Indura Systems PPS Outlier Education

In order to give our customers the information and planning they need to be able to Plan to Profit in 2010, Indura Systems is running a series of PPS Outlier Education workshops in our Miami office during December only.

Already, most of these workshops are fully booked but we may add more dates depending on demand.

The workshops will take the audience, step by step, through the changes to outlier rules and regulations, which will come in to force in January 2010.  We will also give all attendees a simple 10 step action plan to help them minimize the impact of these new regulations on their day-to-day business.

To learn more about these workshops, contact our Customer Support line at (305) 675-6704.

CMS ANNOUNCES POLICY AND PAYMENT UPDATES

News that is generating a lot of questions was posted by CMS on October 30, 2009.  Indura Systems customers can be sure that our top-rated customer support team is ready and available to answer your questions on this topic.

A link to the rule can be found below:
http://www.cms.hhs.gov/HomeHealthPPS/HHPPSRN/itemdetail.asp?filterType=none&filterByDID=0&sortByDID=3&sortOrder=ascending&itemID=CMS1230142&intNumPerPage=10

The Centers for Medicare & Medicaid Services (CMS) today announces a 2.0 percent market basket update to Medicare’s calendar year (CY) 2010 home health prospective payment system (HH PPS) rates and modifications to the home health outlier policy. These improvements are evidence of CMS’ continued efforts to ensure appropriate payments, to prevent fraud and abuse, and to protect beneficiaries in the Medicare home health program. Home health agencies (HHAs) receive additional payments (outlier payments) for 60-day home health episodes of care that carry unusually high costs. For CY 2010, CMS will cap home health outlier payments at 10 percent per HHA and target total aggregate outlier payments at 2.5 percent of all HH PPS payments. The current (2009) target for aggregate outlier payments is 5 percent of total HH PPS expenditures. By lowering the total outlier payment target to 2.5 percent, this final rule increases home health base rates by 2.5 percent for CY 2010.

“This final regulation builds on Medicare’s efforts to refine its payment systems while working to reduce waste, fraud and abuse,” said Jonathan Blum, director of CMS’s Center for Medicare Management. “Through the use of up-to-date home health data, it also provides a clearer focus for oversight of the program while encouraging better coordination of Medicare’s home health benefits.”

In this final rule, CMS continues its current policy of a 2.75 percent reduction to national standardized 60-day episode payment rates and non-medical supply factors in CY 2010. Retention of this policy will help offset the increase in the home health case-mix that is not associated with any underlying change in the actual clinical conditions of home health patients. This CY 2010 reduction is the third year of a four-year phase-in of HH PPS rate adjustments, which were made final in the HH PPS Refinement and Rate Update for the CY 2008 final rule.

Historically, home health payment rates have been updated annually by either the full home health market basket index or by an adjustment to the home health market basket index by Congress. CMS uses the home health market basket index – an inflation measurement of the costs of the mix of goods and services offered by home health agencies. The Deficit Reduction Act of 2005 (DRA) provided for an adjustment to the home health market basket percentage update for CY 2007 and subsequent years depending on quality data submissions by HHAs.

Through implementation of new payment and enrollment safeguards, this final rule will reduce Medicare’s vulnerability to fraud, abuse and improper payments. HHAs currently submit Outcome and Assessment Information Set (OASIS) data as a condition of participation in Medicare. Beginning Jan. 1, 2010, the final rule will require HHAs to submit OASIS data as a condition of payment under HH PPS.

CMS is implementing an improved version of OASIS, called OASIS-C, to collect data on all episodes of care beginning Jan. 1, 2010. This data will document important aspects of the patient’s health status including clinical condition, functional abilities, and service needs. As a result, a clinician will be able to capture a clear and accurate picture of the patient which will assist in development of an appropriate plan of care. Documentation provided through OASIS-C also could be used to signal concerns about patient health, encourage preventive care, identify needs for additional patient treatment, and record patient immunizations and vaccinations.

