To Our Valued Careficient Clients:
The IMPACT Act will focus on discharge and performance improvement with CMS already starting to collect data for this measure. It’s important to remember that discharge planning must start on admission. This is one way to improve your performance on the claims- based measure Discharge to Community which starts impacting payment this year and will be included in Home Health
Compare in 2019.
The measure is designed to evaluate successful discharge to the community and includes no unplanned rehospitalizations or death for 31 days after discharge from Home Health. Well planned and appropriate discharge planning is the key to reducing hospital readmissions.
Home Health CoP’s and Civil Monetary Penalties
Home Health agencies could face civil monetary penalties if they don’t comply with the revised CoPs, though CMS previously decided it would not impose such penalties until January 13, 2019. These penalties will only be imposed for the first year for recertification surveys that resulted in an immediate jeopardy.
Final interpretive guidelines still have not been released but it has been reported that CMS said they are in the clearance process. CMS also reported that the final guidelines will be similar to the draft guidelines.
Settlement Option for Providers Awaiting ALJ Hearings
Beginning Feb. 5, home health agencies and other providers with a low volume of pending ALJ appeals will have a new option for resolution while avoiding the judges’ massive backlog of appeals. To qualify for the Low Volume Appeals option, you must have a Part A or B claim pending at the third of fourth levels of appeal. CMS stated they will settle eligible appeals at 62% of the net allowed amount.
Targeted Probe-and-Educate Review
Targeted reviews will involve the analysis of 20-40 claims per round, with up to three rounds depending on your success. Its vitally important to closely audit your documentation before you submit it to assure that it fulfills everything reviewers expect to see.
Agencies that have a high percentage error rate could face extrapolation, 100% prepayment review or referral to the recovery auditor. If extrapolation is used and, for example, if an agency has 70% denial rate in the three rounds of targeted probe, CMS could potentially go back several years and recoup 70% of the agency’s payments.
The Team at Careficient, Inc.