Posts tagged ‘m0090’

August 31, 2012

Medicare cares whether a visit was billable

Question: We have a patient that did not get a face-to-face until after the 30-day mark after SOC.  I know I can go 30 days prior to when the face-to-face took place. When I count back, the patient was seen by a therapist that day but was not seen by a skilled nurse until several days later.  Do I have to have the clinician do an OASIS/485 for the date she saw? The specifics:

HH original SOC 6/29
Face to Face encounter 8/9
Possible new SOC 7/11 (30 days prior to 8/9)
SN saw 7/9, therapy saw 7/11, SN saw 7/20

Do all consent forms need to be redated to new SOC date as well?  New 485, new OASIS?

Lisa says: Your new SOC should be generated based on a date of 7/11 (30 days back from F2F was 7/11). 7/11 is chosen because it is the first eligible date and the first billable visit was made. Medicare doesn’t care who made the visit as long as it was billable.
 
To generate a new SOC assessment, any qualified clinician can sit down with the old SOC and complete the new one based on the same answers with updates to M0110 and M2200. A new 485 will need to completed with updated orders to reflect the 60 days beginning with 7/11 as the “from” date. M0090 will be the actual date that the new SOC is generated so you will receive late warnings.
 
Medicare does not speak to new consents, but I suggest you at least have some kind of communication with the patient in the interest of patient rights. This could get signed at the next visit. For example:

Dear {Patient},

A visit with your physician within a certain time frame when beginning care with a home health agency is a condition of payment for the home health agency. Because you did not see your physician until {date}, we have a new start of care date for you and the care previous to the date is non-covered by Medicare. (You are not responsible for payment.)

We will continue to provide you care under the previous consent forms signed by you or your representative. Please sign this letter to indicate your receipt of this information.

Regards.

Administrator Signature                                                              Patient Signature

March 20, 2012

How do you correct an OASIS error when a clinician is no longer with you?

From CMS Q&As …

Question: Our clinician reported an ostomy as a surgical wound in the OASIS M1340, Surgical Wound item. The clinician no longer works for the agency, so we cannot contact her about the error. Can this OASIS change be made by the DON without speaking to the clinician?
CMS Answer: You have described a situation where a true OASIS scoring error was discovered during the audit process. The assessment was complete. The patient had an ostomy, a clear, non-disputable fact based on the entire clinical record. The assessing clinician responsible for completing the assessment misunderstood, wasn’t aware, or made an error based on the OASIS scoring guidance, which states all ostomies are excluded as surgical wounds in M1340.
HHAs should have a policy and procedure for correcting errors that involves the assessing clinician. The policy should follow established clinical record professional practice standards and guidance found in relevant CMS regulations and guidance. Normally, if an error is identified through audit or review, the individual who made the original entry into the patient’s record would, whenever possible, make the necessary correction by following agency policy. A correction policy may allow the auditor who found the error to contact the clinician, discuss the discrepancy in the medical record and make the correction following your policy including information such as who discovered the error, and the date and time of communication with the assessing clinician who agrees that it was an error. Correction of an error will not impact the M0090, Date Assessment Completed.
In a case where, as you have described, the original documenter is not available, the clinical supervisor or quality staff may make the correction to the documentation following the correction policy. The supervisor must document why the original assessing clinician is not available to make the correction and how the error was identified and validated as a true error. When corrections are made to assessments submitted to state, you must determine the impact of the correction on the POC, HHRG, the Plan of Treatment, RAP and make corrections to those documents and billing, as applicable.
When the comprehensive assessment is corrected, the HHA must maintain the original as well as subsequent corrected assessments in the patient’s clinical record per requirements at 42 CFR 484.48.

CMS urges HHAs to make corrections and/or submit inactivations as quickly as possible after errors are identified so the state system will be as current and accurate as possible, as the data is used to generate OBQM, OBQI, PBQI, Patient-Related Characteristics Report and HHRG.
Follow the guidance found in CMS Survey & Cert Letter 01-12 New Outcome and Assessment Information Set (OASIS) Correction Policy for Home Health Agencies (HHAs)—ACTION and INFORMATION.

