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Regulatory Compliance

Navigating The Final Rule: Let’s Look At Some Changes And Positives From Home Health Regulation Changes!

Home Health RegulationsWhether you are a brand-new skilled agency or have been in business for decades, the final rule always makes you cringe a little. Home health regulations can be overwhelming when it comes to implementing them. The industry saw many changes in this final rule. Let’s look at some of them. 

Here Are Some Good Things: 

If it seems there isn’t anything good there, then you should take another look.  Here are 5 things that came from proposed home health regulation change in favor of the good guys! 

  • Home Health Gets A Raise: The standard 60-day episode payment increased 2.2%. Neutrality factors included, the average payment per episode is up. 
  • Physician Certification: The plan of care and additional supporting documentation determines eligibility. If signed and dated by the MD containing all necessary elements, then it is sufficient.
  • Recertification: Length of time estimation is eliminated. Good! This is just extra paperwork and time for the agency and the MD.  
  • Telemedicine: The cost associated with remote monitoring can be an admin cost on cost report. It does not mean additional reimbursement. It does not mean substitution for home health visits, but it does mean accounting for the cost. 
  • RAP Payments: RAP payment will continue to exist for established home health agencies. 

Areas Of Concern For The Industry: 

For everything that is positive with the regulations, there are also areas of concern. Here are 3 things with considerable impact: 

  • Patient-Driven Groupings Model: This is a revised HHGM model. It contains the 30-day periods of billing within your 60-day episode. There are 432 payment groups and it eliminates the therapy volume domain. It will consider timing, admission source, 6 clinical groupings, functional level, and co-morbidity adjustments. There are adjustments up to -6.42% based upon LUPAs, coding, and co-morbidities. Number of agencies are anticipated to decrease in certain regions. 
  • Rural-Add On: The add-on percentage will continue to decrease each year. Add-on is 3 different sub-categories: Low Population Density Agencies, High-utilization counties, and all other rural areas. 
  • Home Infusion Therapy Benefit: These services are provided under Part B and not the home health benefit.  The new considerations are only for certain drugs and only with use of an infusion pump in the home.  If Part A providers adhere only to what the Part B provider allows, then patient care could suffer. There could be side-by-side billing, but what if overlap of nursing care exists? If the patient needs to be taught the infusion, then also needs wound care? It just needs additional clarification so there is no chance of incorrect billing. 

Do Your Homework And Call Us If You Need Help: 

At Kenyon Homecare Consulting, we have seasoned consultants from top administration levels. We help navigate operational changes and work with you through changes. Call us at 206-721-5091 or contact us online for assistance. 

The Future Of Homecare Lies With Pre-Claim Review. Make Sure You Are Ready To Face it Full Steam Ahead!

In 2016, Illinois was hit with pre-claim review.  Yikes.  The rest of the nation bristled at the thought. Now, multiple states are in the 5 year Review Choice Demonstration.  It may be a different name, but it is the same concept. Let’s look at who is involved and why all states need to pay attention.

Why Illinois, Ohio, North Carolina, Texas, and Florida?:

Pre-Claim ReviewWell, CMS determined these areas to have known fraud.  It is known fraud and/or high denial rates in previous probe and educate rounds that put these states on the map.  What CMS learned from the 2016 demonstration was that it was able to save money.  So, it only makes sense from that end to continue with a pre-claim process.  December of 2018 will begin the Review Choice Demonstration (RCD) with Illinois and other states will come thereafter.

3 Options For RCD:

Option 1 is just what Illinois did in 2016 where 100% of claims are submitted for pre-claim review.  Option 2 is strictly a post-claim review.  This means 100% of charts will have full ADRs prior to payment.  If you choose not to submit at all, then option 3 allows agencies to receive all Medicare payments with an automatic 25% reduction of payment.  It also sets agencies up with a big target for RAC audits.  After 6 months of review, agencies have either 5% of claims every 6 months for pre-claim review or there will be selective post-payment review.

It will be important for agencies to maintain high levels of compliance in the subsequent 6 month periods.  At any time an agency can be thrown back into 100% pre-claim if compliance is not maintained in every 6 month spot checks.

Will This Happen To All States?:

If CMS yields the same results as the 2016 demonstration, then there is no reason to believe this will not be an ongoing reality for everyone moving forward.  So, what makes sense is to prepare your states for improved turnover time in documentation to prevent RCD from hurting cash flow.  If you address the process with physicians, then it will help with turnover time for orders. With agencies already struggling with cash flow in many states, the industry cannot afford delays in payments.  Know what cash reserves you have to prepare for delayed receipt of payment.

Let Us Help With Your Processes:

With an organizational assessment, Kenyon Homecare Consulting can help tighten your internal processes to prepare for RCD delays. If you would like to discuss how we can help prepare you for RCD, call us at 206-721-5091 or contact us online today.

Are you Ready For Your Home Health Survey? Here’s Why A Mock Survey From A Senior Consultant Can Save You Money And Headache In The Process Of Figuring Out The Answer!

regulatory complianceThe Conditions of Participation have been in full swing for a little while now.  However, those in the process of being surveyed with the new COPs are finding out it is tougher.  Let’s look at why is makes sense both financially and from a compliance standpoint to have a home care consultant mock survey your agency prior to the real thing.

Changes That Can Can Cause Problems:

As an industry, when something allows more flexibility on the part of the agency, it seems like a good thing.  However, this can be where mistakes are made.  Here are a couple of things that are misinterpreted and cause citations:

  • Supervision Of LPNs And Rehab Assistants: It is no longer listed in the COPs as required by a specific timeframe.  Agencies often misinterpret this as no longer being necessary.  The difference now is just that the agency determines the frequency.  If you don’t have it listed in policy as to how often and how you complete the supervision process, then you are out of compliance.  There still needs to be a standard to your supervision and it has to make sense.
  • “Record Review”: Agencies may have jumped up and down at the idea that a formal “record review” process quarterly was no longer required.  If you don’t review the records, how do you know if you meet standards of practice? If you don’t look at medication reviews, intervention completion, or visit frequency, then how do you show compliance? There still needs to be a format in your QI that shows you have ensured the quality of the care is being met and measurement is relevant to your agency.  Again, the timing of how often you review for compliance is what has changed here.
  • No More Margin Of Error: In the past, an agency was allowed a margin of error. Now, one chart missing an order or one aide supervision missing can cause the citation.  This is huge for potential of multiple site visits.

How Does A Mock Survey Save You Money?:

Ultimately, whether or not you are looking at state survey or accreditation, a mock survey goes a long way in getting your compliance into shape prior to survey.  A senior home care consultant will approach your agency like the surveyor would.  Giving you detailed information as to where and where you don’t meet the regulations.  These items can be corrected prior to survey and allow the actual survey to become less stressful.  It is not new that less citations mean decreased risk for re-survey. Additional surveys mean additional plans of correction and more time of office and clinical staff to complete the certification process. This is expensive for an agency.

Let Us Help You Get Ready For Survey:

Whether you need help with a new accreditation or need someone to make sure you are compliant ahead of survey, Kenyon Homecare Consulting can help! With a home care consultant who has experience with CHAP, JCO, and ACHC, we can help make the process smoother and get you survey ready.  Call us today at 206-721-5091 or contact us online to set up your free consultation.