PPS revisions will leave you scrambling at year's end -- if the deadline holds.
The 2.75 percent rate cut proposed for 2008 will hurt even more if you haven't tightened up your OASIS practices since the prospective payment system began.
The Centers for Medicare & Medicaid Services wants to cut next year's PPS rates by 2.75 percent for so-called case mix creep. The cut, which is only the first in a series of three, is part of the massive PPS refinements proposed rule issued April 27 (see Eli's HCW, Vol. XVI, No. 16).
The average case mix weight for home health patients has increased a whopping 23 percent from 1997 to 2003, CMS explains in the rule.
CMS allows that the increase between 1997 and 2000 was probably a "real change" in patients' conditions because of program changes such as the elimination of venipuncture as a qualifying service and introduction of the interim payment system. But 8.7 percent of that 23 percent, the part that happened mainly after PPS began in 2000, isn't due to patient acuity differences, CMS maintains.
Millions cut: Therefore, the agency calls for an 8.25 percent cut phased in over three years. The first 2.75 percent cut will strip $400 million from home health reimbursement in 2008 alone, CMS details in the rule.
CMS points to PPS' financial incentives and increased OASIS accuracy as reasons for the alleged upcoding of patients. Because of those changes, CMS should reduce the rates to bring the average case mix weight back to 1.00 from the 1.23 found in 2003 data, the agency proposes.
Consultant Pat Laff doesn't buy CMS' rationale behind the cut. CMS isn't placing enough emphasis on how drastically OASIS information-gathering has improved, Laff argues.
"Agencies appropriately place a big focus on OASIS accuracy," observes consultant Mark Sharp with BKD in Springfield, MO. It's only natural for HHAs to do so when both their Medicare reimbursement and outcomes scores are based on OASIS data, says Sharp, who's presenting an Eli-sponsored teleconference on the PPS changes Thurs. May 17 (for details, go to
http://goto.elinetwork.net/go/6766. Use coupon code PPSSAVE10P to receive 10 percent off the conference price).
CMS' case mix creep cut and accompanying budget neutrality factor may be "excessive," worries consultant Tom Boyd with Rohnert Park, CA-based Boyd & Nicholas. But CMS seems very firm in its upcoding assumption and may be hard to sway, predicts Boyd.
Take action: If you haven't kept up to speed on OASIS accuracy, you'd better amp up your improvement efforts quickly, experts urge. "Imagine how the impact of the case mix creep adjustment is for those agencies that haven't focused on accurate scoring," Sharp says. They "haven't seen their case mix (and payments) increase consistently with the industry." Adjustment Changes Meet With [...]