November 14, 2011

Jan. 1 M0090 date is the end for case-mix hypertension

CMS has clarified that payment changes relative to the removal of the hypertension codes will be effective with M0090 dates of 1/1/2012.

“Beginning with M0090 dates of January 1, 2012, 401.1 Benign essential hypertension codes and 401.9 Unspecified essential hypertension are removed from the HH PPS case-mix system. Specifically, 401.1 and 401.9 diagnosis codes will no longer result in additional points when computing the HIPPS codes”

Providers should not change the codes they use for hypertension unless they have been coding the 401 codes in error. Changing the codes just to get points is upcoding and we certainly do not want to prove CMS correct about case mix creep. You can be sure that they will be watching for trends in hypertension coding as a result of the case mix change.

Remember hypertension with chronic kidney disease (585) or renal sclerosis (587) changes the hypertension code to the 403 category. There is a presumed relationship between CKD and HTN with HTN causing the CKD.

However, a relationship between heart disease and HTN cannot be presumed. The physician must either state (e.g., heart failure due to hypertension) or imply the relationship (e.g., hypertensive heart disease).

Even if you do not have the information to be able to change the hypertension code to some other category besides 401, do not despair! Remember that hypertension and heart disease are together in Table 4. Even if you do not earn points with the hypertension codes, think how many of your patients with 401 codes also have codes from the 414 category (coronary atherosclerosis and chronic ischemia), 410 (acute myocardial infarction) and 428 (heart failure). Those codes are case mix, too, so you will not be losing any points!

Grouper information!

May 16, 2011

The first visit to the home is the ROC

Some agencies are under the impression that the first visit after the patient returns from an inpatient facility stay has to be the ROC assessment and they believe that any visit prior to the ROC assessment cannot be billed. Both are misunderstandings. The first visit by anyone by your agency, billable or non-billable, is the ROC visit and so the date of that visit is placed in M0032. The ROC assessment has to be completed within 48 hours of return home.

Here is the information from OASIS Q&As

[Q&A ADDED & EDITED 9/09; Previously CMS OCCB 01/09 Q&A #5]

Q15.1. My patient was released from the hospital and needed an injection that evening. The case manager was unavailable and planned to resume care the following day. Could the on call nurse visit and give the injection before the resumption of care assessment is done? Is there a time frame in which care (by an LPN or others) can be provided prior to the completion of the ROC assessment?

A15.1. There are no federal regulatory requirements that prevent an LPN from making the first visit to the patient when resuming care after an inpatient facility stay, but there must be physician orders for the services/treatments provided during that visit. It is not required that the ROC comprehensive assessment be completed on the first visit following the patient’s return home. OASIS guidance states that the Resumption of Care comprehensive assessment must be completed within 2 calendar days after the patient’s return from the inpatient facility. The clinician that completes the ROC comprehensive assessment must be an RN, PT, OT or SLP.

In the case of an unknown hospitalization, a LPN/LVN, aide, or PTA etc makes a regularly scheduled visit and finds that the patient has had a hospitalization meeting the criteria for transfer, calls the agency and reports the hospitalization. The orders you have for the episode are still valid orders after an inpatient admission, so if that regularly scheduled visit has orders that visit is still billable. That visit date is also the date placed in M0032. The qualified clinician has 2 days from the point of acquiring the knowledge of the hospitalization to complete the transfer and the ROC assessments. M0090 is the date the assessment was actually completed.

March 1, 2011

Even with unexpected discharge, M0090 rules

Question: I understand that for a transfer, or unexpected discharge, the data collected at the last skilled visit is used for the remote documentation.  However, we have had several instances of losing several HHA, PTA, and OTA visit reimbursements, as we are using the last skilled visit as the last billable visit. Is this correct?  Sometimes there are nearly two weeks of forfeited visits due to this rule, which we are not sure we are interpreting correctly.

Lisa says: Your HHA, PTA and OTA visits are billable and should be included on your claim. Completing the OASIS DC is a separate issue. The last qualified clinician who saw the patient has to complete the OASIS based on information obtained at that last visit. But remember that the M0090 date is still the date the assessment was completed which is after the other billable visits were provided.