April Brings Spring with some Stings to Home Care
April is proving to be a challenging month in the home health world. With not one, but two new CMS regulations to track, the forums are buzzing on how to manage these issues.
If you are new and trying to get a handle on all the other regulations as well, it might be even more of a challenge to grasp the details, and how to capture the required information. Let’s take a look at the new rules.
First is the face-to-face rule. F2F says that the certifying physician is required to document that he or she, or a non-physician practitioner working with the physician, has seen the patient. The encounter must occur within the 90 days prior to the start of care, or within the 30 days after the start of care. Documentation of such an encounter must include a summary of the patient’s condition, and why home health is necessary.
For a lot of detail straight from the horse’s mouth go to http://www.cms.gov/center/hha.asp. On the surface, this rule sounds somewhat reasonable. The doctor ordering home care should know what is going on with the patient. Moreover, they should not order home health for people who just do not meet homebound requirements. This assumes the doctor has a good understanding and appreciation for home care.
Of course, this is not always the case. Some of the neediest patients are so homebound that they can only see a physician if they are transported by ambulance or if the physician comes to them. This can be a major hurdle. Few doctors are willing to make house calls. An ambulance transport is expensive. The concern is that some of the neediest clients will not get the homecare they need when they can’t be seen.
Even if the physician sees the patient, getting correct documentation is also a problem. One forum writer reports “I can’t even get a face to face back that remotely meets the requirements! Even when we send a dummy copy to follow! I got the best one ever this week! All the physician wrote was ‘pt requested services’. And that’s it!!!!!!!!!!!!”
The real world knows how difficult it is to get the physician to sign a 485, where it is presumed to have been read, and agreed to. Adding another page requiring them to WRITE a summary of the patient’s condition, why they need home health and which services they need, may be a nightmare for many agencies. Of course, the company who figures out how make it easy to gain the compliance of physicians may have a new great marketing tool.
If you need sample letters related to F2F, go to the NAHC site. http://www.nahc.org/regulatory/home.html
The second challenge taking effect on April 1, 2011 is the Therapy assessments regulation. This is summarized on the CMS site, http://www.cms.gov/HomeHealthPPS/Downloads/Therapy_Requirements_Fact_Sheet.pdf
It basically encompasses Assessments at Start of Care, 30 days and 13th and 19th therapy visit timepoints.
This is a real challenge as the 13th and 19th visits are the sum total of all disciplines. This makes it a moving target on the schedule as the visit must be done by a qualified Therapist not a PTA or COTA. Small companies may not find it too difficult to keep up with on paper but I can see it becoming a very difficult challenge for even medium size companies, or companies who contract for Therapy visits.
Some quick Q and A’s I found on the HCAF web site:
The National Association for Home Care & Hospice (NAHC) received responses from CMS to the following questions.
Q: If a patient is reassessed by a therapy discipline based on the 13th or 19th reassessment requirement prior to reaching the “at least every 30 days” [point], would the 30 day reassessment count begin again with the 13th/19th visit assessment? (In other words, whenever the patient is reassessed, does the every-30-days clock start over?)
A: Yes, the 30-day clock restarts with every qualified therapist visit during which the therapist conducts an assessment and measurement and completes documentation.
Q. If a patient is receiving multiple therapy services, must one of the qualified therapists’ actually conduct a reassessment visit on the 13th/19th, or may all of the disciplines conduct their qualified therapist reassessments on the visit closest, but prior to, the 13th/19th? In other words, if PT is 10th, OT is 11th, SLP is 12th, may the PTA visit on the 13th therapy visit as long as the qualified PT assessed the patient on the 10th visit?
A: The visit close to (but before the 13th and 19th) is fine for all disciplines, when there are multiple disciplines.
Q. When we count visits to determine when the next therapy assessment is due, do we count all visits or just billable visits?
A: Count billable visits. (http://hcaf.wordpress.com/2011/02/08/cms-responds-to-therapy-assessment-and-other-questions/)
It is not hard to see why this ruling has come into effect. When you look at the government’s goal; spend fewer healthcare dollars, and the general rule for agencies, maximize care for patients and still make a little profit, it is not hard to see where this rule will push the trend. In general, I predict many agencies will settle for 12 Therapy visits or less on average. This will keep them from spending more for assessment visits and justifying more visits. Some will do it out of fear that they won’t do something right and will not get paid even though they did the visits. Some will be lost in the nightmare of trying to keep up with those 13th and 19th visit dates. Those that try to meet the challenge will have to keep it in the front of their mind with every schedule change.
This will be one more question to ask your software company. It will be interesting to see what innovative ideas will be developed. Early reports are showing that some vendors are not providing any assistance in this area, opting to leave it to the client. August Systems has two viable ways to assist you in keeping on target. We have introduced an added line to our hover hint section. When you hover over a name on the schedule, Not only will you see who is seeing the client, but you will see the Therapy visit count. It will self adjust as visits are made or cancelled. Since it is built into the system, you won’t be doing redundant work as you would a 3rd party tracking system.
The second way we have people using our system, especially where they use contract therapy for visits, is using our telephony, ClockWork. Because the telephony actually shows when visits are done, you can keep track up to the hour of which visit you are on.
I would be interested in hearing what problems and solutions you are finding relating to these new regulations. If you don’t mind sharing, just hit reply and tell me.