In CY 2010, CMS will publicly report 12 nationally accepted and approved quality measures plus 13 new process measures on its CMS Home Health Compare Web site (http://www.Medicare.gov/HHCompare) HHAs that submit required quality data will receive payments based on the full home health market basket update of 2.0 percent for CY 2010. The home health market basket index percentage will be reduced by 2 percentage points to 0.0 percent for CY 2010 for those HHAs that do not submit the required quality data. For CY 2012, CMS will require HHAs to report, as part of the required home health quality measures, the Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Home Health Care Survey for Medicare and/or Medicaid beneficiaries.

To qualify for the Medicare home health benefit, a Medicare beneficiary must be under the care of a physician and: have an intermittent need for skilled nursing care; need physical or speech therapy; or, have a continuing need for occupational therapy. The beneficiary also must be homebound and receive home health services from a Medicare approved HHA.

28th Annual Home Care and Hospice Conference and Exposition

We were delighted to attend the 28th Annual Home Care and Hospice Conference and Exposition in Los Angeles this year.  Our new booth was on display and we enjoyed talking with many visitors about our point of care system, iPOC, and introducing our new EMR product, Igea EMR, due for release in Q1 2010.

Many existing Igea customers visited us to share their delight with Igea HHC, and to offer us valuable feedback on features and functions they would like to see in future releases.  All this information is carefully documented and passed to our research and development team.

A number of visitors asked us about OASIS-C and ICD10 and we were happy to reassure them that our entire product line will remain compliant through all future changes to these standards.

Janet Rosta from the Baptist Memorial Health Care Corporation in Tennessee was the lucky winner of our Dell Mini 10 Netbook, a special prize awarded to all those who visited our booth and could answer 5 questions about Indura Systems and Igea HHC.  Congratulations to Janet.

A new newsletter will be distributed soon and will include some exciting updates and screen shots of our trade show attendance, and our Igea EMR beta release.

Medicare reimbursement for H1N1 vaccine vs. seasonal influenza

The Influenza vaccine for 2009 is reimbursed on reasonable cost, while the Influenza administration rate is reimbursed on the wage adjusted outpatient prospective payment system (OPPS) reimbursement rate.

The OPPS reimbursement rate for 2009 is $24.89. The rate is wage adjusted where the labor portion is 60% and non-labor portion is 40%.

The H1N1 vaccine is to be provided at no charge to providers therefore, there will be no provider reimbursement for the H1N1 vaccine. Medicare will reimburse providers for the administration of the H1N1 vaccine at the same rate as the influenza vaccine administration rate. Home health providers will be reimbursed at the wage adjusted amount for $24.89.

For example, in 2009, the national unadjusted payment rate is $24.89.  If the wage index for the applicable CBSA is .99, then the payment to the HHA would be $24.74

$24.89*.6=$14.934 (the portion to be wage adjusted);

$14.934*.99 (the wage index) =$14.78466 (the wage adjusted portion of the payment)

$14.78466+$9.956 (the 40% of the national unadjusted payment that is not wage adjusted) = $24.74 (after rounding)).

Home Healthcare Focus - August 2009

We are pleased to announce the publication of our August 2009 newsletter, Home Healthcare Focus.

This issue covers:

• Reacting to the Health Care Debate
• How Home Health Care Saves Billions of Dollars
• CMS Boosting Home Health Payments
• Increase in Drug Plan Premiums for Medicare
• Avoiding Falling in to the Trap of False Economy
• Health Insurance Reform Affecting Services

As well as our latest product news, tips on using Igea HHC, and our latest company news.

Read the newsletter here.

CMS issues proposed home health payment rule

The Centers for Medicare & Medicaid Services on July 30 proposed a net decrease of -0.86% in Medicare payments for home health agencies in calendar year 2010. This includes a 2.2% market basket update, which would be decreased by 2.75% as part of a four-year series of cuts that adjust for coding changes between 1999 and 2005. In addition, the rule states that CMS is considering additional coding reductions, based on further analysis of case mix change, that could lower 2010 payments by -4.90.

The proposed rule would also cap outlier payments at 10% per agency and limit total outlier payments to 2.5% of total HH PPS payments. The rule will be published in the Aug. 6 Federal Register with comments accepted through Sept. 28.

