Weekly Newsletter
December 5, 2024
Corcoran Consulting Group, LLC
This Week at CT Healthcare At Home
  • CT Department of Social Services (DSS) Applies for State Plan Amendment for Benchmark Payments for Home and Community-Based Services
  • October 2024 Home Health Interim Performance Reports Available
  • CMS to Move Forward with Hospice Special Focus Program
  • Revised Medicare Non-Coverage Notices Issued
  • CMS Clarifies Data Changes on OASIS submission
  • OIG Report: Selected Home Health Agencies Complied With Terms and Conditions and Federal Requirements for Provider Relief Fund Payments
  • Northeast Home Health Leadership Summit
  • Seizing Opportunities in Continuing Home Health Care Under Medicare Part B: A Path for Connecticut Agencies
Alora Healthcare Systems LLC
News Update
Last week, DSS posted an intent to apply for a State Plan Amendment (SPA) to ensure they can still use the ARPA dollars set aside for infrastructure payments/support for home and community-based providers to integrate their systems for Connie data transfers.

Comments are due by 12/11/24. The Association needs your feedback by 12/9/24 to be able to incorporate into our overall comments. Please contact Tracy Wodatch (wodatch@cthealthcareathome.org) with questions or suggestions.

Source: The Alliance, November 22, 2024

The Preliminary October 2024 Interim Performance Reports (IPRs) for the expanded HHVBP Model are now available on the Internet Quality Improvement and Evaluation System (iQIES), and home health providers have until December 6, 2024, to submit a recalculation request, should that be necessary.

The quarterly IPRs provide home health agencies (HHAs) with the cohort assignment, performance year measure data for the 12 most recent months, and the interim Total Performance Score (TPS). Using the IPR, an HHA can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year. The October 2024 IPRs also report preliminary Achievement Thresholds (AT) and Benchmarks (BM) by volume-based cohort for the quality measure set applicable to the third performance year, CY 2025, and following performance years, respectively.
Source: The Alliance, November 22, 2024

All indications are that the Centers for Medicare & Medicaid Services (CMS) is moving forward with the Hospice Special Focus Program (SFP) as planned. As part of this rollout, 50 hospices will be selected for the first SFP cohort. We anticipate these hospices will soon be notified. Following that notification, CMS plans to publish a list of hospices identified as eligible SFP candidates based on its current methodology.

We recognize the concerns this program raises, particularly around the reliance on flawed and incomplete data. Despite repeated advocacy efforts from the Alliance, the entire hospice community, and our congressional champions including Representative Jimmy Panetta (D-CA), the author of the HOSPICE Act which created the SFP, CMS has not addressed these issues. The release of this information may lead to unintended harm for patients and providers.

While this is a critical moment, there is still time for CMS to change course. If it does not, Members of Congress can take action to hold them accountable and make necessary reforms.

To help you stay prepared, the Alliance has compiled the latest information and materials for members, which you can access here: Hospice Special Focus Program Resources.

We encourage you to contact your lawmakers to support a delay of the SFP by clicking this link
 

Source: The Alliance, November 26, 2024

The Office of Management and Budget (OMB) has renewed the Notice of Medicare Non-Coverage (NOMNC, CMS-10123), and the Detailed Explanation of Non-Coverage (DENC, CMS-10124). The NOMNC and DENC renewed notices contain updates which are applicable only to Medicare Advantage (MA) enrollees. Providers must use the current notices until December 31, 2024, and are required to use the new NOMNC and DENC beginning January 1, 2025.

The NOMNC has been modified to reflect regulations providing MA enrollees additional fast-track appeal rights when they untimely request an appeal to the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO), or still wish to appeal after they end services on or before the planned termination date.

Additionally, DENC and instructions have been updated to include a new element for health plans to complete along with special instructions for repeat appeals within the same episode of care.
HHAs, SNFs, hospices, and CORFs are required to provide a NOMNC to beneficiaries when their Medicare covered service(s) are ending. The NOMNC informs beneficiaries on how to request an expedited determination from their BFCC-QIO and gives beneficiaries the opportunity to request an expedited determination from a BFCC-QIO. A DENC is given only if a beneficiary requests an expedited determination. The DENC explains the specific reasons for the end of covered services.

The revised notices can be found on the Beneficiary Notice Initiative website and are the last four links in the download section.

