Monday, March 31, 2014

SENATE PASSES ICD-10 DELAY BILL: AHIMA Alert

Today, the US Senate voted to approve H.R. 4302, Protecting Access to Medicare Act of 2014, which included language delaying the implementation of ICD-10-CM/PCS by at least one year. The vote was 64 to 35 at 6:59 p.m. ET. The bill now moves to President Obama, who is expected to sign it into law.

The H.R. 4302 bill mainly creates a temporary "fix" to the Medicare sustainable growth rate (SGR). But a seven-line section of the bill states that the Department of Health and Human Services (HHS) cannot adopt the ICD–10 code set as the mandatory standard until at least October 1, 2015—a year after the October 1, 2014 implementation date for which the industry has been preparing.
AHIMA to Seek Immediate Clarification on Technical Issues
Effects of a one year delay include an estimated likely cost of $1 billion to $6.6 billion to the healthcare industry and lost opportunity costs for failing to move to a more effective code set. A cloud will also be cast over the employment prospects of more than 25,000 students who have learned to code exclusively in ICD-10 in HIM associate and baccalaureate educational programs. In a statement on the Senate vote, AHIMA officials said they will work to clarify outstanding questions raised by the delay and continue to work with government officials to implement ICD-10.
"On behalf of our more than 72,000 members who have prepared for ICD-10 in good faith, AHIMA will seek immediate clarification on a number of technical issues such as the exact length of the delay," said AHIMA CEO Lynne Thomas Gordon, MBA, RHIA, CAE, FACHE, FAHIMA. "AHIMA will continue our work with various public sector organizations and agencies such as the Centers for Medicare and Medicaid Services, the Office of the National Coordinator for Health IT, and the National Center for Health Statistics, along with our industry partners such as the ICD-10 Coalition so that ICD-10 will realize its full potential to improve patient care and reduce costs. These are goals that AHIMA and other healthcare stakeholders and our government leaders all share."
AHIMA Thanks Members and ICD-10 Proponents for Remarkable Grassroots Fight
AHIMA thanks its members and other stakeholders for their efforts over the last six days to stop an ICD-10 implementation delay. Proponents of ICD-10 responded to AHIMA's call for a grassroots campaign by making nearly 10,000 phone calls and sending over 1,000 letters to their elected representatives, urging them to vote against an ICD-10 delay and to pass a clean SGR bill. ICD-10 supporters also took to social media, with messages on Twitter containing the hashtag #NoDelay numbering more than 5,000, including several thousand during this morning's hour-long virtual rally. During that hour, a flood of tweets on the topic of ICD-10 catapulted hashtag #ICD10 onto Twitter's "trending topics" list.
While today's vote has delayed ICD-10 implementation, AHIMA will be working to ensure that another delay does not occur legislatively. In the coming weeks, updates will be added to AHIMA's Advocacy Assistant with instructions on how members can continue to advocate for ICD-10.

For more on today's vote and what happens next, visit the Journal of AHIMA website.

Friday, February 28, 2014

From Provider Magazine: CMS extends audit moratorium to MMRs

CMS Extends Audit Moratorium to MMRs

The Obama administration has extended its moratorium on health care audits to include the controversial manual audits, offering another olive branch to long term and post-acute care advocates.

Last week, providers breathed a sigh of relief when the Centers for Medicare & Medicaid Services (CMS) announced that it would “pause” reviews under its Recovery Auditor Contractor program. The reviews were principal culprits behind a monstrous backlog of audit appeals that has swamped the agency.

The CMS pause announcement left open questions about whether the so-called Manual Medical Reviews (MMRs) would continue.

In a clarifying letter to advocates, CMS says that the manual reviews are on hold as well. The suspension is applied retroactively to last week’s recovery audit announcement, CMS says.

Additionally, CMS says that it’s tweaking its audits to address many provider concerns.  Under just-announced or pending rules, auditors now must:
  • Wait at least 30 days “to allow for a discussion” if a provider says that he or she will appeal an audit decision.  Previously, auditors had to end talks when notified of an appeal. 
  • Wait to be paid any contingency fees until after the second level of administrative appeals has concluded. Previously, auditors were allowed to take the cash even if a case was on appeal; and
  • Adjust their document requests to a provider’s denial rates.
Overall, advocates say they’re pleased with CMS’ new posture but still say the central problem isn’t so much the audit process as the audit policy itself. Providers say they have no objection to catching crooks, but the current policy treats everyone as if they were already guilty and ties innocent providers up for weeks, and even months, on endless reviews and paperwork requests—only to be followed by months of appeals.

