News From Home Care
GAO still has reservations despite PPS research
The General Accounting Office concluded in April that while the Health Care Financing Administration’s (HCFA) research and demonstration projects for the home health prospective payment system (PPS) have been useful in helping to design a new system, significant gaps remain.
"Those gaps, coupled with the variation in the way home health services are delivered and the lack of what constitutes appropriate care, mean that PPS could cause unintended consequences for some beneficiaries, some home health agencies, or the level of Medicare spending," the GAO concluded in its report released to Congress.
The proposed 60-day episode is likely to be too long for many beneficiaries and could result in unnecessary expenditures if payments are not adequately adjusted for patient needs, the GAO added.
The GAO also took issue with the basing level of per-episode payment on national averages. It could result in sharp increases in revenue for some agencies and a steep decline for others.
"Concerns remain about whether the case-mix adjustment method will adequately group patients with like resource needs and then appropriately adjust payments for beneficiaries in each group," the report said.
Despite having spent $27 million since 1987 on PPS demonstrations, the GAO says it cannot adequately gauge the effects certain payment policies will have on home health delivery and spending.
For example, the GAO noted that while demonstrations offered evidence that home health visits under PPS would reduce costs, it did not examine alternative levels of payment. In addition, HCFA failed to develop a case-mix adjustment method to alter payments for differences in resource use across groups of patients, according to the GAO.
The GAO recommended that HCFA closely monitor service delivery for various types of beneficiaries and home health agencies so that inadequate or medically inappropriate care can be identified.
Olmstead is key to home health Medicaid coverage
A recent U.S. Supreme Court case against the Georgia Medicaid program represents the otential for the home health industry to transform Medicaid into a home care program rather than a nursing home program.
The Olmstead case, which requires state Medicaid programs to take reasonable efforts to deinstitutionalize the disabled, prompted the National Association of Home Care (NAHC) to rally its members and urge other providers to come up with creative ways to move patients into the home care setting.
"It does not mean that they eliminate nursing homes, but many of these patients can be cared for in the home setting." says Bill Dombi, director of the Center for Health Care Law with the NAHC. He says providers should take a lesson from states that use home care options under Medicaid. New York, he points out, spends roughly 60% of all Medicaid home health dollars in the United States. In contrast, Oklahoma spends "almost nothing."
The Olmstead case has now put the Health Care Financing Administration on the side of home care to enforce the Americans with Disabilities Act. In addition, The Department of Health and Human Services’ Office of Civil Rights has stepped up its effort by requiring each state to develop a plan to comply with the ADA.
Changes in state systems may cause OASIS glitches
Home health agencies using vendor software could face difficulty in entering Outcome and Assessment Information Set (OASIS) data into their systems, thanks to changes made by the Health Care Financing Administration (HCFA).
In addition, home health providers will soon be required to report data from non-Medicare and non-Medicaid patients.
HCFA announced the changes in April that call for slight changes in state agency systems. According to officials, providers using HCFA's own HAVEN (Home Assessment Validation ENtry) data collection software should not notice the change, but those whose software does not meet HAVEN data specifications may experience problems meeting requirements.
Some software allows agencies not to answer certain data items, and HCFA has allowed that "empty" data to be submitted to prevent frustration early in OASIS implementation. "That will stop because [it] does not meet the data specifications, which say every data item must be answered," a HCFA official said.
Reporting of non-Medicare and non-Medicaid patients was previously delayed because of privacy issues. HCFA has since developed a system that allows the reporting of data while protecting patient privacy. HCFA will implement the new system for non-Medicare and non-Medicaid patients through the Federal Register in a notice that will contain details on when it will become effective and how it will operate.
According to HCFA, more than 4 million OASIS records have been collected, which amounts to about 1.8 million Medicare and Medicaid home health patients. At this time, about 95% of agencies required to report OASIS data are doing so.
HCFA’s beneficiary upgrade proposal gets mixed reviews
The Health Care Financing Administration (HCFA) released its long-awaited proposed rule for upgrading durable medical equipment (DME) purchased by Medicare beneficiaries, but suppliers of DME still have some concerns.
The proposed rule was published in the April 27 Federal Register. It permits Medicare beneficiaries to upgrade DME items that fall beyond HCFA’s criteria for medical necessity as long as the beneficiary pays the price difference.
"I think it is a good first step," says Dave Williams, director for government affairs at Invacare in Elyria, OH. "It is extremely workable on most fronts." Williams, who was instrumental in prompting HCFA to publish the proposed rule, said he will go through a more thorough evaluation over the next few weeks with national trade groups and providers.
Williams said his major concern has to do with cases where the product transcends payment category, specifically capped rental to frequently purchased. "But our research and discussion with the carriers indicates that we can probably work through that," he said. The other limitation, he said, is imposed by the inadequacy of the HCPCS coding system.
The DME upgrade provision was mandated by the Balanced Budget Act of 1997, but is among the dozens of provisions for which HCFA has yet to promulgate regulations.
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