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Regulatory Compliance

Having Trouble Keeping Up With Regulation Changes And Day-To-Day Business? See Why A Mock Survey Can Help You Get On Track Before The Real Thing!

Regulation ChangesToday, home health regulations change more than ever. Yes, the basics of regulation are still there, but showing compliance looks a lot different than it used to be. It may seem tough just running the day-to-day operations without trying to prepare for PDGM and any changes within your state. Let’s look at how to keep up with regulation changes in a meaningful way. 

Common Regulation Mistake: 

Most agencies work for the mission that is homecare. This is absolutely the number one reason any of us are here. However, you can’t forget about putting new regulations into place and keeping up with them along the way. If you do, then you can run into big time road blocks financially and legally. Make sure you know how to adequately prove compliance with a regulation. We saw this hit home with providers when face-to-face came into play. Most agencies saw ADRs deny. It wasn’t because agencies didn’t try. It was because agencies and physicians thought they were compliant only to find out it wasn’t enough. This is exactly the reason an objective eye looking at your agency makes sense.  

Why A Mock Survey: 

Agencies often hit compliance hard before survey, but then back down when it is done. If you think surveys will only come in the form of an on-site visit every third year, then you make a big mistake in running your agency. Auditing comes more frequently now than ever. Accrediting bodies make more and more return visits. CMS wants to know the agency doesn’t become lax after the survey is done. Sometimes, the site visits are yearly leading up to the next full 3-year review. This is expensive for agencies. A mock survey can keep you on the straight and narrow. It has an objective eye on your agency for everything needed to show compliance. It is much cheaper than a yearly site visitor! 

Let Us Do Your Mock Survey: 

At Kenyon Homecare Consulting, we have senior consultants who have been surveyors and know when an agency is compliant and when it isn’t. Call us today at 206-721-5091 or contact us online for your free 30-minute consultation to see if a mock survey is right for you.

How Do You Change The Mindset Of Therapy Care Plans In Preparation For PDGM? One Step At A Time And Start Now Before The Ball Drops On New Year’s Eve!

one step at a timeWhether you are new to homecare or have been around for decades, change is always a given! Now, with the PDGM model, it becomes more important to analyze and see if things can be done more efficiently in your therapy program. Wait, it is more than important. It is crucial. Let’s look at steps to make it happen. 

5 Steps To Therapy Change: 

You need to know where to start. If already in the process, then you may see big change or be frustrated with lack of results. Consider methodically approaching the process. 

  • Check Your Outcomes: The first step is checking the therapy report card. Do you see the improvements you need from an Oasis standpoint? If not, then figure out if therapy is underperforming or the Oasis is being marked improperly on SOC or DC. 
  • Check The Documentation: Does it paint the picture of what the therapist is really doing? Is everything documented back to a functional goal? If you don’t know why each intervention is being performed, then it needs to change. 
  • Talk About PDGM: Whether you have contract or staff therapy, the discipline has been attached to additional payment for decades. The idea of managing visits has been different for nursing than therapy. It is a reality. So, therapy mindset has been different. The mindset with PDGM must change since the payment no longer follows the therapist. 
  • Alter The Paradigm: Now comes the management of the care plan between all skilled disciplines. This has been a big focus of care planning for years. Care coordination becomes completely focused on functional goals between all skills. Not therapy versus nursing versus home health aide. This is crucial for PDGM profitability. 
  • Evaluate The Program Often: This will be a work in progress for you that are just beginning. Others who have started know can be challenging. However, for those who successfully implement a meshed and coordinated care plan, it is just better! It really can function like a well-oiled machine. Evaluate the program by looking at your chronic disease care. It is the single most important tool to advance coordinated care for a PDGM world. 

We Can Help: 

At Kenyon Homecare Consulting, we can help you advance a coordinated care program. Whether you need help with documentation, chronic disease education, or operational change call us at 206-721-5091 or contact us online to see how we can help. 

Moving Into 2020: Wrapping Your Head Around Evolving Clinical Staff Into The New PDGM Model Of Care. By The Way, This Includes Every Person Who Sees The Patient.

changeThis is a big time for transition in homecare. This industry just came off a year with the first changes to the Conditions of Participation in decades. It is a big deal. Now, you are faced with new a payment model for 2020. If you think this is just about payment, then you need to research more about the PDGM model. 

Bye Bye Therapy Thresholds: 

The industry knew this was coming. No longer will there be additional reimbursement related to the number of therapy visits. This is a good change. In order to “see” all members of the homecare team working together, there should not be incongruence in reimbursement for one over the other. Many providers continue to struggle with therapy providers not willing to comply with coordination of care or working towards shared care plan goals. This can’t happen in the PDGM model. 

Working As A True Team: 

This is huge too.  For years, healthcare has pushed to eliminate the silos of care between providers. However, the focus has been from hospital to SNF or SNF to homecare. It has not been focused on homecare discipline to homecare discipline. It is always the assumption that all clinicians within a realm of healthcare already work as a tight knit unit. Reality is, this isn’t the case in so many agencies. If you don’t have true interdisciplinary care and care planning, then it is unrealistic to think it will be successful with outside providers. So, this means fix the issues in your own house before the PDGM model hits and 30-day payments are in place. 

