Letter and Invitation from Warren Hebert

Dear Home Care Provider,

Homecare owners and administrators are crucial to our industry’s future. While agencies compete for referrals every day, we also have numerous issues of importance that require us to pull together as a team. Addressing fraud and abuse, accuracy in cost reports, and awareness of the Proposed Rule for Home Health PPS are all areas on which we can agree and collaborate. Louisiana’s top owners and administrators will be in Baton Rouge next week to hear about and discuss these areas of concern and more. The Affordable Care Act (ACA), previously called the Patient Protection and Affordable Care Act, should concern Medicare home health providers across the country.

Rebasing Medicare rates is also included in ACA. CMS will use our Medicare Cost Reports over the coming years to rebase the Medicare rates for 2014. Glen Langlinais and Joe Crouch, Louisiana CPAs with nearly 60 years experience between the two, will be presenting information compiled by the nation’s home health accounting experts from the Home Health Financial Manager’s Association. This presentation is aimed at assuring providers know how to provide accurate and complete information for their cost accountants.

As an added bonus attendees will also hear the latest on the Proposed Rule for PPS Home Health for calendar year 2011. Face to face encounters with physicians for certification and recertification, changes in therapy threshold documentation standards, and CAHPS (Consumer Assessment of Healthcare Providers and Systems) regulations will all be covered.

We hope you’ll join fellow owners and administrators for this important education and opportunity for collaboration.

Warren Hebert, RN, BSN, CAE

RWJF Executive Nurse Fellow ’06-’09Warren Hebert

Chief Executive Officer

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Reasons Why You Can’t Afford to Miss OASIS Answers’ Workshops

Did you know that there have been several major changes to many of the official source documents that instruct home health coders how to assign ICD-9 codes just since September of 2009?  Do you know which documents these are, how to access the most current version of each, what each says and most importantly how they impact your coding choices for your agency?

If you answered “no” to any of the above questions then you really should consider joining us at the next “Art of ICD-9 Coding for Home Health” workshop series.  Why?  Because if you are not aware of these changes, your coding practices could negatively impact your coding accuracy, your agency’s reimbursement and your agency’s risk adjustment.  And this outdated knowledge could attract the attention of your payers and various regulatory bodies that have kept up with these changes.

1. Appendix D

In this latest document issued by CMS (Centers for Medicare & Medicaid Services) we are given criteria for code selection for primary diagnoses, secondary diagnoses as well as when to complete M1024.  This technical document has been described by providers as confusing and was released containing errors.  CMS has issued statements since its release to correct errors, and may correct additional errors or provide additional related clarifications in the future. Even if you participated in past educational teleconferences on this topic, depending on when and how the session was presented, you may not have received the most current and authoritative information related to Appendix D. Or you may have received someone’s interpretation of how you should proceed with process or documentation changes based on what Appendix D might mean. Rumors regarding Appendix D are rampant in the home health community, and what may have been offered as advice is in some cases being viewed as a new requirement, creating unnecessary work and headaches in agencies.

You can rest assured that OASIS Answers is staying on top of this subject and is presenting the very latest direction from CMS.  It is critical that each home health coder understands what Appendix D says – as well as what it doesn’t say and which statements have since been corrected and/or clarified.  Don’t rely on other’s interpretations of this critical CMS document.  It is important that you understand the information and the subsequent corrections so that you can incorporate this information into your coding practice, and be better prepared for future clarifications that will likely be released.

2. Grouper Tables

These are the tables that tell your grouper software how to calculate your reimbursement for Medicare PPS episodes.  Did you know that there have been revisions these tables as recently as May of this year? And that of the 51 characteristics that may impact reimbursement in Medicare’s Prospective Payment System based on OASIS scoring, there are 31 possible ways that ICD-9 coding can impact your reimbursement?  Do you understand the term “Approved V code”?  Are you aware that these V codes impact how your software calculates a Home Health Resource Group that in turn, affects your reimbursement?  If you attend these classes you’ll receive the most current versions of all these tables and understand how to use them.