Home health agencies (HHAs) receive additional payments (outlier payments) for 60-day home health episodes of care that carry unusually high costs. CMS proposes to cap outlier payments at 10 percent per agency and target total aggregate outlier payments at 2.5 percent of total HH PPS payments. Currently, the target for outlier payment targets is 5 percent of total HH PPS payments. As such, CMS reduces home health rates by 5 percent to fund outlier payments. By lowering the total outlier payment target to 2.5 percent of total HH PPS payments, CMS would increase home health rates by 2.5 percent.

Read the full article.

Presidential Report Confirms Health Care Jobs On The Rise

We didn’t have to read the new jobs report from Obama’s Council of Economic Advisers to know that health care’s going to add a lot of jobs over the next several years.

But we were interested in the report’s finding that the biggest job growth of any category in the economy would come not for doctors, nurses, or nursing home workers, but for a broadly defined group called “other medical services and dentists.”

The report defines that group as “a broad category including the ever-expanding home health care, outpatient care, and medical and diagnostic laboratories subsectors,” and projects more than 2 million new jobs per year for the group, on average, between 2008 and 2016.

A separate projection looks at the growth of health-related jobs versus all other occupations between 2000 and 2016. The finding: 12% growth for “other occupations”; 35% growth for “health practitioners”; and 48% growth for “health care support.” Health care support includes physical therapists, physical therapist assistants, medical social workers and home health care aides, the report says.

Joint Commission Offers Seasonal Flu Immunization Strategies

Free Monograph Designed to Improve Health Care Worker Vaccination Rates

(OAKBROOK TERRACE, Ill. – June 24, 2009) Seasonal influenza in health care workers is a personal health threat, but also poses a significant risk to the patients in their care. In an effort to help health care organizations improve the rate of health care worker influenza vaccinations, The Joint Commission is releasing a monograph “Providing a Safer Environment for Health Care Personnel and Patients Through Influenza Vaccination: Strategies from Research and Practice.”

The monograph, which was supported by an educational grant from sanofi pasteur, is the result of the project Strategies for Implementing Successful Influenza Immunization Programs for Health Care Personnel, a 10-month collaboration between The Joint Commission, the Association for Professionals in Infection Control and Epidemiology, Inc. (APIC), the Centers for Disease Control and Prevention (CDC), the Society for Healthcare Epidemiology of America (SHEA), and the National Foundation for Infectious Diseases (NFID).

The monograph includes information about seasonal influenza and the influenza vaccine, barriers to successful programs and strategies for overcoming them, and examples of successful initiatives organizations have used to improve their influenza vaccination rates. The Joint Commission received more than 229 submissions from health care organizations and a subset of submissions was selected for a panel review. Ultimately, 28 submissions were selected for inclusion in the monograph.

The monograph incorporates evidence-based guidelines and published literature to highlight practical strategies and the tools submitted by health care organizations. Electronic copies of the monograph are available on The Joint Commission’s Web site at www.jointcommission.org, and can be downloaded free of charge.

“Health care worker flu vaccination rates have been less than optimal for years and the vaccination rate is still below 50 percent. Organizations are eager to find ways to encourage their employees to get vaccinated,” says Jerod M. Loeb, Ph.D., executive vice president, Division of Quality Measurement and Research, The Joint Commission. “The monograph includes strategies that organizations can employ and provides a foundation to improve vaccination rates.”

According to the CDC, vaccination coverage of health care personnel remains low despite the documented benefits on patient outcomes, staff absenteeism and reducing infections among staff. In addition, increased vaccination rates can reduce costs within health care organizations. Health care personnel can acquire seasonal influenza from patients and can also spread the disease to vulnerable patients or other staff. In 2007, The Joint Commission implemented a new standard in hospitals and long term care facilities requiring that influenza vaccinations be offered to staff and practitioners.

