,” Jake Brown, president of Always Best Care, said in a press release. “Ken and Erica have strong relationships with area hospitals, social workers, senior communities and resources throughout Saint Croix Valley. The network they have established within the community, coupled with their hands-on management style and passion for quality health care, will translate well into their new business.”
Ken and Erica will also have Erica’s mother Judy Gustafson, who is a retired nurse of 40 years, serve as the company’s care coordinator.
“After working within the health care industry for many years, it became clear to me that additional services were needed in our area,” Ken Crawford said in the press release. “Always Best Care is a leader in senior care, which is one of the reasons why Erica and I are proud to offer its award-winning services to local families in need.”
VNAA Partners With CliftonLarsonAllen
The Visiting Nurse Association of America (VNAA) and professional services firm CliftonLarsonAllen (CLA) will partner together to offer financial leadership, education and guidance for the home-based care industry by expanding VNAA’s Center for Value Based Transformation (CVBT).
“VNAA sought a strong collaborator to expand financial leadership and educational offerings at this critical time in health care delivery transformation,” Tracey Moorhead, president and CEO of VNAA, said in a press release. “CliftonLarsonAllen demonstrated the recognized expertise and experience to support agency leaders as they navigate value-based payment systems. This new alliance will offer tools and resources to help ensure continued growth and success in home-based care.”
Programs developed under this alliance will also help VNAA transform toward value-based health care delivery and payment models, including performance improvement, operational management, clinical program design and financial success models.
“The vision of CLA’s health care practice is to be thought leaders impacting the future of health care,” Mike Slavik, chief industry officer of CLA’s health care practice, said in the press release. “We are excited about the opportunity to collaborate with the VNAA and support its mission of transforming home-based care for providers and populations in the community.”
Suncoast Hospice Forms Strategic Alliance
Suncoast Hospice and its parent company, nonprofit Empath Health, have started a strategic alliance with Tidwell Hospice and its parent company, Stratum Health System. The alliance will be known as Pontus Health, Inc.
The purpose of the alliance is to help with the changing health care landscape and provide insight into best practices, purchasing efficiencies, as well as expanding end-of-life care. In the future, the alliance may add other non-profit, community-based, end-of-life care organizations.
The strategic alliance will not change the day-to-day operations of Suncoast.
Princeton HealthCare To Join University of Pennsylvania Health System
Princeton HealthCare System (PHCS) will become part of the University of Pennsylvania Health System, pending state and federal approval.
Princeton Healthcare operates the University Medical Center of Princeton at Plainsboro and provides rehabilitation, home care and hospice care.
“We are proud of this exciting opportunity to combine Princeton HealthCare’s strong reputation for providing excellent care in the community with Penn Medicine’s strengths as a national leader in complex and specialty care,” Ralph Muller, CEO of Pennsylvania Health System, said in a prepared statement. “Aligning with PHCS will offer new opportunities for Penn Medicine to expand our services in New Jersey, and enable a mutually beneficial relationship for patients by uniting options for close-to-home care with coordinated access to Penn Medicine’s world-class advanced medicine.”
Prior to the final documents, both companies signed a letter of intent last summer to explore the partnership. Princeton sought a partnership with a larger hospital, and Pennsylvania Health System was chosen out of 17 potential partners.
“Affiliating with the University of Pennsylvania Health System represents the best means of assuring that PHCS and its affiliates can continue to fulfill their mission and charitable objectives in the future,” Barry Rabner, CEO of Princeton HealthCare, said. “When this partnership is finalized, members of our community will receive enhanced high-quality care right here, close to home, and they will enjoy the added benefit of easier access to the latest medical breakthroughs, clinical trials, cutting-edge technologies and specialized clinical expertise here and elsewhere in the Penn Medicine system.”
Princeton HealthCare will maintain day-to-day control of operations.
Homecare Homebase Collaboration with Samsung Reaches New High
Software company Homecare Homebase is collaborating with Samsung to bring its software to Samsung Galaxy Tablets.
The partnership began with implementing the Homecare Homebase platform on 10,000 Samsung Galaxy tablets, but has now grown to more than 140,000 tablets in five years.
“We’re focused on growing our presence in the home health and hospice fields to meet increasing market demand,” Scott Pattillo, chief strategy officer at Homecare Homebase, said in a press release. “The solutions we deliver in home health care with Samsung play a pivotal role in empowering medical professionals to provide top-quality care, using Homecare Homebase’s state of the art platform to keep up with today’s increasingly complex health care reporting requirements and regulations.”
The software integration with Samsung tablets is hoping to improve communications for patients and families. The software allows an all-in-one solution to streamline processes like workflow management, revenue management and resource management.
Written by Alana Stramowski
The Centers for Medicare & Medicaid Services (CMS) has issued a final rule creating mandatory bundled payment programs for cardiac conditions, and expanding the scope of an existing bundled payment program for joint replacement episodes.
These bundled payment programs are seen as an opportunity for home health providers, which can help hospitals control costs and quality for the patients involved. But there have been concerns, as well.
Powerful voices in the home health industry—including Kindred Healthcare (NYSE: KND) and the National Association for Home Care & Hospice (NAHC)—have said CMS is moving too aggressively with mandatory programs that have yet to be proven effective.
Incoming Health and Human Services Secretary Tom Price shares these concerns, and has been an outspoken critic of mandatory bundled payment programs. He may halt them soon after the Trump administration takes office in January.
“Expect anything CMS does at the 11th hour to be on a list for Price to consider killing upon confirmation,” Terry Haines, managing director and head of political analysis at Evercore ISI, an economic research firm, told Modern Healthcare.
The current leadership at CMS stands behind the programs. The concept is that hospitals in affected markets would be responsible for all the costs related to episodes of care for certain patients: those who have had heart attacks, bypass surgery, joint replacements, or surgeries to repair hip and femur fractures.
The programs should save money while improving care, according to CMS.
The home health opportunity comes from hospitals being incentivized to work more closely with post-acute providers—and potentially share incentive payments with them.
“As a practicing doctor, I know the importance of hospitals, doctors, nurses and others working together to support a patient from heart attack or surgery all the way through recovery. These bundled payment models support coordinated care and can reward clinicians through the Quality Payment Program,” said Patrick Conway, M.D., CMS acting principal deputy administrator, in a statement issued Tuesday.
Written by Tim Mullaney
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