Bill Myers is Provider’s senior editor. He can be reached at wmyers@providermagazine.com.  Follow him on Twitter, @ProviderMyers.

Thursday, February 20, 2014

CMS SUSPENDS RAC OPERATIONS

February 18, 2014 – CMS is in the procurement process for the next round of Recovery Audit Program contracts.  It is important that CMS transition down the current contracts so that the Recovery Auditors can complete all outstanding claim reviews and other processes by the end date of the current contracts.  In addition, a pause in operations will allow CMS to continue to refine and improve the Medicare Recovery Audit Program.   Several years ago, CMS made substantial changes to improve the Medicare Recovery Audit program.  CMS will continue to review and refine the process as necessary. For example, CMS is reviewing the Additional Documentation Request (ADR) limits, timeframes for review and communications between Recovery Auditors and providers.  CMS has proven it is committed to constantly improving the program and listening to feedback from providers and other stakeholders.  Providers should note the important dates below:
• February 21 is the last day a Recovery Auditor may send a postpayment Additional Documentation Request (ADR)
• February 28 is the last day a MAC may send prepayment ADRs for the Recovery Auditor Prepayment Review Demonstration
• June 1 is the last day a Recovery Auditor may send improper payment files to the MACs for adjustment
CMS will continue to update this Website with more information on the procurement and awards as information is available. Providers should contact RAC@cms.hhs.gov for additional questions.

Wednesday, February 19, 2014

Virginia Providers: 4th Quarter Preliminary CMI reports from DMAS are incorrect. You do not have to do the research requests.


From: "Andrea Crump" <ACrump@MSLC.COM>
Date: February 19, 2014 at 5:15:16 PM EST
To: "Andrea Crump" <ACrump@MSLC.COM>
Cc: "Mary Hairston" <mary.hairston@dmas.virginia.gov>, William.Lessard@dmas.virginia.gov, "Les Wingfield" <LWingfield@MSLC.COM>, "Richard Weinstein" <RWeinstein@MSLC.COM>, "Wendy malone" <wmalone@MSLC.COM>
Subject: Update on 4th Quarter CMI Reports
Please forward this message to the MDS Coordinators in your organization:
4th Quarter Preliminary CMI Reports were sent to nursing facility providers on February 17.  Many providers have contacted Myers and Stauffer or DMAS about discrepancies in these reports.  DMAS is investigating and will communicate the results to providers.  Please do not utilize these reports or submit research requests until further communication from DMAS.

Andrea N. Crump
Manager
 
MYERS AND STAUFFER LC
 
4400 Cox Road, Suite 110
Glen Allen, VA 23060
PH 804.270.2200
FX 804.270.2311

Friday, February 7, 2014

MAC/ZPIC Contractor Directory: Interactive by state

I just came across this on the CMS website.  Don't know how long it's been up, but it's a 'one stop shopping center' for finding the name and POC information for finding your MAC, ZPIC, & RAC.  Link is below, you may have to cut and paste.

Review Contractor Directory - Interactive Map

The Review Contractor Directory - Interactive Map allows you to access state-specific CMS contractor contact information. You may receive correspondence from one or several of these contractors in your state. They may request medical records from you, as they perform business on behalf of CMS. You can use this website to access their contact information including emails, phone numbers and websites.


http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Review-Contractor-Directory-Interactive-Map/index.html

