First major PPS refinements tackle hot button issues like therapy, LUPAs.
Home health agencies may alternately cheer and boo as they read through the massive proposed rule on the prospective payment system released April 27, but the boos will likely win out.
Good news: The Centers for Medicare & Medicaid Services addressed many of the industry's concerns with the proposed changes, notes Bob Wardwell with the Visiting Nurse Associations of America.
The rule proposes action on significant changes in condition (SCICs), the therapy threshold, low utilization payment adjustments (LUPAs), M0175, uneven allocation of payment to key home health resource groups (HHRGs), non-routine medical supplies and long-stay patients, points out Wardwell, who headed up PPS' creation and implementation when he was a top official at CMS.
"While it's hard to say yet if they have been handled well, at least [CMS has] tried," Wardwell tells Eli.
"Hallelujah!" exclaims consultant Mark Sharp with BKD in Springfield, MO, regarding the proposed elimination of M0175 as a case mix driver and SCIC episodes altogether. Both M0175 and SCICs "were widely misunderstood and resulted in a lot of confusion and inaccurate payments to providers," says Sharp, who's presenting an Eli-sponsored teleconference on the PPS changes Thurs. May 17 (for details, see ad p. 115 or go to
http://goto.elinetwork.net/go/6766. Use coupon code PPSSAVE10P to receive 10 percent off the conference price).
Bad news: But the rule also includes some serious problems for HHAs. As Eli's HCW reported in March, CMS wants to make payment cuts over successive years to make up for supposed upcoding of home health patients over time (see Eli's HCW, Vol. XVI, No. 10).
The proposal to cut rates 2.75 percent each year for three years is a "poison pill inserted by the White House on case mix creep," Wardwell blasts.
Shocker: "While the administrative adjustment for case mix creep was expected, the magnitude of the downward adjustments was a big shock," Sharp maintains. "A 2.75 percent reduction in base payment rates for each of the next three years was a greater cut than anyone expected."
Leaving caregiver and Medicaid variables out of new case mix calculations and leaving the partial episode payment (PEP) adjustment untouched is also disappointing, Wardwell adds.
Hidden cost: And CMS proposes paying for changes like LUPAs and SCICs by taking the cost out of the PPS base payment rate.
Bottom line: The case mix creep cut "greatly offsets" some positive refinements, Sharp concludes.
Here's a rundown of the most important changes in the 311-page proposed rule: Therapy Threshold As expected, CMS proposed changing the way it counts therapy towards case mix from the current, single 10-visit threshold to a new, gradual threshold at six, 14 and 20 visits with additional increments within the threshold categories (see related [...]
