by Tim Rowan

Coordinating the efforts of six different technology vendors may soon be a thing of the past for clients of Springfield, Missouri-based healthcare at home software and services provider HEALTHCAREfirst. The company has assembled all of its products and services into a bundle that it will be calling its “Solution Suite.” The pricing model will change as well, with a single monthly payment for the bundle instead of separate charges for each component. (more…)

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by  Jason Lewallen

When business is slow and cash flow falters, many healthcare providers, like all business owners, face some tough choices. Simple math forces the business rule that financial outlays must be adjusted to match shrinking revenue. How an owner handles those critical moments often determines success or failure.

Time after time, I see one particular mistake repeated. (more…)

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By Tim Rowan, editor and publisher
The Centers for Medicare and Medicaid Services (CMS) is seeking approval from the Office of Management and Budget to initiate a new “probable fraud measurement” pilot. The request is for permission to initiate another home health data collection mechanism but, to make OMB approval easier, CMS is classifying it not as a new request but as an “extension of a currently approved collection.” [Details about this proposal are provided in this article, as are details about a second request by CMS, this one to test the practice of requiring prior authorization for all home health services before a claim for those services can be submitted. The author describes how healthcare at home agencies might be affected by suspected fraudulent activity, and also stresses the importance for healthcare at home agencies to submit comments and recommendations about these proposals to CMS representatives and providers this contact information.]

The request has been published in the Federal Register as a proposed rule with a 60-day public comment period, which ends on April 5.

In part two of the same CMS publication, the agency has a second request which it does categorize as a “new data collection.” It wants to test the practice of requiring prior authorization for all home health services before a claim for those services can be submitted. Comments from the public are urgently needed for this proposal.

The complete text of CMS’s two requests, plus information about how to submit your comments, are printed here for your reference.

Keep in mind: as with existing MAC, ZPIC, and RAC efforts to identify improper payments, there will be no effort by CMS to differentiate between fraud resulting from criminal intent or fraud resulting from honest errors, failure to fully document medical necessity, or any other slip-up by otherwise honest providers. Should prior authorization become a final rule one day, it will become more urgent than ever to enhance clinical practice, especially regarding documentation QA, in order to avoid even the appearance of fraudulent intent.

1. Type of Information Collection Request: Extension of a currently approved collection
Title of Information Collection:Medicare Probable Fraud Measurement Pilot
Use:The Centers for Medicare & Medicaid Services (CMS) is seeking Office of Management and Budget (OMB) approval of the collections required for a probable fraud measurement pilot. The probable fraud measurement pilot would establish a baseline estimate of probable fraud in payments for home health care services in the fee-for-service Medicare program. CMS and its agents will collect information from home health agencies, the referring physicians and Medicare beneficiaries selected in a national random sample of home health claims. The pilot will rely on the information collected along with a summary of the service history of the HHA, the referring provider, and the beneficiary to estimate the percentage of total payments that are associated with probable fraud and the percentage of all claims that are associated with probable fraud for Medicare fee-for-service home health.
Form Number:CMS-10406 (OMB Control Number 0938-1192);
Frequency:Annually;
Affected Public:Individual and Private Sector (Business or other for-profits);
Number of Respondents:6,000;
Total Annual Responses:6,000;
Total Annual Hours:7,500.
(For policy questions regarding this collection,  contact Cecelia Franco at (786) 313-0737).

2. Type of Information Collection Request:New Collection
Title of Information Collection:Medicare Prior Authorization of Home Health Services Demonstration;
Use: Section 402(a)(1)(J) of the Social Security Amendments of 1967 (42 U.S.C. 1395b-1(a)(1)(J)) authorizes the Secretary to “develop or demonstrate improved methods for the investigation and prosecution of fraud in the provision of care or services under the health programs established by the Social Security Act (the Act).” In accordance with this authority, we seek to develop and implement a Medicare demonstration project, which we believe will help assist in developing improved procedures for the identification, investigation, and prosecution of Medicare fraud occurring among HHAs providing services to Medicare beneficiaries.

This demonstration would help assure that payments for home health services are appropriate before the claims are paid, thereby preventing fraud, waste, and abuse. As part of this demonstration, we propose performing prior authorization before processing claims for home health services in: Florida, Texas, Illinois, Michigan, and Massachusetts.

