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Comment Period Closing for 2013 Home Health PPS Rule

The deadline is 5:00 pm eastern time on September 4, 2012 to comment on the proposed PPS rules for 2013.  The proposed PPS rule that was published in the July 13, 2012 Federal Register at www.gpo.gov/fdsys/pkg/FR-2012-07-13/pdf/2012-16836.pdf where you can find the process for submitting comments.
 
The National Association for Home Care & Hospice has identified four issues of concern, and is encouraging home health agency leaders to review these issues, and make comments.
1.  Acute Care Hospitalization Claims Based Measure.
CMS proposed to use claims-based Acute Care Hospitalization measure in place of the OASIS-based measure. This would provide a more accurate accounting of hospitalization rates, especially since home health agencies must now often rely on patient self-reporting of hospital stays for OASIS.
2.  Home Health Face To Face Encounter
NAHC will once again urge CMS to rescind the current F2F documentation requirements which have proven costly to home health agencies and burdensome to physicians and support personnel, including discharge planners. Despite continuous efforts by home health agencies to educate physicians in the intricacies of F2F documentation requirements since 2010, doctors remain confused, and often uncooperative. Further, NAHC believes that agencies have incurred increased administrative costs associated with education, tracking and resending of documentation, as well as the inability to submit claims for countless episodes of care when physicians failed to document F2F encounters, or document correctly.
3.  Therapy Reassessments
The new rules regarding therapy assessments have added new burden including scheduling problems and increased costs to home health agencies. 
4.  HHRG Grouper Diagnosis changes
CMS’ proposal to ‘enhance’ the HH PPS Grouper will eliminate assignment of case-mix points to the majority of diagnosis codes that are replaced by V codes, and limit the ability to report all Diabetes, Neuro1 and Skin1 codes in the limited spaces at M1020 and 1022. In addition, CMS’ proposal could limit case mix points for fractures when coding rules require that they be reported as secondary diagnoses.
NAHC received information from over 300 home health agencies about the effect of the proposed change to Grouper logic on clinical scores. This change will reduce payment of affected episodes by an average of $200 per episode.
As we have said over and over again, your state and national associations are the grass roots of home care in America.  We encourage you to be involved in your association, and to actively participate in the legislative and regulatory process.  Take a few minutes to review these changes to the HH PPS Rule, and submit your comments.
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