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CMS is delaying the effective date of its January 13, 2017 final home health agency (HHA) conditions of participation (CoP) rule for six months, until January 13, 2018. While CMS is not making any other substantive changes to the rule’s requirements., the agency is making two other conforming date changes:  (1) CMS is giving HHAs…

As previously reported, in January 2017 the Obama Administration finalized major changes to the conditions of participation (CoPs) that home health agencies (HHAs) must meet to participate in Medicare and Medicaid. The rule is currently scheduled to go into effect July 13, 2017, except that the requirement to implement data-driven performance improvement projects is…

CMS has announced that it is “pausing” its Pre-Claim Review demonstration in Illinois for at least 30 days, effective April 1, 2017, and it is not expanding the demonstration to Florida in April as previously planned. During this pause period, Medicare contractors will not accept additional pre-claim review requests; instead, home health claims will be…

The Medicare Payment Advisory Commission (MedPAC) has released recommendations to Congress regarding how Medicare fee-for-service payment system rates should be adjusted in 2018. One of the focus areas for MedPAC is post-acute care (PAC), which includes skilled nursing facility (SNF), home health agency (HHA), inpatient rehabilitation facility (IRF), and long-term care hospital (LTCH) services.  According to MedPAC, the “unnecessarily high level of spending and the inequity of payments across different types of patients” necessitate changes to both payment levels and overall system design.  MedPAC therefore reiterates its previous recommendation for a uniform Medicare PAC prospective payment system (PPS) that bases payments on patient characteristics; MedPAC believes that transition to the PAC PPS could begin as early as 2021. In the meantime, MedPAC recommends that Congress:
Continue Reading Post-Acute Care Providers Targeted for Cuts in MedPAC’s Latest Report to Congress

CMS has finalized extensive changes to the conditions of participation (CoPs) that home health agencies (HHAs) must meet to participate in the Medicare and Medicaid programs. The rule is intended to provide HHAs with enhanced flexibility while focusing on “a patient-centered, data-driven, outcome-oriented process that promotes high quality patient care at all times for all…

The Centers for Medicare & Medicaid Services (CMS) is extending for six months its current moratoria on the Medicare, Medicaid, and Children’s Health Insurance Program (CHIP) enrollment of new nonemergency ground ambulance suppliers and home health agencies (HHAs) in selected states, effective January 27, 2017.  The temporary moratoria on new HHA enrollment (including new subunits …

CMS has announced a number of changes to its temporary Medicare enrollment moratoria for certain provider types in select geographic areas as a mechanism to address fraud, waste, and abuse. First, CMS is extending for six months and expanding statewide its current moratoria on the enrollment of new Medicare Part B nonemergency ground ambulance suppliers in New Jersey, Pennsylvania, and Texas, and enrollment of new Medicare home health agencies (HHAs) in Florida, Illinois, Michigan, and Texas. CMS states that the statewide expansion is intended to address situations in which providers circumvent a moratorium by enrolling in counties outside a moratorium and servicing beneficiaries within the moratorium area. Second, CMS is expanding these moratoria to Medicaid and Children’s Health Insurance Program (CHIP) enrollment. Third, CMS is lifting its current temporary moratoria on Part B emergency ground ambulance suppliers. These policies are effective July 29, 2016.
Continue Reading CMS Announces Changes to HHA/Ambulance Supplier Enrollment Moratoria, New Exception Process Demo

On June 22, 2016, the Department of Health and Human Services Office of Inspector General (“OIG”) issued a comprehensive report detailing its nationwide analysis of common characteristics in home health fraud cases. In tandem with this report, the OIG issued an Alert on improper arrangements and conduct by and among home health agencies (“HHAs”) and physicians. Essentially, the OIG has broadcast a warning shot—it will increase its already aggressive prosecution of home health services fraud.

The Centers for Medicare & Medicaid Services (“CMS”) has also stepped up its own efforts to combat health care fraud. Specifically, the agency announced that it will implement a pre-claim review demonstration for HHAs in five states — Illinois, Florida, Texas, Michigan, and Massachusetts — identified as particularly susceptible to home health services fraud. This pre-claim review demonstration mandates that HHAs seeking Medicare reimbursement for home health services submit currently-mandated documentation to the Medicare Administrative Contractor (“MAC”) earlier in the claims payment process.  Although HHAs need not wait for a determination prior to furnishing services, the documentation is intended to determine if the service level complies with Medicare coverage requirements. CMS intends this review process to aid investigative and enforcement efforts by both CMS and OIG.Continue Reading OIG, CMS Focus New Scrutiny on Home Health Industry: Additional Investigative and Enforcement Activity Likely to Follow