Saturday, February 1, 2014

OIG Work Plan for SNFs 2014

Medicare Part A billing by skilled nursing facilities (new) 
Policies and Practices. We will describe SNF billing practices in selected years and will describe variation in billing among SNFs in those years. Context—Prior OIG work found that SNFs increasingly billed for the highest level of therapy even though beneficiary characteristics remained largely unchanged. OIG also found that SNFs billed one-quarter of all 2009 claims in error, resulting in $1.5 billion in inappropriate Medicare payments. CMS has made substantial changes to how SNFs bill for services for Medicare Part A stays. (OEI; 02-13-00610; 00-00-0000; various reviews; expected issue date: FY 2014; work in progress) 
 Questionable billing patterns for Part B services during nursing home stays 
Billing and Payments. We will identify questionable billing patterns associated with nursing homes and Medicare providers for Part B services provided to nursing home residents during stays not paid under Part A (for example, stays during which benefits are exhausted or the 3-day prior-inpatient-stay requirement is not met). A series of studies will examine several broad categories of services, such as foot care. Context—Congress explicitly directed OIG to monitor Part B billing for abuse during non-Part A stays. (Medicare, Medicaid, and SCHIP Benefits Improvement and Protection Act of 2000 (BIPA), § 313.) (OEI; 06-14-00160; various reviews; expected issue date: FY 2014; work in progress) 
 State agency verification of deficiency corrections 
Quality of Care and Safety—We will determine whether State survey agencies verified correction plans for deficiencies identified during nursing home recertification surveys. Context—A prior OIG review found that one State survey agency did not always verify that nursing homes corrected deficiencies identified during surveys in accordance with Federal requirements. Federal regulations require nursing homes to submit correction plans to the State survey agency or CMS for deficiencies identified during surveys. (42 CFR § 488.402(d).) CMS requires State survey agencies to verify the correction of identified deficiencies through onsite reviews or by obtaining other evidence of correction. (State Operations Manual, Pub. No. 100-07, § 7300.3.) (OAS; W-00-13-35701; W-00-14-35101; various reviews; expected issue date: FY 2014; work in progress) 
 Program for national background checks for long-term-care employees 
Quality of Care and Safety. We will review the procedures implemented by participating States for long-term-care facilities or providers to conduct background checks on prospective employees and providers who would have direct access to patients and determine the costs of conducting background checks. We will determine the outcomes of the States' programs and determine whether the programs led to any unintended consequences. Contex—This mandated work is ongoing and will be issued at the program's conclusion as required. (Affordable Care Act, § 6401.) (OEI; 07-10-00420; expected issue date: FY 2017; work in progress; Affordable Care Act) HHS OIG Work Plan | FY 2014 Medicare Part A and Part B Page 9 
 Hospitalizations of nursing home residents for manageable and preventable conditions 

Quality of Care and Safety—We will determine the extent to which Medicare beneficiaries residing in nursing homes are hospitalized as a result of conditions thought to be manageable or preventable in the nursing home setting. Context—A 2013 OIG review found that 25 percent of Medicare beneficiaries were hospitalized for any reason in FY 2011. Hospitalizations of nursing home residents are costly to Medicare and may indicate quality-of-care problems in the nursing homes. (OEI; 06-11-00041; expected issue date: FY 2014; work in progress) 

Friday, January 24, 2014

Verbal guidance from CMS on coding Section K that is beyond what is published in the current RAI Manual

From the AANAC LTC Leader dated 1/23/14  (NOTE FROM JUDY:  THIS IS NOT IN THE CURRENT RAI MANUAL)

Officials with the Centers for Medicare and Medicaid Services (CMS) discussed several issues at the Jan. 16 Skilled Nursing Facility/Long-term Care Open Door  Forum (SNF/LTC ODF).


K07010 coding example

CMS officials provided an example to illustrate the proper coding of MDS 3.0 item K0710 (percent intake by artificial route) when the look-back period includes time prior to and after admission or reentry:
Mr. K has been able to take some fluids orally. However, due to his progressing multiple sclerosis, his dysphaghia is not allowing him to remain hydrated. Therefore, he received the following fluid amounts over the last seven days via supplemental tube feedings while in the hospital and after he was admitted to the nursing home.

Over four days in the hospital, Mr. K received the following:
• Monday, 400 cc;
• Tuesday, 520 cc;
• Wednesday, 500 cc; and
• Thursday, 480 cc.

Over three days in the nursing home, Mr. K received the following:
• Friday, 510 cc;
• Saturday, 520 cc; and
• Sunday, 490 cc.

In this scenario, K0710B (average fluid intake per day by IV or tube feeding) would be coded as follows:
• K0710B1 (while NOT a resident) would be coded 1, indicating 500 cc per day or less.
• K0710B2 (while a resident) would be coded 2, indicating 501 cc per day or more.
• K0710B3 (during entire seven days) would be coded 1, also indicating 500 cc per day or less.

“The rationale for this is that the total fluid intake in the last seven days while Mr. K was not a resident was 1,900,” said officials. “That is the sum of 400 on Monday, 520 on Tuesday, 500 on Wednesday, and 480 on Thursday. The average fluid intake while not a resident totaled 475 cc. Because that is less than
500, the correct coding is 1 for K0710B1 (while NOT a resident).” The total fluid intake within the last seven days while Mr. K was a resident of the nursing home was 1,520 cc, said officials. “That is the sum of 510 on Friday, 520 on Saturday, and 490 on Sunday. The average fluid intake was 507 cc for those three days. Since it is greater than 500, the correct coding for K0710B2 (while a resident) would be 2.”
Finally, “the total fluid intake during the entire seven days, and that includes while he was in the nursing home and prior to being in the nursing home while he was in the hospital, was 3,420 cc,” said officials. “The average for that entire seven-day period was 489 cc (dividing the total of 3,420 cc by those 7 days).

Because that 489 is less than 500, the correct code for K0710B3 (during entire seven days) would be 1.”