Contact Us
Subscribe to this blog via RSS
Join us on LinkedInCategories
- Data Privacy
- Kentucky Consumer Data Protection Act
- Department of Health and Human Services' Office of Civil Rights
- Medical Residents
- DEI
- Medical Cannabis
- SB 47
- Workplace Violence
- Assisted Living Facilities
- EMTALA
- FDA
- Reproductive Rights
- Roe v. Wade
- SCOTUS
- Medical Spas
- medical billing
- No Surprises Act
- Mandatory vaccination policies
- Workplace health
- Coronavirus Aid, Relief and Economic Security Act
- Code Enforcement
- Department of Labor ("DOL")
- Employment Law
- FFCRA
- CARES Act
- Nursing Home Reform Act
- Acute Care Beds
- Clinical Support
- Coronavirus
- COVID-19
- Emergency Medical Services
- Emergency Preparedness
- Families First Coronavirus Response Act
- Family and Medical Leave Act (“FMLA”)
- KBML
- medication assisted therapy
- SB 150
- Department of Health and Human Services
- Legislative Developments
- Corporate
- United States Department of Justice ("DOJ")
- Employee Contracts
- Non-Compete Agreement
- Opioid Epidemic
- Sexual Harassment
- Health Resource and Services Administration
- House Bill 333
- Litigation
- Medical Malpractice
- Senate Bill 79
- Locum Tenens
- Physician Prescribing Authority
- Senate Bill 4
- "Two Midnights Rule"
- 340B Program
- Chronic Pain Management
- HIPAA
- Hospice
- Kentucky minimum wage
- Minimum wage
- Prescription Drugs
- Skilled Nursing Facilities (“SNFs”)
- Uncategorized
- Affordable Insurance Exchanges
- Drug Screening
- EHR Systems
- Electronic Health Records (“EHR")
- Fraud
- Health Care Fraud
- HIPAA Risk Assessment
- ICD-10
- KASPER
- Mental Health Care
- Office for Civil Rights ("OCR")
- Primary Care Physicians ("PCPs")
- Stark Laws
- Urinalysis
- Accountable Care Organizations (“ACO”)
- Affordable Care Act
- Alternative Payment Models
- Anti-Kickback Statute
- Centers for Medicare & Medicaid Services (“CMS”)
- Certificate of Need ("CON")
- Charitable Hospitals
- Compliance
- Data Breach
- Department of Health and Human Services (HHS)
- Electronic Protected Health Information (ePHI)
- False Claims Act
- Federally Qualified Health Centers (“FQHCs”)
- Fee for Service
- Health Information Technology for Economic and Clinical Health Act (HITECH Act)
- Health Insurance Portability and Accountability Act of 1996 (HIPAA)
- Health Professional Shortage Area ("HPSA")
- Hospitals
- HPSA
- HRSA
- Kentucky Board of Medical Licensure
- Kentucky’s Department for Medicaid Services
- Limited Services Clinics
- Medicaid
- Medical Staff By-Laws
- Medically Underserved Area ("MUA")
- Medicare
- Mid-Level Practitioners
- Office of Inspector General of the United States Department of Health and Human Services (OIG)
- Part D
- Patient Protection and Affordable Care Act (“ACA”)
- Pharmacists
- Physician Assistants
- Qui Tam
- Rural Health Centers (“RHCs”)
- Rural Health Clinic
- Telehealth
- American Telemedicine Association (“ATA”)
- Criminal Division of the Department of Justice (“DOJ”)
- Health Care Fraud Prevention and Enforcement Action Team (“HEAT”)
- Hydrocodone
- Kentucky Board of Nursing
- Kentucky Pharmacists Association
- Qualified Health Care Centers (“FQHC”)
- Telemedicine
- United States ex. Rel. Kane v. Continuum Health Partners
- Webinar
- Agreed Order
- All-Payer Claims Database ("APCD")
- APRNs
- Chain and Organization System (“PECOS”)
- Chiropractic services
- Clinical Laboratory Improvement Amendments of 1988 (“CLIA”)
- Douglas v. Independent Living Center of Southern California
- Drug Enforcement Agency ("DEA")
- Emergency Rooms
- Enrollment
- Hinchy v. Walgreen Co.