CMS has released its proposed rule to update the Medicare home health prospective payment system (HH PPS) for 2017. CMS estimates that the policies in the proposed rule would reduce overall Medicare payments to home health agencies (HHAs) by $180 million (1.0%) in 2017 compared to 2016 payments. This projected decrease reflects a 2.3% home health payment update percentage (derived from a 2.8% market basket update minus a 0.5% multifactor productivity adjustment), that is more than offset by (i) a proposed 0.97% reduction to account for nominal case-mix coding intensity growth, and (ii) a -2.3% rebasing adjustment (the final year of a four-year phase-in). CMS also proposes changes to its calculation of outlier payments that would decrease payments by an estimated 0.1%. The proposed CY 2017 national, standardized 60-day episode payment rate would be $2,936.68; the rate for an HHA that does not submit the required quality data would be reduced by 2 percentage points to $$2,879.27. The proposed rule also would recalibrate HH PPS case-mix weights and update the home health wage index using more current hospital wage data.
Continue Reading CMS Proposes CY 2017 Update to Medicare Home Health PPS Rates

CMS has announced a new three-year Medicare “pre-claim review” demonstration for home health services in five states — Illinois, Florida, Texas, Michigan, and Massachusetts  — with “high incidences of fraud and improper payments for these services.”  The pre-claim review demonstration requires currently-mandated documentation to be furnished to the Medicare Administrative Contractor (MAC) earlier in the claims payment process.  The initiative does not require the home health agencies (HHAs) to wait for a determination prior to furnishing services, however, nor does it modify the scope of the Medicare home health services benefit.  CMS expects this initiative to “bolster the efforts that CMS and its partners have taken in implementing a series of anti-fraud initiatives in these states,” such as the use of temporary moratoria on the enrollment of new home health providers in selected geographic areas.
Continue Reading CMS Announces Pre-Claim Review Demonstration for Medicare Home Health Services

The Medicare Payment Advisory Commission (MedPAC) has released its annual recommendations to Congress on Medicare policies, including Medicare fee-for-service (FFS) payment updates and a status report on the Medicare Advantage and Medicare Part D programs.  The following are highlights of the recommendations for 2017 (some of which were recommended previously):
Continue Reading MedPAC Releases Annual Recommendations to Congress on Medicare Policy

CMS published a final rule on February 2, 2016 to implement statutory requirements regarding documentation of face-to-face encounters with Medicaid beneficiaries within certain timeframes as a condition of Medicaid coverage of home health services and certain medical equipment.  The rule also makes several clarifications to Medicaid policies related to coverage of home health services, including medical supplies furnished under this benefit.
Continue Reading CMS Finalizes Medicaid Home Health and Medical Equipment Policy Changes, Including Face-to-Face Encounter Requirements

CMS published a notice February 2, 2016 announcing an additional 6-month extension of its current temporary Medicare enrollment moratoria for new ground ambulance suppliers and home health agencies (HHAs), subunits, and branch locations in designated metropolitan areas.  The moratoria, which also apply to enrollment in Medicaid and the Children’s Health Insurance Program, apply to:

  • New

…

On February 4, 2016, CMS is hosting a provider call on Improving Medicare Post-Acute Care Transformation (IMPACT) Act requirements regarding the reporting of standardized patient assessment data by post-acute care (PAC) providers (skilled nursing facilities, home health agencies, inpatient rehabilitation facilities, and long-term care hospitals). During this call, CMS and the Office of the National…

On December 15, 2015, Congressional leaders released sweeping spending and tax proposals, including a number of provisions impacting Medicare and the Affordable Care Act (ACA). The legislation is being considered on a fast track; the House approved the tax component of the package today, and it is scheduled to vote on the appropriations bill tomorrow, with Senate action expected shortly thereafter. Medicare/Medicaid provisions of the Consolidated Appropriations Act of 2016, which are intended to offset the costs of reauthorizing the World Trade Center Health Program, include the following:
Continue Reading Congressional Leaders Announce Spending/Tax Deal with Medicare and ACA Provisions; House Approves Tax Package

CMS published its final CY 2016 Medicare Home Health Prospective Payment System (PPS) rule on November 5, 2015.  CMS projects that overall Medicare payments to home health agencies (HHAs) will be reduced by 1.4% — or $260 million – in CY 2016 compared to 2015 levels as a result of the policies finalized in the rule. The final 2016 home health payment update is 1.9%, reflecting a 2.3% home health market basket update that is reduced by a 0.4% multifactor productivity adjustment. This update is offset, however, by: (i) a 0.97% reduction to account for estimated case-mix growth unrelated to increases in patient acuity (this “nominal case-mix growth” adjustment also will be applied in CYs 2017 and 2018), and (ii) a -2.4% rebasing adjustment (the third year of a four-year phase-in). The final CY 2016 national, standardized 60-day episode payment rate is $2,965.12; the rate for an HHA that does not submit required quality data is reduced by 2 percentage points to $2,906.92. 
Continue Reading Medicare Home Health PPS Payments to Fall by $260 Million in 2016