Regulations:
WATCH OUT FOR EVEN BIGGER CASE MIX CREEP CUTS
Published on Mon Aug 06, 2007
CMS promises PPS billing info shortly in Open Door Forum.
Home health agencies thinking they'll take their PPS medicine and be done with it must think again.
In its proposed prospective payment system refinements issued in April, the Centers for Medicare & Medicaid Services wanted an 8.25 percent cut over three years to home health agency payments due to supposed case mix creep. In its PPS refinements final rule issued Aug. 22, CMS added a 2.71 cut in the fourth year to a total 10.96 percent cut (see Eli's HCW, Vol. XVI, No. 29).
But that may not be the last payment cut for case mix creep. CMS will continue to look for "growth of the nominal change in case-mix" in future years, it says in the final rule. If the agency finds it, "CMS may adjust the percentage reduction in the second and/or third year, elect to adjust the percentage reduction in only the fourth year, or adjust the percentage reduction in any combination of years."
The rule sounds like the case mix creep cuts could go on "in perpetuity," noted Bob Wardwell of the Visiting Nurse Associations of America in the Aug. 29 Open Door Forum for home care providers.
That regulatory language does indeed give CMS the "flexibility" to measure case mix increases and implement future cuts, said CMS' Randy Throndset in the forum. The provision will also help agencies avoid a whopping increased cut all in the last year if CMS finds more increases, Throndset said.
Implementation jitters: Forum listeners were eager to access the final billing logic, grouper and HAVEN software. HHAs' comment letters on the proposed rule frequently blasted the short time frame to ramp up on PPS refinement implementation, and the delay to those items is making it even shorter.
Throndset promised CMS is trying to get the software and billing information out as soon as possible. "Folks are working feverishly," he pledged.
Hit the books: HHAs that ran their patient mix through the proposed rule will have to start over to figure out how the final rule will affect them. That's because CMS changed many of the scoring rules and case mix weights in the final rule.
"There are hundreds of significant changes," said Wardwell, a former top CMS official who headed up PPS' original design. Agencies would like to know why the changes came about, Wardwell said. But Throndset declined to offer specifics in the forum that drew 430 listeners.
Watch for fixes: The final rule contained some wage index errors and an incorrect example of calculating an outlier adjustment, Throndset noted. CMS will issue corrections to those errors soon.
Other issues addressed in the forum include: • Fraud demonstration. Don't expect CMS to cut you any slack if you fall in [...]
