{"id":8357,"date":"2023-11-06T14:55:09","date_gmt":"2023-11-06T20:55:09","guid":{"rendered":"https:\/\/staging.amityhealthcaregroup.com\/?p=8357"},"modified":"2025-07-05T05:59:59","modified_gmt":"2025-07-05T11:59:59","slug":"issue-date-november-6th-2023","status":"publish","type":"post","link":"https:\/\/staging.amityhealthcaregroup.com\/?p=8357","title":{"rendered":"Issue date: November 6th 2023"},"content":{"rendered":"


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November is a National Home Care<\/strong> and Hospice<\/strong> month! Amity Healthcare Group would like to thank all home care and hospice professionals- caring and dedicated nurses, home care aides, therapists, and social workers- who make a difference in the lives of the patients and families every day.<\/span><\/span><\/div>\n

Amity\u2019s News!<\/strong><\/p>\n

The annual 2023 NAHC conference was a success! Three days filled with meeting industry leaders and providers, education, and meaningful conversations.<\/p>\n

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\nOASIS -E Corner<\/strong><\/span><\/span><\/p>\n

There are several questions that were brought up by our clients this week that we wanted to share \u00a0with you. The responses to the questions are from the OASIS Q&A below.
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\nQ10. What if the patient refuses a visit during the 5-day recert window? [Q&A EDITED 09\/09]<\/strong>
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\nA10.<\/strong> Most patients are willing to receive a visit if the visit schedule and required time points have been explained to them during the episode.\u00a0In addition, PPS requires a visit during the same ‘window’ for the agency to receive continued reimbursement for a specific Medicare patient. If the HHA is completely unable to schedule a visit during this period, the follow-up assessment should be completed as soon after this period as possible.<\/span>
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\nAlthough it is not explicitly spelled out in the CoP, the expectation that accompanies the requirement to update the comprehensive assessment between days 56 & 60 is that the orders for the ensuing 60 days will be based on the results of that assessment. The patient’s care orders essentially expire at the end of day 60, so day 61 begins a new<\/span><\/span><\/p>\n

payment episode. The agency should be aware of potential legal issues associated with completing the assessment late, considering that the agency may not have orders for visits after the end of the 60-day period. If the patient is a Medicare patient, you should discuss any payment-related issues with Medicare Administrative Coordinator (MAC).<\/p>\n

Q11. If an agency misses the recertification assessment window of day 56-60, yet continues to provide skilled services to the Medicare patient, is the agency required to discharge and readmit the patient? Or could the agency conduct the RFA 4 assessment late? Will any data transmission problems be encountered?<\/strong><\/p>\n

A11. When an agency does not complete a recertification assessment within the required 5 day window at the end of the certification period, the agency should not discharge and readmit the patient. Rather, the agency should send a clinician to perform the recertification assessment as soon as the oversight is identified. The date assessment completed (M0090) should be reported as the actual date the assessment is completed, with documentation in the clinical record of the circumstances surrounding the late completion. A warning message will result from the non-compliant assessment date, but this will not prevent assessment transmission. No time frame has been set after which it would be too late to complete this late assessment, but the agency is encouraged to make a correction or complete a missed assessment as soon as possible after the oversight is identified. Obviously, this situation should be avoided, as it does<\/p>\n

demonstrate non-compliance with the comprehensive assessment update standard (of the Conditions of Participation). For the Medicare PPS patient, payment implications may arise from this missed assessment. Any payment implications must be discussed with the agency’s Medicare Administrative Coordinator (MAC).<\/p>\n

If you have not had a chance to do so yet please review October 2023 OASIS Q&A HERE<\/a><\/em>
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\nNATIONAL NEWS<\/u><\/strong><\/span><\/span><\/p>\n

CMS \u00a0CY 2024 Home Health Final Rule
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\nThe Centers for Medicare and Medicaid Services (CMS) released the CY 2024 Home Health Final Rule<\/a> on November 1, 2023. The rule includes decisions regarding Medicare home health services payment rates for CY 2024 as well as a number of other proposals
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\nBelow, you will find a summary of primary areas of the CY 2024 Home Health Final Rule:<\/span><\/span><\/p>\n

Medicare Payments<\/strong><\/p>\n

CMS finalized a permanent prospective payment adjustment to the CY 2024 home health 30-day period payment rate. The finalized -2.890 percent permanent adjustment is half the full permanent adjustment of -5.779 percent (-5.653 percent in the proposed rule). As a result of CMS finalizing roughly half of the full permanent adjustment projected, Medicare payments to HHAs in CY 2024 will increase in the aggregate by 0.8 percent, rather than a 2.2 percent decrease as initially proposed. The Final Rule, the net inflation update is set at 3.0% (3.3% Market Basket Index \u2013 0.3% Productivity Adjustment).<\/p>\n

The outcome of these payment rate changes on 30-day period base rates and per-visit LUPA rates is as follows.<\/p>\n

(HHAs that failed to provide required quality data have these rates reduced by two percent)<\/em><\/p>\n

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In response to rate changes, NAHC President William A. Dombi stated, \u201cWe continue to strenuously disagree with CMS\u2019s rate setting actions, including the budget neutrality methodology that CMS employed to arrive at the rate adjustments. We recognize that CMS has reduced the proposed 2024 rate cut. However, overall spending on Medicare home health is down, 500,000 fewer patients are receiving care annually since 2018, patient referrals are being rejected more than 50% of the time because providers cannot afford to provide the care needed within the payment rates, and providers have closed their doors or restricted service territory to reduce care costs. If the payment rate was truly excessive, we would not see these actions occurring. The fatally flawed payment methodology that CMS continues to insist on applying is having a direct and permanent effect on access to care. When you add in the impact of shortchanging home health agencies on an accurate cost inflation update of 5.2% over the last two years, the loss of care access is natural and foreseeable.\u201d<\/em><\/p>\n

Disposable Negative Pressure Wound Therapy (dNPWT)<\/strong><\/p>\n

The Consolidated Appropriations Act, (CAA) 2023 included technical amendments for the payment of dNPWT. \u00a0The Act modifies the methods for calculating separate payments for dNPWT devices for each of the next three years. Additionally, beginning January 1, 2024, nursing and therapy visits provided for dNPWT will be billed separately on the home health claim type of bill (TOB) 32x. \u00a0 Beginning in calendar year (CY) 2024 and each subsequent year, claims for the separate payment amount of an applicable dNPWT device using Healthcare Common Procedure Coding System (HCPCS) code A9272 would be reported on claims submitted using the TOB 32x. That is, claims with a date of service on or after January 1, 2024 for an applicable dNPWT device will no longer be submitted on TOB 34X. CMS will be issuing billing instructions…<\/p>\n

Home Health Value-Based Purchasing Program (HHVBP)<\/strong><\/p>\n

For the expanded HHVBP Model, CMS is finalizing its proposals to:<\/p>\n