Archive for July, 2010

July 30, 2010

Learn the timing of transfers

This question on transfers recently came to me: We have a home health patient admitted on 7/21 to our agency. On 7/24 he was admitted to inpatient acute care for dehydration, acute renal failure and UTI . However, he was discharged in less than 24 hours. According to the [OASIS] Manual, if it is less than 24hrs, it does not count as admission.
So do we need to do transfer and an ROC?

Lisa says:

To meet the criteria for transfer the patient must:
1) Be admitted as an inpatient;
2) Reside as an inpatient for at least 24 hours (not including time spent in ER); and
3) Be treated for a condition (not for diagnostic purposes).
Your situation does not require a transfer and ROC.

Want to learn more about the specifics of transfers? Go to Chapter 3, Section O (Emergent Care) of the OASIS manual, to see what criteria CMS has put around transfers.

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July 29, 2010

Valid assessments for M1910

In its April 2010 Q&As, CMS addressed the issue of valid tests on M1910, showing risk of falls. The Timed Up and Go test is a falls risk assessment, and CMS noted that the TUG test is validated and standardized.

Your patient must be able to get up and walk to perform this test. What if the patient is bedbound or chairbound and unable to perform the TUG but still is at risk for falls based on a non-validated falls risk test?

How should M1910 be answered?

There are other validated falls risk assessments for bedbound and chairbound patients. You can review Chapter 3 of the OASIS manual to see more thoughts from CMS.

As for M1910, it needs to be answered in the negative if one of the factors in the multifactor falls risk assessment is not validated.

Looking for that April 2010 Q&A?

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July 26, 2010

Pressure ulcer answers!

I always get questions during and after education seminars. Here are a few dealing with one of our favorite home health questions: pressure ulcers

Is a reddened coccyx with a few scabbed areas considered a Stage 2 because of the scabs?

Lisa says:  A Stage 1 has intact skin. The presence of scabs would be considered more than Stage 1; however, it cannot be staged if the wound bed is not visible.

If we have a Stage 3 that is closed and would be a Stage 3 on admit and discharge, do we put zeros for MO1310 1312 and 1314 to reflect that it is closed.

Lisa says: A closed Stage 3 is never fully healed, so will continue to be called a Stage 3 at each time point unless it breaks down and becomes a Stage 4. The correct response to M1310,1312 and 1314 is 000.

If a patient went in hospital for shoulder surgery and was kept in observation and left just shy of 24 hours, would the admission MO1000 be NA ?

Lisa says: This patient would still be marked ‘Hospital’ as M1000 is not related to the criteria for a transfer assessment. The item simply asks from which facility was the patient discharged. (A transfer assessment  is not required.) Note: Before you mark ‘Hospital,’ make sure this patient was not considered outpatient, e.g., had outpatient surgery.

July 22, 2010

Quick news: CMS answers OASIS questions

I’ll have some thoughts on these answers later, but just wanted everyone to know that CMS has released its quarterly Q&As to clarify OASIS issues.

Here are some highlights:

  • Pressure ulcers (M1306, M1308, M1310, M1312, M1314, M1320, M1324): responses on sutured and grafted ulcers, as well as responding for resolved suspected DTI
  • Measuring the depth of ulcers
  • M1510 heart failure followup issues
  • Other issues dealing with M102, M104, M1012

See the responses here.

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July 19, 2010

CMS proposes payment changes to HH services for 2011

CMS is proposing major changes in therapy qualifications, documentation and “effectiveness” of therapy in the 2011 proposed HHPPS rule. It is also proposing case-mix changes and payment changes.

This post gives an overall view and focuses on payment aspects.

The Centers for Medicare & Medicaid Services (CMS) announced late last week in its Home Health Prospective Payment System Rate Update for Calendar Year 2011 Proposed Rule a number of changes for HHAs and Hospice regarding certification, case-mix, therapy and skilled service documentation and requirements, and payment rates.

The proposed rule has a 4.75 percent decrease in Medicare payments to home health agencies (HHAs) for calendar year (CY) 2011. Based on updated data analysis, instead of the planned 2.71 percent reduction for CY 2011, CMS proposes to reduce HH PPS rates by 3.79 percent in CY 2011 and an additional 3.79 percent in CY 2012.

The agency estimates that this could be a $900 million decrease compared to payments HHAs received in CY 2010.  The decrease is a combination of market basket update, a wage index update, reductions to the home health prospective payment system (HH PPS) rates and other factors.

The Affordable Care Act (ACA) mandates a 1 percentage reduction to the CY 2011 home health market basket amount. The ACA also changes the existing home health outlier policy through a 5 percent reduction to HH PPS rates, with total outlier payments not to exceed 2.5 percent of the total payments estimated for a given year.

Among the proposals that could help lower payments is a proposal to pull two hypertension codes, 401.9 and 401.1, from the case-mix list. CMS is also proposing far more specific, and restrictive language regarding therapy. The proposals include clarifications on the roles and duties of therapists and assistant, specifics on therapy for rehabilitation or maintenance that moves toward written goals, that all therapy visits must be considered reasonable and necessary, and what constitutes assessment, documentation and goals.

“The new HH PPS provisions will help ensure more accurate payments under Medicare and reflect prudent financial stewardship of the Medicare Trust Fund,” said Jonathan Blum, director of the Center for Medicare and deputy administrator for CMS.

In CY 2010, CMS finalized a policy that requires HHAs that change ownership within three years of initial enrollment to obtain a new State survey or accreditation.  CMS now proposes exceptions to the 36-month provision for certain types of ownership transactions.  CMS is also clarifying the quality reporting requirements for the CY 2012 HH PPS rate update, as it relates to the Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey.

Home health payment rates are updated annually by the home health market basket percentage increase.  CMS uses the home health market basket index, which measures (and tracks) inflation in the prices of an appropriate mix of goods and services included in home health services.

Read my post on the HTN case-mix proposal.

Read my post on proposed documentation and therapy roles.

Read about CMS’s specific skilled services wording aimed at reasonable and necessary therapy.

Find out more at www.healthcare.gov.

Read the full proposed rule.

Comments are being accepted until Sept. 14 on this proposed rule, CMS-1510-P. To send comments, go to http://www.regulations.gov.  Follow the instructions under the “More Search Options” tab.

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