Archive for March, 2013

March 17, 2013

Face to Face 2013

By  guest blogger-Brandi Whitemyer, BSN,RN, HCS-D,COS-C

Since its implementation in 2011, face-to-face encounter requirements have presented home health agencies with confusing and monumental challenges that impact payment, referral relationships, documentation, and agency workflow. As agencies rise to meet these challenges, it seems questions arise faster than answers in an industry pushed to fulfill yet another demand. Some of the toughest scenarios presented by face-to-face challenges can often only be solved with the assistance of an industry expert. Don’t let your agency be fooled and lose valuable revenue by assuming the answers to your face-to-face questions are easy.

Some of the most common and confounding issues involve late face-to-face encounters. While CMS has provided guidance on these scenarios, resolving them nevertheless involves attention to detail and patience to assure you don’t lose revenue. For example, does your agency know what to do in the following scenario? An encounter you thought occurred on day 28 never happened, only to find out the patient’s encounter occurred 70 days following the agency’s original start of care date. How should your agency act now?

According to CMS Q&As released as of April 2012, you will need to count back 30 days from the late encounter, identify the closest billable visit on or after that date (which will become your new SOC date), and create a new start of care OASIS using those M item response from the OASIS completed closest to that identified first billable visit date. Previous OASIS (including the SOC and any recertification completed) will need to be deleted per CMS guidance prior to the submission of any newly generated OASIS as well. In this process, you will need to assure that as you adjust your episode dates, you generate new plans of care to cover the corrected episode dates, and have these signed by the physician as well. Sounds simple enough right? Maybe, but too often it seems that one simple situation like this can create an avalanche of issues and questions.

For example:

Q: Why delete the OASIS rather than inactivate it?

A: CMS does not require nor want OASIS data on patient episodes that are considered non-covered. In this case, the original OASIS completed are representative of non-covered episodes.

Q: Where do I obtain the M item responses if the closest OASIS is a recertification or a discharge?

A: Use all available M item responses from the available OASIS first, then other M items may be obtained from the ROC or SOC OASIS, whichever was completed closest to the identified first billable visit date.

Q: What about the plan of care? How do I know what interventions and goals to include in which episodes now that the episodes have shifted?

A: As you may have varying interventions and goals from one episode to the next, you will need to review each original episode alongside the revised episode to assess what interventions and goals to include in each newly generated plan of care. Remember that the care you provided at any time must be supported by orders, either within the plan of care or supplemental.

These are just a few of the questions that can come up and, while CMS has issued a myriad of guidance on the issue, navigating a sticky face-to-face issue can still be confusing and time consuming. Unfortunately, the burden of the face-to-face falls on the home health agency, and handling any face-to-face scenario incorrectly can put your claims at risk and risk important revenue for your agency. Be sure to educate your agency staff to assure face-to-face compliance and reduce your risk. Selman-Holman & Associates can help your agency with any number of questions and issues related to face to face, including medical reviews and appeal of claim denials related to face-to-face issues. Don’t take a chance and risk your agency’s bottom line.

March 17, 2013

Outsource coding and review

By guest blogger-Brandi Whitemyer, BSN,RN, HCS-D,COS-C

With ICD-10 on the forefront and the continued impact of PPS changes that have caused agencies to identify cost effective practices, the utilization of outsourced coding and OASIS review has come to center stage in the home health industry. After discussing this issue with many agencies around the U.S, the debate seems to come down to cost savings. In the end, how will the agency either reduce its current spending or increase its revenue by implementing a practice of outsourcing its coding and OASIS review? When done right, it can be a winning solution for an agency.

Agencies need to start preparing for the October 14, 2014 implementation of ICD-10. This means either the agency’s own coders need to be proficient in the ICD-10 coding system, or the agency needs an alternative plan. For larger agencies or those using all certified coders, training may be a viable option. For smaller agencies or those who use coders without formal training, the agency needs to realistically realize 1) the cost of training for a smaller staff, 2) the reality of trainability for staff.

In addition to upcoming ICD-10 concerns, agencies need to pay close attention to quality and outcomes in the current advent of ACOs. The reduction of OASIS errors and ability to submit accurate data that demonstrate outcomes has become increasingly important for home health agencies everywhere. Those who can show responsiveness, quality patient care, and, above all, superior patient outcomes are those who will be most appealing to ACOs and ultimately hold an upper hand against other agencies in the race to compete.

How can outsourcing the process of coding and OASIS review help your agency and what questions do you need to ask? Start with asking how the process can benefit your workflow and revenue cycle. Utilizing the services of a company that specializes in outsource coding and OASIS review services guarantees timeliness of the coding and review process, as well as accuracy. This process can expedite an agency’s RAP turnaround time, in addition to assuring accurate reimbursement for claims. Over time, feedback provided from expert review can even reduce the overall rate of clinician OASIS errors, providing for faster completion of OASIS and improved clinician understanding of OASIS guidelines. Take a look at the overall reduction in initial errors in submitted OASIS over six months for one agency after initiating the services of outsourced coding and OASIS review:


OASIS Error Rate over 6 months- Prestige Home Health of Canton, Ohio

For this same agency, after two years of continued use of these services, overall submitted OASIS errors now average only 1%. With an improved understanding of OASIS guidance and quick feedback from expert review, clinicians are able to submit more accurate and timely OASIS.

So with so many companies claiming to “specialize” in home health coding and OASIS review, is it really an apples-to-apples comparison? Agencies need to do their homework when it comes to choosing a company to perform this service. Saving a bit of money now may only result in having to pay for clean up down the line, so beware of making a dollars-to-dollars comparison. Some suggested questions:

1) Who will be performing the service? Will it be one person or multiple employees assigned and will the agency be able to contact the assigned individual directly? (Being able to go direct to your coder without a middleman for every question can make worlds of difference when you need an answer fast!)

2) What are the minimum qualifications and experience for the company’s employees? Is there only a requirement to be certified or is there a higher standard? While certification holds merit, an agency claiming to “specialize” should be able to show some degree of higher standards than the general population.  In addition, how often is the work of employees audited for quality and is those results available? Can your agency ask for work to be audited on request if questions arise?

3) What is the turn around time for submitted work? Can your agency ask for work to be expedited and how does the company process this. A company that has inflexible submission processes may cause delays.

After your agency contemplates all of these issues, then its time to decide the value of a dollar. Spending a bit more to assure the quality and timeliness of work now is well worth it. Finally, with any outsource coding and OASIS review company that your agency may be considering, examine that company’s readiness for ICD-10. Any company claiming to specialize in home health coding should be prepared to help your agency make this transition smoothly and should have coders on board who are AHIMA Approved ICD-10 Trainers and Ambassadors. Ultimately, don’t be afraid to spend a bit more to get the quality your agency deserves in a time where accuracy and expertise couldn’t be more important!