3. Coding Guidelines

These are the official coding “laws” that all coders must follow when assigning ICD-9 codes. While the revisions this year are minimal compared to previous years it is critical to stay on top of the changes and to make sure that you’re using the latest version.  A link will be provided so that you can download the updates as they will not be included in many of the brand new 2011 coding manuals. If any of this is news to you, you really should consider joining us at these coding workshops provided by your state home care association.

On the intermediate level day (Creating a Diagnostic Masterpiece) we continue to build on the foundational knowledge presented in the beginning class.  We cover such topics as how to access and use chapter-specific coding guidelines to code familiar home health scenarios including diabetes, stroke, cancer, hypertension and wounds.  We learn the rules for using complication, late effects, combination and V & E codes.   We take a closer look at how Medicare’s PPS impacts our coding choices.  Coding scenarios allows participants to use the new skills learned.

As you can see the skill set required to successfully assign ICD-9 codes to home health cases is highly technical, challenging and ever-changing.  Coding “truths” that we held dear last year or even a few short months ago could now result in noncompliance.   In order to become proficient at ICD-9 coding it is important to constantly learn the new rules as well as “unlearn” old rules that have become noncompliant or otherwise outdated. All this is complicated by the fact that many home health coders wear multiple hats.  If your agency is like most you are juggling more than just coding functions.  It is challenging to stay on top of all the source documents related to coding and changing rules. Given the dynamic trends in home health coding guidance, it is critical to receive credible and comprehensive updates at least once a year.

Please join us September 8th & 9th for the Art of ICD-9 Coding for Home Health: Intermediate Level Workshop. We’ll save you a chair!

Sparkle Sparks, MPT, HCS-C, COS-C

OASIS Answers, Inc.

http://oasisanswers.com

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Zone Program Integrity Contractors now Active in Louisiana

ZPIC Audits Reach Louisiana

The first news of ZPIC (Zone Program Integrity Contractor) activity in Louisiana came earlier this week. An in home provider organization received a request for 30 records, to be sent within 24 days. The records requested are for services provided from mid 2008 to March 2010.

Have you had requests from the Zone Program Integrity Contractors (ZPICs) yet? ZPICs hit HCLA’s radar in the spring of 2010 when we read about a Texas agency that had charts reviewed, visits denied, the extrapolation formula applied and a request for $2.9 million to be returned to CMS.    

ZPICs are the latest CMS enforcement weapon to detect fraud and abuse, and they target both the medical necessity of a claim and coding errors. From the operations perspective, expect ZPICs to be disruptive, time consuming for providers, and expensive when it comes to the resources necessary to address requests for information. They can also arrive unannounced, demand medical records, and interview providers and beneficiaries. They can conduct both pre and post payment reviews.

    You can find more information about the ZPICs at Medicare’s ZPIC website.  

About ZPIC Audits

Zone Program Integrity Contractors (ZPICs), which replaced Program Safeguard Contractors (PSCs), are single-function contractors.  ZPICs are responsible for (1) data analysis and data mining, (2) conducting medical reviews in support of benefit inquiry, (3) supporting law enforcement and answering complaints, (4) investigating fraud and abuse, (5) recommending recovery of federal funds through administrative action, and (6) referring cases to law enforcement.  Because ZPIC audits are commonly related to an investigation of fraud and abuse, it is essential for Medicare providers and suppliers to align themselves with qualified health care attorneys who possess an in-depth knowledge of the Medicare program and a sophisticated understanding of governing federal regulations. 

Unlike the RAC and the CERT which limit their review only to claims that have already been paid, the ZPIC will audit active claims in order to identify fraud.  When conducting an audit, ZPICs generally perform a database review of a provider/supplier’s Medicare claims.  The ZPICs will compare a provider or supplier’s Medicare billings with that of providers and suppliers of the same type within a designated area.  If the ZPIC suspects fraud or abuse, it may conduct an on-site inspection, request additional documentation, review patient records, as well as interview beneficiaries and providers.   

ZPIC audits may result in pre-payment and post-payment claims review, the initiation of administrative sanctions, such as payment suspension, overpayments, provider exclusion; and may even lead a provider/supplier being referred to law enforcement.

Want to keep learning?  Attend the Fall Leadership Summit on September 22, 2010 in Baton Rouge!

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