Begin With Education: 

Chronic disease care is the key to a true medical home model. It requires clinicians to be laser-focused on a shared patient care plan. All caregivers need educated about working in this type of model. It means more than nurses rattling off signs and symptoms of a CHF exacerbation. It is more than the aide documenting blood sugar readings. The COPD patient with pulse ox readings from the therapist doesn’t manage chronic disease. These items are all task-related and not about management of the disease. A comprehensive chronic disease management program gives you the paradigm shift you need in a PDGM model. It sets you up to be efficient and profitable. 

Call Us For Help: 

At Kenyon Homecare Consulting, we have comprehensive online disease management programs on the clinician and agency level. Call us at 206-721-5091 or contact us online for more into how chronic disease management is the key to future success.

The Year Of The CERT: What CMS Learned And How You Need To Cover Yourself To Get Paid!

regulatory complianceMany of you will read this and know exactly what CMS learned. The home health industry has been dealing with lots of changes in the last several years.  However, recent audits have alerted CMS to some issues with plan of care compliance. 

Changes In The Conditions Of Participation: 

If agencies focused on only the big changes to the COP’s, then others probably got missed.  It makes sense that while you try to comply with emergency preparedness, clinical management, and proper governance that something can be missed elsewhere. This is the issue for agencies now. The plan of care condition of participation is now a condition for payment. In order to be compliant for payment purposes, advanced directives info must be present. 

CERT Testing: 

Bill Dombi, President of the National Association of Homecare and Hospice communicated January 9th that Medicare home health agencies need to determine compliance with COP 42 CFR 484.60. This includes proper advanced directive documentation. If proper advanced directive information does not flow to your plan of care properly, then your agency is at risk of retroactive claim denials. This means more than just a DNR notation on a plan of care. Through Comprehensive Error Rate Testing (CERT), CMS evaluates proper coding, coverage and billing rules. This is done with random sampling yearly. The most recent data available is a 9.51% error rate totaling over 36 billion dollars in recoupment for Medicare home health payments from 2017. 

Avoiding Recoupment: 

Does your EMR have the proper information included for staff to input all the needed information? If not, then you need to make changes in operations to make sure a check and balance of the POC or 485 has the information present. Does Oasis contain detailed information on advanced directives? If your agency determines there is information not included on the plan of care, then initiate protocol for an addendum from the MD that includes the information you need for proper payment. You can submit corrected claims accordingly after speaking directly with the MAC about the process. Ultimately, it makes sense to make the changes now prior to massive audits that put your agency on administrative overload. 

Let Us Help You: 

Regulatory compliance can get tough. It can feel like you just keep your head above water in daily operations. At Kenyon Homecare Consulting, senior consultants help with operational flow or education regarding regulations and compliance. Call us today at 206-721-5091 or contact us online. 

Combing Through The 2019/2020 Home Health Payment Rule Changes Without Pulling Your Hair Out!

healthcare reformWhenever CMS drops payment changes, home health agencies want to cringe. Over the years, agencies become better at completing documentation and filling out Oasis properly. In response, CMS hits us with terms like case mix creep and then  changes payment for services. It can be overwhelming to jump multiple hurdles and not feel like you reach the finish line. Let’s look at payment and policy reform and how it changes care planning. 

Per CMS: 

CMS states policy changes for 2019 are based upon empowering patients, increasing competition, and fostering innovation.  The goal here is that the changes are supposed to be less about paperwork and more about patient focus. Focus on the condition/needs of the patient and not on the amount of care provided. This is the continued evolution of a value-based purchasing model with advancement of quality reporting. 

30-Day Periods In A 60 Day POC: 

This is a huge stand out for providers. Ultimately, instead of the 60-day episode of care, CMS will begin paying according to 30-day periods. This is a budget neutral plan from CMS to begin calendar year 2020. The therapy thresholds will be gone then as well. If you follow the rationale from CMS, then it makes sense. Value-based purchasing and episodic care are not meant to be based on the volume of visits. However, therapy thresholds are. So, your efforts to push therapy providers to work together in an interdisciplinary manner is not in vain. It is necessity. 

What Does PDGM Ultimately Mean: 

It means you must see each discipline working collectively. Weekly goals are discussed between disciplines and all members know exactly what to work on in the patient care plan that week. Then, progression of care is a systematic effort focused on joint goals. Now, this does not mean everything is going to be easy. If you thought so, you wouldn’t be in home health right now. Correct? Well, in all honestly, this is absolutely the time to advance home health into the next realm of care. This is front-loading of care from all disciplines. It is making the Oasis something you learn from as opposed to a form that must be filled out for payment. It is making the medical home model reality for all home care providers.

Kenyon Homecare Consulting Can Help: 

At Kenyon Homecare Consulting, we are working through these changes with agencies along with you. The senior consulting staff can help you move through operational changes to match the industry standard of care. As we continue to focus on aspects of payment reform, please call us at 206-721-5091 or contact us online to see if we can help you meet your goals.

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.