Additional Documentation Request (ADRs) New Time Line
Change Request 9323 issued by Medicare has been released and dictates how MACs or intermediaries start counting down the time they have to respond to an ADR. MACs have 60 days to respond to your submission as long as you submitted the documentation within the 45 day window.
Probe and Educate
CMS has started to conduct pre-payment review on home health claims for episodes that began on or after August 1, 2015. CMS has delegated this task to MACs who have been instructed to begin sending letters out after October 1, 2015.
The purpose of the audit is to help provide education to agencies on the new requirements of certifying a patient. An end date for this exercise has not been issued, which likely means it could go on forever.
Get Ready for the Next Disaster
All healthcare providers are required to have a disaster plan in place should something catastrophic occur. To help with identifying resources and whom to go to for assisting your agency and patients, the US Department of Health and Human Services (DHS) launched TRACIE (Technical Resources, Assistance Center and Information Exchange). The resources include live assistance by phone, online databases of information, and a discussion board. If your agency doesn’t have a disaster plan in place, you must get on this before winter comes! We have information available, should you need any assistance. To access TRACIE, go to: https://asprtracie.hhs.gov/.
The National Association for Home Care, along with several others, had filed a motion to stay (prevent) the new overtime law from taking effect this month. The motion was not granted and the Department of Labor’s enforcement will take place. Agencies should ensure all clinical staff be capped at 40 hours or pay overtime. Failure to do so will be a violation of the Fair Labor Standards Act, which could result in significant penalties.
Several DC lawmakers are not happy with CMS’ proposed 2016 cuts and have called for a rollback. The $350 million cut has been called absurd and a real threat to all agencies, especially those that provide services in rural areas. Additionally, several key policymakers have been in contact with CMS regarding the Value Based Purchasing trial that is expected to start on January 1, 2016.
The group is concerned that the data being used (2000-2010) is out of date and should be based on 2014 data. Also, home health is the only provider group that will be receiving such a large cut; 5% for the value based purchasing model. Hospitals and nursing homes are under a similar trial program but have their maximum cut set to 2%. We will keep you updated on this as it develops.