CY 2023 Home Health Payment Proposed Rule

Last week, CMS released the CY 2023 Home Health Payment Proposed Rule.  The news is not cheery.  In fact, as Bill Dombi, President & CEO of the National Association for Home Care & Hospice stated, “CMS has declared war on home health care”.  During the 60-day comment period which will end on August 16, 2022,…

OASIS-E Items

One of the proposed OASIS-E data items for next year is B1300-Health Literacy.  This new item asks how often the patient needs to someone help them to read instructions, pamphlets, or other written material from their doctor or pharmacy.  Possible answers range from “never” to “always” and includes options for the patient not being able…

Allowed Practitioners

In June, CMS made a clarification to a previous transmittal which allows clinical nurse specialists, physician assistants, and nurse practitioners to certify eligibility and order services under the Medicare home health benefit.  These individuals, of course, are defined as allowed practitioners.  The CMS Transmittal 11447 replaced Transmittal 11386 (previously released in April 2022) and stated…

Provider Relief Funds

If you are an organization with a fiscal year ending 12/31, now is the time to get going on your audit of the Provider Relief Funds (“PRF”) received during Period 1 and Period 2 and other HHS awards, if applicable. An audit of the HHS awards is required if your organization expended $750,000 or more…

Plan of Care Survey Deficiency

According to CMS, the top survey deficiency cited for hospice continues to be Standard §418.56(b)—Plan of Care.  This regulation is fairly straight forward; however, state surveyors consistently find deficiencies.  The issue often boils down to good communication between members of the interdisciplinary team (IDG) and adequate documentation.  The IDG is responsible for collaborating with the…

MAC Legacy Resources Awarded “CHAP Verified” Status

Home Health, Home Care and Hospice Products meet CHAP Standards DENTON, TX., May 19, 2022 – We are proud to announce that CHAP has named tools produced by MAC Legacy as “CHAP Verified” resources.  CHAP conducted a thorough product review on a number of tools to verify that they allow organizations to meet the intent…

Allowed Practitioners

Recently, CMS issued a revision to a previously released transmittal—Change Request 12615.  The subject was an update to Chapter 7, Home Health Services in the Medicare Benefit Policy Manual.  One of the items included in this transmittal was a clarification of the rule change from the CARES Act which allows clinical nurse specialists, physician’s assistants,…

OASIS-E

Home health agencies will be transitioning to a new OASIS data set, the OASIS-E, in January 2023.  The IMPACT Act established in 2014 was designed to standardize post-acute care reporting data among various providers.  SPADEs–Standardized Patient Assessment Data Elements—was a result of the IMPACT Act.  CMS’ goal is to regulate quality measures across the post-acute…

Hospice Certification

As scrutiny of hospice organizations increase, it’s particularly important for hospices to ensure their certifications and recertifications of terminal illness meet all required elements.  In the 2021 Medicare FFS Supplemental Improper Payment Data report of improper payments, the top cause for error was “insufficient documentation of the physician’s certification/recertification”.  A few short months from now,…

Emergency Preparedness

Spring in the United States brings more than beautiful flowers and green grass.  In fact, this Spring has brought snow storms, wildfires, floods, and deadly tornadoes.  The Conditions of Participation for home health, hospice, and many state licensed home services require the establishment of an emergency plan for its organization, employees, and patients. In addition…