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Founded in 1951, The Joint Commission seeks to continuously improve the safety and quality of care provided to the public through the provision of health care accreditation and related services that support performance improvement in health care organizations. The Joint Commission evaluates and accredits more than 16,000 health care organizations and programs in the United States, including more than 8,000 hospitals and home care organizations, and more than 6,200 other health care organizations that provide long term care, behavioral health care, laboratory and ambulatory care services. In addition, The Joint Commission also provides certification of more than 600 disease-specific care programs, primary stroke centers, and health care staffing services. An independent, not-for-profit organization, The Joint Commission is the nation's oldest and largest standards-setting and accrediting body in health care. Learn more about The Joint Commission at www.jointcommission.org.

HCAF Show - Orlando, FL June 24 and 25 2009

Stop by and meet us at booth 25 in Orlando. We want to give you something!

Bring along one or two of the forms that you use in your home health care agency, in Microsoft Word or Microsoft Excel formats, on a CD or USB stick, and we will convert them to digitized forms while you wait - no charge!

While we convert your forms, we will show you home health care agencies are increasingly turning to point of care solutions to make it easier for caregivers to capture and deliver notes for their entire treatment schedule. This helps agencies submit their bills faster - no more searching for visit notes, no more transcribing of notes in to other systems.

Come and meet our team at booth 25, HCAF Show, Omni Orlando Resort at Championsgate, Orlando, Florida, 5:00pm to 7:30pm on June 24th, and 7:00am to 6:30pm on June 25th, 2009.

To call ahead to schedule an appointment, phone (305) 675-6704 and ask for Marc on extension 704.

ENSURE APPROPRIATE PAY FOR HEALTH SERVICES

ENSURE ADEQUATE AND APPROPRIATE PAYMENT
FOR MEDICARE HOME HEALTH SERVICES

ISSUE: The Centers for Medicare & Medicaid Services (CMS) administratively has promulgated a 2.75 percent across-the-board rate reduction for home health services for 2008, 2009, and 2010, as well as a 2.71 percent cut for 2011. The 2.75 percent cuts scheduled for 2008 and 2009 have been implemented. Over the next five years (2009- 2013) these cuts will reduce outlays for home health by $7.59 billion unless Congress blocks them. These reductions are based on an unfounded allegation by CMS that case mix weights have increased without attendant changes in patient characteristics, referred to by CMS as “case mix creep” or “upcoding.”

In its 2009 report to Congress, the Medicare Payment Advisory Commission(MedPAC) recommended that Congress eliminate the home health market basket update for 2010 and accelerate the application of the 2011 coding creep adjustment proposed for 2011 (2.71 percent) to 2010—reducing current rates in 2010 by 5.46 percent. MedPAC also recommended that Congress direct CMS to rebase home health payments in 2011, using 2007 costs as a base.

A 5 percent rural payment differential or “rural add-on” for home health services delivered in rural areas expired on December 31, 2006. This has resulted in rural home health agency closures and threatened access to home health care for beneficiaries living in rural areas.

In February 2009, the Obama Administration included MedPAC’s 2009 recommendations for deep cuts to home health as part of its proposed FY 2010 budget. Over five years these harmful cuts would take more than $13 billion from the Medicare home health program. The administration’s budget also calls for the bundling of hospital and post acute care payments beginning in 2013.

RECOMMENDATION: Congress should: 1) Reform the Medicare home health payment model to achieve a more reliable payment distribution that reflects varying resource uses and costs incurred in providing care to individual patients; 2) Reject any proposals to cut the home health market basket inflation update or impose additional rate reductions for home health agencies; 3) Reinstate the 5 percent add-on payment for home health services in rural areas; 4) Block the home health case mix rate reductions and reform the regulatory process for evaluating case mix changes; and 5) Reject proposals to bundle home health payments into hospital or other provider payments.

RATIONALE:
• MedPAC’s proposed freeze in home health payments, coupled with the CMS regulatory payment reductions and rebased payment rates, would reduce home health payments by $550 million in 2010, by 2.5 billion in 2011, and by $13 billion from 2010 through 2014. These cuts would come from a benefit that is about $15.5 billion per year ($2 billion less than in 1997) and under control in terms of expenditure growth.