We would establish a prior authorization procedure that is similar to the Prior Authorization of Power Mobility Device (PMD) Demonstration, which was implemented by CMS in 2012. This demonstration would also follow and adopt prior authorization processes that currently exist in other health care programs such as TRICARE, certain state Medicaid programs, and in private insurance.

The information required under this collection is requested by Medicare contractors to determine proper payment or if there is a suspicion of fraud. Medicare contractors will request the information from HHA providers submitting claims for payment from the Medicare program in advance to determine appropriate payment.
Form Number:CMS-10599 (OMB Control Number: 0938-NEW)
Frequency:Occasionally
Affected Public:Private sector (Business or other for-profits and Not-for-profits)
Number of Respondents:908,740
Number of Responses:1
Total Annual Hours: 454,370. (For questions regarding this collection contact Carla David (410) 786-4799.)

Dated: February 2, 2016

William N. Parham, III, Director, Paperwork Reduction Staff, Office of Strategic Operations and Regulatory Affairs.

How to submit your comment
When commenting, please reference the document identifier or OMB control number:

Regulations.gov Docket Info

To be assured consideration, comments and recommendations must be submitted in any one of the following ways:

1. Electronically. You may send your comments electronically to regulations.gov. Follow the instructions for “Comment or Submission” or “More Search Options” to find the information collection document(s) that are accepting comments.

2. By regular mail. You may mail written comments to the following address: CMS, Office of Strategic Operations and Regulatory Affairs, Division of Regulations Development, Attention: Document Identifier/OMB Control Number: CMS-10406 and CMS-10599, Room C4-26-05, 7500 Security Boulevard, Baltimore, Maryland 21244-1850.

To obtain copies of a supporting statement and any related forms for the proposed collection(s) summarized in this notice, you may make your request using one of following:

1. Access CMS’ Web site address at http://www.cms.hhs.gov/PaperworkReductionActof1995.

2. Email your request, including your address, phone number, OMB number, and CMS document identifier, to Paperwork@cms.hhs.gov.

3. Call the Reports Clearance Office at (410) 786-1326.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com

 

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ALEXANDRIA, Va., — On February 24, the National Hospice and Palliative Care Organization and its affiliated organizations (National Hospice Foundation, Global Partners in Care, and Hospice Action Network) announced that President and Chief Executive Officer J. Donald Schumacher, PsyD, will retire at the end of 2016. Schumacher has been president and CEO of NHPCO since 2002. [Schumacher’s accomplishments during his 40+ years’ involvement with all matters related to hospice and palliative care are detailed in this article.]

Schumacher’s decision to retire comes after more than four decades of service on behalf of hospice and palliative care at the community provider level as well as in national and international leadership roles.

“I look back on these years and what stands out so vividly in my mind has been the opportunity to work with so many individuals who have dedicated their professional lives to caring for others. I have visited hospice and palliative care programs of all kinds in every corner of this country and have had the opportunity to engage with professionals, volunteers and supporters who have taught me important lessons every single day. I have met with an untold number of legislators and administrators sharing the hospice and palliative care story. I have spent time at the bedside of the dying and their family members – and I have been privileged to learn from them all,” said Schumacher.

A committee under the direction of NHPCO Board Chair Linda Rock will lead a national search for Schumacher’s successor. The organization’s current leadership team anticipates smooth operation during this period of transition.

Representative accomplishments during Schumacher’s tenure as president and CEO include:

  • Consistent membership retention levels averaging 96 percent every year.
  • Development of Hospice Action Network, a grassroots advocacy network in excess of 60,000 hospice advocates and supporters.
  • Successful efforts to increase more timely and appropriate levels of hospice oversight by federal regulators and protection of the Medicare hospice benefit.
  • Launch and successful growth of the We Honor Veterans initiative created in partnership with the Department of Veterans Affairs.
  • The award winning national engagement campaign, Moments of Life: Made Possible by Hospice.
  • Expansion of the work of Global Partners in Care to nations beyond sub-Saharan Africa.
  • Creation of the National Center for Care at the End of Life as the permanent home of NHPCO and its affiliated organizations.

