Today’s blog post comes from Senior Copywriters Erica Cohen and Char Bohnett.
In 2008, Centers for Medicare and Medicaid Services (CMS) implemented the first refinements to the Home Health Prospective Payment System (HH PPS) since its inception on October 1, 2000. One of the major changes included discontinuing the use of a single 10-therapy threshold for the purpose of payment and instead implementing three therapy thresholds at six, 14, and 20 visits. Additionally, the Affordable Care Act requires CMS to update the HH PPS rates annually; these rates are effective January 1st of each year.
According to PT in Motion News Now, on November 2nd, CMS released the final rule for the HH PPS for 2013. “The rule finalizes a reduction in rates of 1.32%, which is approximately a $10 million decrease to payments for the home health 60-day episode for [calendar year] 2013.”
Also of importance, CMS finalized “three revisions regarding the requirement that a qualified therapist complete a functional reassessment of the patient at the 14th and the 20th visit, and every 30 days.
- “If a qualified therapist missed a reassessment visit, therapy coverage would resume with the visit during which the qualified therapist completed the late reassessment, not the visit after the therapist completed the late reassessment.
- “In cases where multiple therapy disciplines are involved, if the required reassessment visit was missed for any one of the therapy disciplines for which therapy services were being provided, therapy coverage would cease only for that particular therapy discipline.
- “In cases where the patient is receiving more than one type of therapy, qualified therapists must complete their reassessment visits during the 11th, 12th, or 13th visit for the required 13th visit reassessment and the 17th, 18th, or 19th visit for the required 19th visit reassessment.” (However, if this is not feasible without providing an extra unnecessary visit or delaying a visit, then you can do so during the visit scheduled to occur closest to the 14th Medicare-covered therapy visit, but no later than the 13th.)
CMS also finalized its proposal to “allow a nonphysician practitioner in an acute or post-acute facility to perform the face-to-face encounter in collaboration with or under the supervision of the [patient’s] physician…and allow such physician to inform the certifying physician of the patient’s homebound status and need for skilled services.”
Lastly, CMS included extensive provisions on the Home Health Conditions of Participation and provided several ways in which home health agencies can meet the survey and certification requirements. Additionally, CMS explains their remedial actions should they find violations.
CMS will publish their final rule in the Federal Register on November 8, 2012. For more information, please visit the APTA’s website.
In addition to the changes to the Home Health Prospective Payment System, CMS also issued its 2013 final rule for the outpatient prospective payment system (OPPS) on November 1st. According to PT in Motion, CMS clarifies in this rule that “ it was not the intent of the agency in the [calendar year] 2012 OPPS final rule to establish different requirements for critical access hospitals (CAHs) and for OPPS hospitals for the same services. Therefore, physical therapy, speech therapy, and occupational therapy services that are paid under the OPPS are subject to the direct supervision requirements in 42 CFR § 410.27, whether they are furnished in OPPS hospitals or CAHs. The physical therapy, speech therapy, and occupational therapy services that are not paid under the OPPS and are paid instead under the Medicare Physician Fee Schedule are not subject to the direct supervision requirements in § 410.27, whether they are furnished in OPPS hospitals or in CAHs.”
Perhaps the most notable information contained in this rule is CMS’s implementation of the Medicare Part A to Part B Rebilling (AB Rebilling) Demonstration from 2012 through 2014, which “allows participating hospitals to receive 90% of the allowable Part B payment for Part A short-stay claims that are denied on the basis that the inpatient admission was not reasonable and necessary.” Participating hospitals need to simply rebill these denied Part A claims under Part B.
As this ruling has generated significant controversy, CMS has committed to taking the more than 350 public comments (summarized in the proposed rule) into consideration in future policymaking.