• Currently, about one third of Medicare home health agencies (HHAs) have negative Medicare profit margins. The National Association for Home Care & Hospice (NAHC)as calculated that by 2011, nearly two-thirds of home health agencies will have negative Medicare profit margins if MedPAC’s proposed freeze, accelerated CMS regulatory cuts,and rebasing of payment rates are implemented.

• MedPAC fails to evaluate the impact on care access that occurs with the current wide ranging financial situation of HHAs. Regardless of average margins, there is a wide range in agency margins and thus a wide range in impact that the proposed across-the board cuts in payments would have. There is no evaluation to date of the completely reformed home health payment model put in place in 2008. In the event that the wide range in margins continues, a more sophisticated payment model connecting payments to resource use should be developed.

• MedPAC’s proposal to reduce home health payments is based on claims that home health agencies are making excessive profit margins on Medicare services. MedPAC’s financial analysis of Medicare HHAs, projecting a 12.2 percent margin for 2009, is unreliable. First, it does not include any consideration of the 1,626 agencies (21 percent)that are part of a hospital or skilled nursing facility. In some states, hospital-based HHAs make up the majority of the providers (ND 85.0 percent; SD 76.5 percent; MT 66.7 percent; OR 63.0 percent). Facility-based HHAs have an average Medicare profit margin of negative 6.19 percent. Second, the MedPAC analysis uses a weighted average,combining all HHAs into a single unit, rather than recognizing the individual existence and local nature of each provider. It sees a single national profit margin for freestanding agencies as representative of over 9,700 very diverse HHAs. When all agencies’ margins are included and given equal weight, the true Medicare margin would be closer to 5 percent. About one third of home health agencies currently have negative margins. Third, MedPAC margin data fails to recognize many agency costs, including the cost of telehealth equipment, increasing costs for labor, emergency and bioterrorism preparedness, and system changes to adapt to the new home health payment changes.

• Home health agencies are already in financial jeopardy as a result of Medicaid cuts and inadequate Medicare Advantage and private pay rates. Ongoing study of home health cost reports by the National Association for Home Care & Hospice indicates that the overall financial strength of Medicare home health agencies is weak. The average allpayor profit margin for freestanding HHAs is reduced to 4 percent when taking into account losses from non Medicare payors.

• Recent cost reports reveal that the average Medicare margin for rural agencies is negative 3.52 percent. The loss of the 5 percent rural add-on payment for home health services in rural areas has resulted in reductions in service areas, agency closures, and reports that some agencies had to turn away high resource use patients who are more expensive for agencies to serve. In many rural areas home health agencies can be the primary caregivers for homebound beneficiaries with limited access to transportation.

• The “case mix creep” adjustment ignores increases in patient acuity, particularly a significant increase in orthopedic and neurologically impaired patients requiring restorative therapy. These changes in patient characteristics are documented in a report from the Lewin Group and directly correlate with changes in case mix weights.

• CMS alleges that the entire change in the average case mix weights between 1999 and 2005 is the result of provider upcoding or factors unrelated to changes in patient characteristics. If this had occurred one would expect to see a big increase in Medicare home health expenditures. In fact, as the chart below indicates, Medicare home health expenditures are far lower than the Congressional Budget Office (CBO) had expected under the new Home Health Prospective Payment System and are $2 billion less than in 1997.

• Bundling home care payments into hospital or other provider payments would severely compromise both the quality and availability of home health care for Medicare beneficiaries. It would cause major disruption to the health care industry, be anticompetitive, increase the federal regulatory burden and erect a new and unnecessary barrier to beneficiaries’ access to quality care. Hospitals have no experience in the management of post acute care and no infrastructure to manage utilization review. Hospitals are the highest cost sector so this is not the place to locate efficiencies in post acute care. If bundled payments are considered, they should go to community-based providers that have a breadth of experience in providing post acute care and avoiding unnecessary hospitalizations.

TAKE ACTION NOW:

http://www.congressweb.com/cweb4/index.cfm?orgcode=nahc