From 1989 until he joined NHPCO, Schumacher served as the president and CEO of The Center for Hospice and Palliative Care in Buffalo, where he led the development of integrated hospice and palliative care programs. Prior to that, he was the president and founder of the Hospice of Mission Hill in Boston, which was established as one of the first HIV/AIDS hospices in the U.S.

A globally recognized authority on hospice and palliative care, Schumacher has been active throughout his career as a member and officer of various industry organizations.  He currently serves on the boards of the National Health Council and the World Hospice and Palliative Care Alliance. An active public speaker, he has presented domestically and internationally on topics such as strategic planning for hospices, quality and access to care, palliative care policy development, and clinical guidelines for HIV.

Schumacher is a licensed clinical psychologist in New York and Massachusetts and holds a doctorate degree in psychology from the Massachusetts School of Professional Psychology, Boston. Among his professional awards, in 2005, he received the Distinguished Alumni Award from the State University of New York at Buffalo, where he earned his M.S. degree in counseling psychology.

Don Schumacher has worked tirelessly for our members and those we serve. Through his strategic leadership, we have seen a strengthened, unified hospice and palliative care community that is working to increase access, promote quality, and expand the vision of care for people living with serious and life-limiting illness,” said NHPCO Board Chair Linda Rock.

Schumacher will be honored at this year’s annual National Hospice Foundation Gala on April 22, 2016.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com

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Submitted by Jami Albro-Fisher, CIO
Fazzi Associates

Dear Editor,

Thanks for the write-up on Hollywood Presbyterian. I agree that it is difficult or even impossible for users to recognize when an email is infected. The samples you provided will help. [The author provides several tips for avoiding/preventing ransomware attacks. based on personal experience as CIO at Fazzi Associates.]

 

However, there is another important lesson for agencies. Why did it take Hollywood Presbyterian 10 days to recover from the attack? Of course, we may never know the details but a few best practices can drastically reduce the impact and down time.

First, frequent backups of their file system would have enabled them to quickly recover everything since the last good backup. The ransomers would have had no power over them. Backup frequency for mission critical systems should be at least daily. Better yet, hourly, 15-minute, or even continuous backups are possible.

Second, limiting execution privileges on workstations where malware tries to run could entirely prevent damage. System administrators can easily make this change.

Finally, there is documentation available on the internet with additional measures IT managers can consider. Here is just one example.

I am speaking from experience. We were hit with the same ransom malware last year. So we know it can happen to anyone. But while the malware was attempting to encrypt our files, we were able to discover it and get it stopped within 26 minutes, not 10 days as in the hospital’s case. We diagnosed the problem and recovered every file from backups with just a few hours of downtime. Without that backup, we would have been much worse off.

Jami Albro-Fisher, CIO
Fazzi Associates

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com

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by Tim Rowan

SAN DIEGO, Calif.Feb. 22, 2016/PRNewswire/ResMed (NYSE:RMD), the world’s leading tech-driven medical device company and innovator in sleep-disordered breathing and respiratory care, today announced a definitive agreement to acquire privately held Brightree®, a leader in business management and clinical software applications for the post-acute care industry. This acquisition adds to (more…)

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“It happened to me, and it could happen to you.”

This lyric from the 60’s Supremes song, “The Happening” would be good to keep in mind when you read the story about a major hospital being hit by ransomware, the hacker attack that locks you out of your own data until you pay them an exorbitant amount of money. (more…)

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By Tim Rowan, Publisher of Home Care Technology Report

This week, the Centers for Medicare & Medicaid Services and America’s Health Insurance Plans, the insurance industry’s lobbying arm, as part of a broad Core Quality Measures Collaborative of health care system participants, released seven sets of clinical quality measures. These measures support multi-payer alignment, for the first time, on core measures primarily for physician quality programs. This work is informing CMS’s implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) through its measure development plan and required rulemaking, and is part of CMS’s commitment to ensuring programs work for providers while keeping the focus on improved quality of care for patients.

