Are you ready for the changes taking effect next year? Last October 29, 2020, the Centers for Medicare and Medicaid Services (CMS) released its final home health payment rule for 2021 with some notable updates affecting agency operations. In this article, we will recap the most important aspects of the final rule, its implications, and the things your agency should already be prepared by now to adapt to the changes.
Beginning January 1st, CMS will require agencies to file a non-paying Request for Anticipated Payment (RAP) within five days of the start of care for each 30-day billing period, or there will be a payment reduction for each day the RAP is late.
The reduction in payment will equal one-thirtieth for each day from the start of care or the ‘from date’ for subsequent 30-day periods until the date the agency submits the RAP. Furthermore, when a RAP is submitted late, and the period of care resulted in a Low Utilization Payment Adjustment (LUPA), no LUPA per-visit payments would be made for visits that occurred on days prior to the submission of the RAP.
There are two minimum requirements agencies must meer prior to submitting a RAP next year:
- A verbal order from the physician that includes the services required for the initial visit. This must be signed and dated by the registered nurse or qualified therapist responsible for furnishing or supervising the ordered service in the plan of care that will be signed by the physician
- Start of care visit is completed and the patient is admitted for home health services
This rule adopts the revised Office of Management and Budget (OMB) statistical area delineations as described in OMB Bulletin 18-04. The changes in the Wage Index will have a significant impact on HHAs that serve certain geographic areas. Core Based Statistical Area (CBSA) codes have been restructured —some urban counties may have become rural, rural areas may have become urban, or existing CBSAs may have been split.
The area Wage Index that applies based on the patient’s residence has changed significantly to reflect updated census information. To lessen the impact for affected home health agencies, CMS set a 5% cap for negative changes to an area wage however, no cap has been set for wage index increases.
It will be important for agencies to use the latest delineations to maintain a more accurate and up-to-date payment system that reflects the reality of population shifts and labor market conditions. Read this article to learn more >
Telehealth and the Plan of Care
The rule finalized provisions that remote patient monitoring or other services furnished via telecommunication technology must be included on the plan of care (POC) and should describe the patient’s needs to support its use to reach goals. Additionally, §409.46(e) is amended to include other communications or monitoring services (including audio-only technology) that are consistent with the beneficiary’s POC. An example of this would be remote patient monitoring that transmits data, such as blood pressure or glucose monitoring.
On the other hand, the final rule reiterates that these services cannot substitute for a home visit nor be compensated as a billable visit.
What your agency should already be prepared to do
✓ Streamline intake: Observe a 24-hour turnaround
Speed up your preparation of all documentation for the first billable visit —a RAP can only be submitted as soon as the first billable visit is complete. Make sure your team understands the importance of newly set timelines and how they can address or report problems. Try imposing monetary penalties for late turnaround.
✓ Do not rush your OASIS
Ideally, the OASIS SOC must be submitted by clinicians within 24 hours from the actual visit, but agencies can still make use of the full 5-day collaborative period to complete the comprehensive assessment. Remember that the OASIS does not need to be completed in order to file a RAP. Make it clear to clinicians that a faster RAP submission should not compromise thorough assessment and collaboration.
✓ Communicate with physicians
Thorough referrals (together with the comprehensive assessment) are essential to effective care planning. It provides key information that helps clinicians better understand a patient’s condition.
If you are still getting confusing, incomplete, or inaccurate referrals, put it on top of your list to keep talking to physicians and other practitioners about the importance of these documents and how they impact patients.
Written or verbal orders for home health admission should already contain the most specific primary diagnosis as the focus of care. Symptom codes (R codes) being used as a diagnosis in the referral order must be avoided.
✓ Mind the calendar
The 5-day RAP timeframe includes weekends and holidays. Develop a plan for covering these downtimes including employee vacation and sick leaves. Your contractors should also understand how they are expected to handle the same scenario in their operations.
✓ Outsource OASIS review and coding
PDGM reimbursements are driven by accurate OASIS documentation and coding —these areas continuously evolve over time while factoring in complex case-mix weights, clinical grouping assignments, functional assessments, and comorbidity interaction among others.
Home health agencies can see greater profitability by outsourcing these functions. Beyond cost savings, it can also spare your organization the time and effort of staying on top of the ever-changing standards.
Qavalo outsourcing solutions can support your organization in realizing big picture process improvements and business scalability. Connect with us and let’s explore how your agency can benefit from outsourcing in 2021.