Source: The Alliance, November 21, 2024

In light of a recent data breach that could compromise a beneficiary’s MBI, the Alliance submitted to the Centers for Medicare & Medicaid Services (CMS) the following question. Following the question is CMS’ response.
  • Alliance question: I am requesting clarification on the impact changes/corrections to the OASIS assessment has on the timely submission of a previously submitted assessment. We anticipate that a number of beneficiaries will be receiving new MBIs due to the CMS and Wisconsin Physicians Service Insurance Corporation (WPS) MOVEIt data breach. This change could require the HHA to open a timely submitted OASIS assessment to change the MBI so that it matches the new MBI reported on the claim. If an HHA opens a previously submitted OASIS assessment, makes the correction, and resubmits the assessment, does the submission date change to reflect the last submission date? Or is the original submission date retained?  
  • CMS answer: At this time, as the MBI number reported in M0063 must match the MBI reported on the claim, continue to follow the instructions from the Medicare Claims Processing Manual. These instructions state that when there is a new MBI on a claim, M0063 – Medicare Number must be updated so that it matches the MBI number submitted on the claim. The instructions to update the MBI do not impact compliance with the 30-day submission requirement and do not result in a change to the original submission date of the OASIS.
Below is from the Medicare Claims Processing Manual, chapter 10, section 10.1.19 – Payment Adjustments – Applying OASIS Assessment Items to Determine HIPPS Codes
 
Note: Changes to a beneficiary’s Medicare Beneficiary Identifier (MBI) can affect the match. If an HHA becomes aware of a change to the MBI via the MBI look-up tool and uses the new MBI on their claim when the prior MBI was used on the OASIS, that will cause the claim to be returned. In these cases, HHAs should update item M0063 on the OASIS and then resubmit the claim.

Source: HHS-OIG, November 29, 2024
 
Why OIG Did This Audit
  • The Provider Relief Fund (PRF), a $178 billion program, provided funds to eligible providers for health care-related expenses or lost revenue attributable to COVID-19. HHS was responsible for initial PRF program oversight and policy decisions, and HRSA administers the PRF program.
  • Providers receiving PRF payments were to ensure that the payments were: (1) used to prevent, prepare for, or respond to COVID-19; (2) used for health care-related expenses or lost revenues attributable to COVID-19; (3) not used to cover expenses or losses reimbursed by other funding sources; and (4) not used to pay salaries in excess of a certain threshold or to pay for certain prohibited activities.
  • This audit is part of a series reviewing PRF payments to various provider types. Specifically, this audit assessed whether 25 selected home health agencies (HHA) expended taxpayer funds in accordance with Federal and program requirements.
What OIG Found
  • The selected HHAs complied with terms and conditions and federal requirements for expending PRF funds.
  • The selected HHAs reported that they used $108.7 million of their PRF payments to offset lost revenues, $58.8 million for general and administrative expenses, and $42.1 million for health care-related expenses.
What OIG Recommends
The selected HHAs complied with terms and conditions and federal requirements for expending PRF funds. Accordingly, this report does not contain recommendations.
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Membership News
  
Calling all leaders! It’s time to inspire, motivate, and lead at the Twenty-Second Annual Northeast Home Health Leadership Summit. Join us for a powerful gathering of industry experts and visionaries. Register now and be part of the conversation shaping the future of home care! 
Source: Ana Handshuh & Julie Kennedy, RubyWell
 
The demand for home health services in Connecticut continues to grow as its population ages. According to Connecticut’s State Plan on Aging, adults 65 and older make up over 17% of the overall population. And their numbers are expected to increase 57% by 2040. This demographic shift will continue to drive the increasing need for home health services, particularly for patients requiring ongoing care beyond post-discharge recovery.
 
Despite the growing need, the current system presents challenges for home health agencies seeking to serve these patients. Confusion persists around documenting and demonstrating medical eligibility for ongoing home health services covered by Medicare Part B. Agencies often struggle with the nuanced requirements for skilled supervision of care plans and face potential audits or payment claw backs when patients require long-term services without discharge.
 
The payment structure of the HH PPS, including the PDGM model, quality reporting, and value-based care, all prioritize outcomes like patient improvement and cost efficiency. These mechanisms create financial disincentives for agencies to continue serving stable patients, even when ongoing care is medically necessary under the clarified standards of Jimmo v. Sebelius. These dynamics create a financial strain for agencies focused on long-term care, as the payment model rewards short-term, improvement-driven outcomes rather than the maintenance and stabilization goals central to chronic care management.