Archive for December, 2010

December 15, 2010

Yes, the Symposium has contact hours, admin hours, and CEUs!

I’ve gotten a number of questions on whether the First Annual Coding and Regulatory Symposium, my two-day conference in January in Las Vegas, is approved for education credits.

Yes! It is approved for:

12 nursing contact hours
12 administrator hours

Learn all about the Jan. 27-28 conference and why it is useful for administrators, coders, and OASIS experts!

2011lasvegas … see the attached brochure!

December 14, 2010

Check box does not meet F2F requirements, but labels might

These questions are the Q&As from NAHC from questions that the organization has received on the face-to-face encounter issue.

Question:  Clarify the regulatory requirement of no standardized language. To be used in documentation of F2F are we able to create a form that contains check box options for the physicians in regards to diagnosis, etc.?
Answer: A check box would not meet CMS’ intent since the agency would be providing prescribed verbiage that a physician must choose from. This “standardized” language may not fit with the clinical condition of the patient. The full text from CMS in the Federal Register reads: “The law requires this as a condition for HH payment. We proposed that the documentation of the encounter be a separate and distinct section of, or an addendum to, the certification, and that the documentation include why the clinical findings of the encounter support HH eligibility. We believe that our proposed documentation requirements meet the Congress’ intent for more physician involvement in determining the patient’s eligibility and managing the care plan. We believe that were we to allow the HHA to craft standard language which the physician would then simply sign, we would not achieve the sort of physician involvement in the eligibility determination and care plan which was the Congress’ intent. As such, we believe that if a HHA were to develop standardized encounter language to be signed by the physician, they would not be adhering to the statutory payment requirements that the “physician document” the encounter.”

Question:  May a home health agency put labels on a form for the physician to complete?
Answer: When asked if it would, however, be acceptable for the agency to at least label the section of the 485 or addendum where the physician’s documentation should be placed, titling it for example “Physician Verification of Face-to-Face Encounter,” and then to include subheadings which include: Date of Encounter, Medical Condition for Encounter, Services Needed, Clinical Findings, Homebound Status, Physician Signature, Date. CMS responded Yes, this is fine.  As long as the info/clinical findings and how the findings support eligibility are documented by the physician, in his/her own words.

Question:   If a hospitalist documents the F2F and certifies the patient, is the primary physician (who will sign the 485 and oversee the episode of care) required to complete a face to face as well?  Or does the hospitalists F2F meet the requirement?
Answer: No, a second face-to-face by the physician ordering services and signing the plan of care is not required.

Question:   If a F2F encounter occurred within the past 90 days prior to referral for homecare and the reason for the F2F was not related to the homecare referral we must then get an additional F2F encounter documented?
Answer: Yes a second encounter will be required.

Question:   I thought the face to face for homecare was effective for admissions as of 1/1/11?
Answer: The face-to-face encounter is required for any patient with a Start of Care Medicare fee-for-service episode 1/1/11 and after. It is not required for recertification episodes.

December 13, 2010

Maternity patients are exempt from OASIS

Question: If a patient has a disrupted wound post c-section, do we do an OASIS assessment? 

Lisa says: No, maternity patients are exempted from OASIS. The ONLY time you’d want to complete OASIS on a maternity patient is if Medicare is the payor. In that case, you’d want an HHRG.

December 9, 2010

HHAs must convert to OASIS individual user IDs

To comply with CMS security regulations, CMS is changing the way agencies login to the OASIS Submission System and CASPER Reporting. The change will require agency users to register for a named individual user account ID.

When the security changes are deployed to your state, you will no longer be able to
access the OASIS State Submission System using your state-assigned shared login ID.
You will be required to register for a named individual user ID.

The HHA Individual User Registration link will be added to the OASIS State Welcome
page. The link will be displayed directly above the OASIS Submission link.


December 8, 2010

2011 OIG Work Plan focuses on payments

If you haven’t seen it yet, or you don’t know about it, the Office of the Inspector General is implementing its FY2011 Work Plan. The great thing about OIG is that the agency spells out exactly what  it will be focusing on in each care continuum.

Here’s a look at the HHA (Medicare Part B) focus:

Payments for HH Beneficiaries: The OIG will review Part B payments for services and medical supplies provided. The agency specifically mentions identifying payments to outside supplies to examine controls.

HHA Claims for Medicare HHRG: Coverage requirements (homebound, intermittent care, under care of MD, etc.) are a focus. OIG will also assess the accuracy of HHRGs submitted in 2008.

Oversight of OASIS: OIG will review CMS’s oversight of OASIS data. The focus is to review CMS’s process that should ensure that HHAs submit accurate, complete data.

HHPPS Controls: This includes reviews for billings at the appropriate service location. This focus will analyze HHA activities on items such as the number of claims submitted, number of visits provided, ownership information, and arrangements with other facilities.

HHA Profitability: This analysis items seeks to determine whether the payment methodology should be adjusted.

Medicare HHA Enrollment: This item really focuses on cross relationships with suppliers and ownership. OIG specifically mentions that previous work found that DME suppliers omitted or provided inaccurate information … and that these suppliers were often associated with HHAs through shared owners or managers.

See OIG’s focus across the health care spectrum.

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