September 2018 Industry News

Value Based Purchasing Proposed Changes for 2019

On July 12, 2018, CMS released the Proposed Payment Rule for 2019. One aspect of this final rule that providers are taking note of is the proposed changes to the Value-Based Purchasing (VBP) Model. This calls for a decrease in the amount of improvement points an agency can earn in the VBP model. This would include removing five measures and add two new composite measures.

  • “Influence Immunization Received for Current Flu Season” and “Pneumococcal Polysaccharide Vaccine Ever Received” would be removed
  • “Improvement in Bathing”, “Improvement in Bed Transferring”, and “Improvement in Ambulation-Locomotion” would be replaced by two new composite measures:
  • “Total Normalized Composite Change in Self-Care”
  • Improvement in Grooming
  • Improvement in Upper Body Dressing
  • Improvement in Lower Body Dressing
  • Improvement in Bathing
  • Improvement in Toileting Hygiene
  • Improvement in Eating
  • “Total Normalized Composite Change in Mobility”
  • Improvement in Toilet Transferring
  • Improvement in Bed Transferring
  • Improvement in Ambulation/Locomotion

Article Details from HCLA Newsletter published on 08/30/18 which was written by Melinda Gaboury from Healthcare Provider Solutions.

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Corrective Action Will Be Required If Too Many RAPs without Final Claims

Effective September 17, 2018, when a MAC identifies an agency’s misuse of RAPs (such as a high rate of final claims not being filed), the MAC will initiate corrective action that includes (but not limited to) warning, education, corrective action plans, RAP suppression, and referrals to the Unified Program Integrity Contractor (UPIC). RAP suppression (normally lasting 90 days) means that all RAPs submitted by the agency will process with a zero payment. UPIC referrals can lead to actions including being placed on 100% pre-payment review or a post-payment audit with continued RAP suppression. MACs will be conducting monthly audits to identify the potential misuse of RAPs.

To recap, among the things MACs are monitoring for fraud and abuse are:

  • More RAPs submitted than Final Claims Submitted
  • Final claims being submitted late resulting in RAPs being auto-canceled
  • Variation in the number of RAPs submitted on key markers
  • Other behavior indicative of misuse

Article Details from HCLA Newsletter published on 08/22/18 which was written by HH Line.

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Final Hospice Payment Rule for FY2019 Released

A few things to take note of, in regards to the payment rule are as follows:

  • Continuous Home Care (CHC) hourly rate reduced to $41.56 hourly rate
  • The hospice aggregate Cap amount will be increased by 1.8%.
  • CMS is finalizing some CAHPS related updates and issues
  • Begin public reporting of the HIS-based Hospice Comprehensive Assessment Measure on the Hospice Compare website

Article Details from CAHSAH Newsletter Published on 08/06/18.

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Coding Changes Effective October 1, 2018

More coding changes are coming, and we all have to be ready! A brief summary of changes that will impact your agency are below:

  • Neoplasms – Z85.0 (Personal history of malignant neoplasm of digestive organs) and Z85.7 (personal history of other malignant neoplasms of lymphoid, hematopoietic and related tissues) to describe a patient with a primary site malignancy not a secondary malignancy. If there is a secondary malignancy, use codes in the Z85.8 subcategory.
  • Myocardial Infarctions – don’t use I22. Except when capturing Type 1 or unspecified myocardial infarctions (MIs) that occur within 4 weeks of a previous Type 1 or unspecified MI.
  • Pulmonary Hypertension – An exception was added to sequence the underlying cause of a patient’s secondary pulmonary hypertension according to what treatment is aimed at (code pulmonary hypertension first, followed by T code for the drug)
  • Post-Procedural Septic Shock – New code for post-procedural sepsis (T81.44-) should be coded first, then T81.12 (postprocedural septic shock). Do not use R65.21 (sever sepsis with septic shock) but should use codes for acute organ dysfunction
  • Burns – Only code the highest degree of a burn when the patient has burns of different degrees affecting the same anatomic site on the same side of the body. Only assign a code for burns of multiple sites when the documentation doesn’t specify individual sites
  • Underdosing – definition was expanded to include when patients stop taking prescribed medication on their own versus under doctor’s orders
  • BMI – Clarification specified that the diagnosis associated with the BMI code (such as obesity) must meet the definition of a reportable diagnosis not the BMI itself

For information regarding October 1, 2018 coding changes, click here.

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Make Sure PHI is Encrypted

Patient Health Information (PHI) must be protected. One way to protect the data would be to encrypt it. The HHS Office for Civil Rights (OCR), which helps to enforce HIPAA, explained that encryption is a best practice. If you aren’t going to use encryption, you need to document which alternative you’re using. Encryption also enables a provider to help report a data breach. HIPAA and many state laws will not require you to report a data breach unless the data was “unsecured”.

See more information about HIPAA’s breach notification rule here.

Article Details from HCLA Newsletter Published 08/22/18.

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