Special Alert for All Home Health Operators from NAHC!

Reposted from an email alert sent to IAHHC members:

January 9, 2019 Special Alert for All Home Health Operators!

An extremely serious issue involving Medicare home health has surfaced that requires the immediate attention of your organization.

Effective January 13, 2018, the “Plan of Care” (POC) Condition of Participation under 42 CFR 484.60 also became a Condition for Payment under the home health benefit, 42 CFR 409.43. This means that all the elements must be in the POC or Medicare payment will be denied. While this generally does not present any concerns, one of the new POC requirements has created problems for many HHA s that may not have modified their POCs sufficiently to meet the new POC requirements. A compliant POC for payment purposes must now include “information related to any advance directives.”Recent audits as part of the Comprehensive Error Rate Testing (CERT) program have uncovered significant noncompliance with this new requirement.  At the same time, MAC audits have approved claims that involve POCs that do not include full information on a patient’s advance directives.NAHC is advocating to CMS that a broad-scale, efficient remedy needs to be implemented given the apparent widespread oversight by HHAs. These HHAs do appear to have obtained all the needed advance directive information. It is just that the information did not fully find its way to the POC. At this point, CMS has not agreed to any remedial measures other than potentially hundreds of thousands of individual claim corrections.In the absence of a systemic fix, the noncompliance puts HHAs at risk of further audits and the likelihood of a high volume of retroactive claim denials. However, there is still an opportunity to correct these POC deficiencies. Still, that opportunity will be shrinking as claim corrections must be filed prior to the close of the one year window for claim submissions that will begin to close on January 13, 2019.

WHAT SHOULD YOU DO?
Review January 13, 2018, and later POCs to determine if they are compliant. For example, a POC will not be compliant on the Advance Directives requirement if the only entry references whether or not the patient has a Do Not Resuscitate (DNR) order as there are more types of Advance Directives than just DNRs.If you find non-compliance, review the patient record to determine if the needed information is available. For example, the OASIS info should include Advance Directive detail. For non-compliant claims, secure a signed POC addendum from the certifying physician that includes the required information for the POC. Submit corrected claims to your MAC. One of the MACs is accepting these corrections without a need to cancel the original claim and submitting a rebilling as there is no reimbursement effect. We expect the other MACs will do the same. The corrected submissions can be done sequentially over the next twelve months so that the administrative burden is spread out consistent with the one-year window on claim submissions. It is advisable to get your MACs take on how to handle corrections before proceeding. The correction process is a huge burden for HHAs, physicians, and Medicare itself. Since there is no effect on payment rates, NAHC strongly believes that it is in everyone’s interest that sensible remedial actions take place instead of massive claim corrections. Nevertheless, HHAs must protect themselves from the risk of retroactive claim denials based on insufficient advance directives information on the POC before corrective opportunities close with the one-year window. At present, the burdensome approach outlined above is the only option. For further information, contact Mary Carr mkc@nahc.org, or Katie Wehri, Katie@nahc.org at NAHC.

Posted in NAHC ReportTagged advanced directivesCMSComprehensive Error Rate Testinghome healthMedicareMedicare Administrative Contractorsplan of care


CMS Rule Making Process Begins for OASIS D Item Set

IAHHC sent out the following information concerning the OASIS-D data set process:

CMS filed a notice and request for comment on proposed revisions to the OASIS item set. The notice was posted on the Federal Register website March 9 and is scheduled for publication March 12.

CMS is seeking approval from the Office of Management and Budget for January 1, 2019 implementation of OASIS-D. Public comment will be open for 60 days.

CMS has also posted a 2019 OASIS change table online. In the crosswalk, you will see items that are replacing current items as well new items to be added, such as J1900 (Number of Falls since SOC/ROC, whichever is more recent).

The current version of the item set, OASIS-C2, went into effect just last year. The proposed modifications are driven by the IMPACT Act.

A draft of OASIS-D is expected in July and a finalized version is expected as early as November, CMS officials said during the Q&A portion of a February home health, hospice and durable medical equipment (DME) open door forum.

Related link: View the change table here: http://go.cms.gov/2FGdJsL.

Frontotemporal Degeneration: The Importance of Knowledge, Advocacy and Support to Advance Quality Care | American Society on Aging

Tuesday, January 16, 2018

2-3pm EST

Part of the National Alzheimer’s and Dementia Resource Center webinar series sponsored by the Administration for Community Living.

Register now for FREE

Includes complimentary CEUs

This web seminar provides an overview of frontotemporal degeneration (FTD) disorders and how they differ from Alzheimer’s disease and other dementias. Attendees will learn the symptoms, approaches to care and importance of support for the family system. An individual living with FTD and his wife will share their experiences and strategies for maintaining quality of life.

Participants in this web seminar will be able to:

  • Identify three ways FTD differs from Alzheimer’s disease and other dementias;
  • Identify the three main clinical presentations of FTD and their symptoms; and,
  • Describe two positive approaches to care in FTD

Source: Frontotemporal Degeneration: The Importance of Knowledge, Advocacy and Support to Advance Quality Care | American Society on Aging

QSEN-Related Simulation Objectives are a Key to Improving Patient Care | Healthy Simulation

Programs that conduct simulations in nursing education in either service or academia should take a moment to review the objectives of a few of their scenarios. Do the objectives include QSEN competencies? As a reminder, here are the six competencies:

  • Patient Centered Care
  • Safety
  • Informatics
  • Teamwork and Collaboration
  • Quality Improvement
  • Evidence-Based Practice.

In 2005, the Quality and Safety Education for Nurses (QSEN) initiative was funded by a grant from the Robert Wood Johnson Foundation to improve healthcare education and prevent patient errors. The goal of QSEN is to ensure that all nurses have the knowledge, skills, and attitudes (KSA) necessary to continuously improve the quality and safety of the healthcare systems in which they work. Over a thousand faculty were educated under a “train-the-trainer” model and as word of the competencies spread across the country, QSEN competencies became integrated into undergraduate and postgraduate programs. Eventually QSEN competencies were included in simulation. However, a recent survey study of nursing faculty by Gerry Altmiller (2017) discovered a huge range in the estimate of faculty having received QSEN education (20% to 80%). Reasons for not using QSEN included faculty’s lack of training and lack of knowledge how to integrate simulation. Altmiller concluded that faculty training should be ongoing and that “competencies in nursing education remains varied and inconsistent”.

Incorporation of QSEN competencies into simulation provide a significant opportunity to improve patient safety outcomes. The QSEN website has a ton of useful information, especially through the resources tab. Your program can access the QSEN faculty training for free for 3 months, as well as take advantage of the other resources such as examples of simulations and implementation strategies. A simple search for “simulation” on the website will help you find teaching strategies involving the methodology. Hint: Select “older posts” to find other QSEN sim posts!

Celeste M. Alfes published a very helpful article on the QSEN website entitled “ Developing A QSEN Competency Checklist for Simulation Experiences”.   The article includes free checklists for including QSEN competencies, learning objectives, competency checklists and evaluations in simulation scenarios.

Source: QSEN-Related Simulation Objectives are a Key to Improving Patient Care | Healthy Simulation