Partners in the Collaborative recognize that physicians and other clinicians must currently report multiple quality measures to different entities. Measure requirements are often not aligned among payers, which has resulted in confusion and complexity for reporting providers. To address this problem, CMS, commercial plans, Medicare and Medicaid managed care plans, purchasers, physician and other care provider organizations, and consumers worked together through the Collaborative to identify core sets of quality measures that payers have committed to using for reporting as soon as feasible. This release is the first from the Collaborative, which plans to add more measure sets and update the current measure sets over time. CMS and the partner organizations believe that by reducing the complexity for providers and focusing quality improvement on key areas across payers, quality of care can be improved for patients more effectively and efficiently. [The author presents details about core quality measurements identified by the Core Quality Measures Collaborative, led by AHIP and its member plans’ Chief Medical Officers, leaders from CMS and the National Quality Forum (NQF), among other participants; and indicates how, in various stages, implementation of core measures will accelerate the achievement of value-based payment throughout the healthcare system.]

 

“In the U.S. Health care system, where we are moving to measure and pay for quality, patients and care providers deserve a uniform approach to measure quality,” said CMS Acting Administrator Andy Slavitt. “This agreement today will reduce unnecessary burden for physicians and accelerate the country’s movement to better quality.”

Measure Development: “Improving Quality and Making the Physicians’ Lives Easier”

The Core Quality Measures Collaborative, led by AHIP and its member plans’ Chief Medical Officers, leaders from CMS and the National Quality Forum (NQF), as well as national physician organizations, employers, consumers, and patient groups worked hard to reach consensus on these core measure sets.

The guiding principles used by the Collaborative in developing the core measure sets are that they be meaningful to patients, consumers, and physicians, while reducing variability in measure selection, collection burden, and cost. The goal is to establish broadly agreed upon core measure sets that could be harmonized across both commercial and government payers.

The core measures are in the following seven sets:

  • Accountable Care Organizations (ACOs), Patient Centered Medical Homes (PCMHs), and Primary Care
  • Cardiology
  • Gastroenterology
  • HIV and Hepatitis C
  • Medical Oncology
  • Obstetrics and Gynecology
  • Orthopedics

“The AAFP’s involvement in the Collaborative is aimed at improving the quality of care while making family physicians’ lives easier by simplifying the information they are being asked to provide to payers,” said Douglas E. Henley, MD, Executive Vice President and Chief Executive Officer of the American Academy of Family Physicians. “We are acutely aware of the huge amount of administrative complexity and burden that impacts the daily work of our members and diverts time and resources away from direct patient care. A major part of this is the burden of multiple performance measures in quality improvement programs with no standardization or harmonization across payers. This agreement on a set of core measures for primary care and the PCMH represents a big step toward the goal of administrative simplification for family physicians and improved quality of care.”

Implementation: “Accelerating the Shift to Value-Based Payment”

Implementation of the measures will occur in several stages.

  • CMS is already using measures from the each of the core sets. Using the notice and public comment rule-making process, CMS also intends to implement new core measures across applicable Medicare quality programs as appropriate, while eliminating redundant measures that are not part of the core set.
  • The Health Care Payment Learning and Action Network (HCPLAN), a public-private collaboration established by CMS, will integrate these quality measures into their efforts to align payment model components with public and private sector partners.
  • CMS is working with federal partners including the Office of Personnel Management, Department of Defense, and Department of Veterans Affairs, as well as state Medicaid plans to align quality measures where appropriate.
  • Commercial health plans will implement these core sets of measures as and when contracts come up for renewal or if existing contracts allow modification of the performance measure set. 
  • The Core Quality Measures Collaborative views the upcoming year as a transitional period, as it begins adoption and harmonization of the measures. Ongoing monitoring by the Collaborative of the use of these measures will enable modifications of measure sets, as needed and based on lessons learned, including minimizing unintended consequences and selection of new measures as better measures become available.

“Health Care Service Corporation has long supported efforts such as the Core Quality Measure Collaborative that improve care quality in ways that are sustainable, accessible and equitable for our members and all consumers,” said Dr. Stephen Ondra, Senior Vice President and Chief Medical Officer, Health Care Service Corporation. “Today’s announcement by the Core Quality Measure Collaborative is an important step in getting payers, providers, purchasers and consumers on the same page when they measure and compare health care quality. The efforts announced today will make health quality data more easily understood, less burdensome to collect and more relevant to the needs of all stakeholders. This work will ultimately help accelerate the shift toward payment models that are based on the value of care, rather than the volume.” 

The Collaborative will continue to convene to monitor progress, invite broader participation, and add additional measures and measure sets. 