- ICD-9
- Jimmo v. Sebelius
- Kentucky Senate Bill 7
- Maintenance Standard
- Medicare Part D
- Minors
- Ophthalmological services
- Overpayments
- Physician Compare website
- Re-validation
- Texting
- Vitas Innovative Hospice Care
- "Plan of Correction"
- 2014 Medicare Physician Fee Schedule (“PFS”)
- 501(c)(3)
- Affinity Health Plan
- Appeal
- Arbitration
- Cadillac tax
- Centers for Disease Control and Prevention
- Chronic Care Management
- Community health needs assessment (“CHNA”)
- Compliance Officer
- Compounding
- Condition of Participation ("CoP")
- CPR
- Daycare centers
- Denied Claims
- Department of Medicaid Services’ (“DMS”)
- Dispenser
- Division of Regulated Child Care
- Drug Quality and Security Act (“DQSA”)
- Employer Mandate
- Essential Health Benefits
- Federation of State Medical Boards (“FSMB”)
- Food and Drug Administratio
- Form 4720
- Grace Period
- Health Professional Shortage Areas (“HPSA”)
- HealthCare.gov
- Home Health Prospective Payment System
- Home Medical Equipment Providers
- Hospitalists
- House Bill 3204
- Individual mandate
- Inpatient Care
- Intermediate Sanctions Agreement
- Kentucky Health Benefit Exchange
- Kentucky Medical Practice Act
- Kindred v. Cherolis
- Kynect
- Licensure Requirements
- LLC v. Sutter
- Long-term care communities
- Long-Term Care Providers ("LTC")
- Low-utilization payment adjustment ("LUPA")
- Medicare Shared Saving Program (MSSP)
- Mobile medical applications ("apps")
- Model Policy for the Appropriate Use of Social Media and Social Networking in Medical Practice (“Model Policy”)
- National Drug Code ("NDC")
- National Institutes of Health
- Network provider agreement
- New England Compounding Center ("NECC")
- Nonprofit hospitals
- Nonroutine medical supplies conversion factor (“NRS”)
- Outsourcing facility
- Payors
- Personal Service Entities
- Physician Payments
- Physician shortages
- Ping v. Beverly Enterprises
- Power of Attorney ("POA")
- Prescriber
- Qualified Health Plan ("QHP")
- Quality reporting
- Social Media
- Spousal coverage
- State Health Plan
- Statement of Deficiency ("SOD")
- Sustainable Growth Rate (“SGR”)
- Upcoding
- UPS
- “Superuser”
- Advanced Practice Registered Nurses
- Audit
- Autism/ASD
- Business Associate Agreements
- Business Associates
- Call Coverage
- Compliance Programs
- Decertification
- Doe v. Guthrie Clinic
- EHR vendor
- Employer Group Health Plans
- ERISA
- Fair Labor Standards Act (FLSA)
- False Billings
- Genetic Information Nondiscrimination Act ("GINA")
- Group Purchasing Organizations ("GPO")
- Health Reform
- House Bill 104
- Kentucky House Bill 159
- Kentucky House Bill 217
- Kentucky Primary Care Centers (“PCCs”)
- Licensed practical nurses (LPN)
- List of Excluded Individuals and Entities
- Managed Care Organizations (“MCOs”)
- Meaningful use incentives
- Medicare Administrative Coordinators
- Medicare Audit Improvement Act of 2012
- Medicare Benefit Policy Manual
- Nurse practitioners (NP)
- Office of the National Coordinator for Health Information Technology (“ONC”)
- Part A
- Part B
- Patient Autonomy
- Patient Privacy
- Personal Health Information
- Provider Self Disclosure Protocol
- Recovery Audit Contractors (“RAC”)
- Registered nurses (RN)
- Self-Disclosure Protocol
- Senate Bill 39
- Senate Finance Committee Report
- State Medicaid Expansion
- Trade Association Group Coverage
- Abuse and Waste
- Center for Disease Control
- Consumer Operated and Oriented Plan programs (“CO-OPS”)
- Critical Access Hospitals (“CAHs”)
- Essential Health Benefits (“EHBs”)
- Free Conference Committee Report
- Health Care Fraud and Abuse Control Program
- Healthcare Information and Management Systems Society (HIMSS)
- House Bill 1
- House Bill 4
- Kentucky Cabinet for Health and Family Services
- Kentucky Health Care Co-Op
- Kentucky Health Cooperative (“KYHC”)
- Kentucky “Pill Mill Bill”
- Occupational Safety and Health Administration (“OSHA”)
- Pain Management Facilities
- Small Business Health Options Program (“SHOP”)
- Sunshine Act
- Employee Agreement
- Health Care Law
- Health Insurance
- Healthcare Regulation
McBrayer Blogs
Proposed Payment Changes for Medicare Home Health Agencies, cont.
Earlier this week, I discussed CMS’ proposal to rebase the payment rates for home health services. Here I will discuss CMS’ other proposed changes to home health payment.
Earlier this week, I discussed CMS’ proposal to rebase the payment rates for home health services. Here I will discuss CMS’ other proposed changes to home health payment.
Coding Changes
According to CMS, there are several ICD-9 codes that are resulting in “inaccurate overpayments” through their inclusion in the home health prospective payment system. CMS is suggesting removal of two specific ICD-9-CM codes:
(1) those that are too acute for the home health setting, and
(2) diagnosis codes for health conditions that do not require home health
intervention, do not impact home health plan of care, and/or would not result in the use of additional home health resources.
ICD-10-CM codes will be included in the payment system starting in October 2014.
Quality Reporting
CMS’ proposal seeks to add two claims-based quality measures:
(1) re-hospitalization during the first thirty (30) days of home health stay, and
(2) ER use without readmission during the first thirty (30) days of home health
stay.
These measures will allow home health agencies to make reduction of hospital readmissions a high priority.
Cost Allocations for Home Health Agency Surveys
Another proposed home health payment change is that Department of Medicaid Services’ (“DMS”) responsibilities for home health surveys would be explicitly recognized in the State Medicaid Plan. Additionally, CMS seeks to use the cost allocation methodology used for dually-certified nursing homes – assigning Medicare and Medicaid 50% of the actual costs.
Home health providers and stakeholders should review the proposed rule and its effects on home health services. Remember that comments are due by August 26, 2013. If you would like to know more or have questions about the proposal, contact the healthcare attorneys at McBrayer.
Services may be performed by others.
This article does not constitute legal advice.