“Members of the Collaborative have taken a leadership role in identifying measures that will drive quality improvement and outcomes for patients,” said Carmella Bocchino, Executive Vice President, America’s Health Insurance Plans. “This is a first step of an ongoing process to ensure both public programs and the private sector align measures and reporting especially as we advance alternative payment models.” Patient groups were a vital part of the Collaborative and their participation is critical to ensure that people receive the benefit of high quality care. 

“Our health care system urgently needs measurement that drives improvements in quality, supports informed consumer decision-making and ensures we’re paying for and incentivizing high-value care. What we released today is a start at achieving consensus on the best measures, but we need to continue pushing for even better ones,” said Debra L. Ness, president of the National Partnership for Women & Families. “We need measurement that works for clinicians and helps them improve care, while also providing information that is meaningful and actionable for patients and families. Alignment across payers is key to making sure measurement doesn’t waste resources or create unnecessary burden. Ultimately, it plays a foundational role in achieving better health and better health care at lower costs.” 

For more information on this announcement, please see:

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com

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 by Audrey Kinsella

The CMS-directed Value-Based Purchasing (VBP) program is new to the healthcare at home service industry. But it is not at all unfamiliar to the much wider healthcare service delivery realm. The Home Health Value-Based Purchasing program model, about which CMS posted its final rule on November 5, 2015, leverages the successes of and lessons learned from other CMS-initiated value-based purchasing programs and demonstrations. These predecessors include the Hospital Value-Based Purchasing Program and Home Health Pay-for-Performance Demonstration, https://innovation.cms.gov/initiatives/home-health-value-based-purchasing-model

The purpose of these programs is to shift focus from volume-based, fee-for-service payments toward incentives that promote quality care delivery to Medicare beneficiaries. The HHVBP model will test whether incentives for better quality care can improve outcomes in the delivery of healthcare at home services.

It may be too soon to learn from the experiences of the healthcare at home agencies in the nine demonstration states how to achieve desired results from HHVBP (The demonstration began 1/1/16 in Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee). However, a new report, titled “The Essential Guide to the Home Health Value-Based Purchasing Program,” has just become available from Advanced TeleHealth Solutions (www.advanced-telehealth.com/essential-guide).

This guide provides in-depth detail about the program and its rules, and the author’s intention is stated at the outset: “to help home health agencies succeed with HHVBP, including advice on how to harness remote patient monitoring to improve their chances of HHVBP success.”

 

The guide also contains critical information on the 24 outcomes and process measures included in HHVBP. It provides help calculating a “Total Performance Score” and its impact on reimbursement, plus other details for HHAs wanting to start out on a sure footing when VBP becomes the law for all.

Planning for HHVBP is by no means a leisurely pastime. Not only are there indications in recent news that all HHAs will be required to provide VBP services, but there are also reports that quality performance will be assessed on a competitive basis. Details on the CMS site about payments provided to HHAs in the nine demonstration states note payment adjustments to be applied until 2022, as follows:

  • a maximum payment adjustment of 3 percent (upward or downward) in 2018,
  • a maximum payment adjustment of 5 percent (upward or downward) in 2019,
  • a maximum payment adjustment of 6 percent (upward or downward) in 2020,
  • a maximum payment adjustment of 7 percent (upward or downward) in 2021, and
  • a maximum payment adjustment of 8 percent (upward or downward) in 2022.

Business as usual is being redefined yet again for healthcare at home providers. Agencies in the 41 states not participating in the VBP demonstration have been given a gift, both of time to prepare and to benefit from others’ experiences. Use it.

Audrey Kinsella, MA, MS, is HCTR’s telemedicine reporter. She has written on home telehealthcare and new technologies for home care service delivery for 20 years, in 6 books, multiple web sites, and more than 150 published articles. Audrey can be reached at audreyk3@charter.net or 828-348-5308.

©2015 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. homecaretechreport.com One copy may be printed for personal use; further reproduction by permission only. editor@homecaretechreport.com

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by Elizabeth Hogue, Esq.

Overpayments are defined as any funds that providers receive or retain under Title XVII of the Social Security Act to which providers, after applicable reconciliation, are not entitled. The Centers for Medicare and Medicaid Services (CMS) has issued a final rule on return of overpayments by providers. Below are key requirements of the final rule.  (more…)

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