Post-Acute Care

Overview

Home Health

Home health care is a formal, regulated program of care delivered by a variety of health care professionals in the patient’s home for the treatment of a medical condition, illness or disability. Home health is provided through certified home health agencies (HHAs).

As components of the post-acute continuum of care, HHAs provide essential health care services. This specialized support allows patients to remain at home when they would otherwise have to be admitted to a costly institutional setting, such as a skilled-nursing facility or hospital.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective home health care services.

CHA News Article

CMS Clarifies Home Health ‘Face-to-Face’ Documentation

The Centers for Medicare & Medicaid Services (CMS) Medicare Learning Network has issued an article titled “Documentation Requirements for Home Health Prospective Payment System (HH PPS) Face-to-Face Encounter.” The article is designed to provide education on the required narrative for documenting the home health face-to-face encounter, and includes information and examples to help health care professionals avoid insufficient documentation errors and HH PPS improper payments. A copy of the article is attached.

CHA News Article

CMS Revises Sections of Medicare Benefit Manual Due to Settlement Agreement

To clarify coverage policies following a recent settlement agreement, the Centers for Medicare & Medicaid Services (CMS) has revised portions of its Medicare Benefit Policy Manual on services provided by skilled-nursing facilities, inpatient rehabilitation facilities, home health agencies and outpatient therapy. Based on the settlement agreement, Jimmo v. Sebelius, CMS Transmittal 176 specifies that standards requiring potential for improvement may not be applied as a rule of thumb to determine Medicare coverage for services that require skilled-nursing care or skilled therapy services.  It also provides guidance on appropriate documentation. CMS notes that the transmittal, attached, does not represent an expansion of benefits or a change in Medicare’s longstanding policy on the need for skilled-nursing care and skilled-therapy services.

CHA News Article

CMS Updates Home Health PPS Payments
Reimbursement cut by 1.05 percent from CY 2013

Home health (HH) agencies paid under Medicare’s prospective payment system (PPS) will see a 1.05 percent decrease in payments in calendar year (CY) 2014 as compared to CY 2013 under a final rule released by the Centers for Medicare & Medicaid Service (CMS). The decrease reflects the combined effects of an increase in the home health market basket update percentage of 2.3 percent, offset by a rebasing adjustment of negative 2.7 percent as required by the Affordable Care Act (ACA), and a .62 percent decrease due to a refinement of the HH PPS Grouper. The ACA requires CMS to begin phasing in rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates and the non-routine supply conversion factor to reflect changes since the inception of the HH PPS. For hospital-based facilities, CMS estimates the reduction will be smaller, negative .58 percent, for CY 2014.

Overview

Hospice

Hospice provides comprehensive and interdisciplinary health care to terminally ill patients, as well as bereavement and support services to the patients’ loved ones. Patients receiving hospice care forgo curative treatments. Hospice care is provided through certified hospice programs, and may be delivered in any patient care setting, but is most often provided in the patient’s home.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective hospice health care services.
 

CHA News Article

CMS Invites Applications for Hospice Care Choices Model

The Centers for Medicare & Medicaid Services (CMS) is requesting applications from hospices for participation in the Medicare Care Choices Model. The primary goal of the Care Choices Model is to test whether beneficiaries who meet Medicare hospice eligibility requirements would elect hospice if they could continue to seek curative services. Applications are due June 19. Additional information about the Medicare Care Choices Model is available at http://innovation.cms.gov/initiatives/Medicare-Care-Choices. A copy of the CMS announcement is attached. 

Overview

Inpatient Rehabilitation & Therapy Services

Medical rehabilitation focuses on improving or restoring functional independence for individuals with disabilities resulting from injury, illness or a medical condition.

Medical rehabilitation is provided at all levels of the health care continuum, including general acute-care hospitals, inpatient rehabilitation facilities (IRFs), skilled-nursing facilities, long-term-care hospitals, outpatient programs and home health agencies.

CHA News Article

Senate Passes House SGR Patch
Legislation includes post-acute care provisions, California GPCI fix

Yesterday, the U.S. Senate passed H.R. 4302, the Protecting Access to Medicare Act of 2014, averting for one year cuts to physicians required by the sustainable growth rate (SGR). The bill, which passed the House last week, also contains a California-specific provision to make adjustments to the Geographic Practice Cost Index (GPCI), which sets locality for payments to physicians. For many years physicians in 14 California counties have experienced reduced payments because of the GPCI, and the legislation will allow for a more accurate locality adjustment in those counties beginning in January of 2017. In addition to the California GPCI fix, the legislation also includes several provisions of interest to providers of post-acute care services (select “Read more” below). President Obama has indicated he will sign the bill. A summary of the bill’s hospital-related provisions is available here.

CHA News Article

Final Regulations for Physician Fee Schedule Published

The Division of Workers’ Compensation (DWC) has published the final regulations pertaining to the revised physician fee schedule (PFS), which became effective Jan. 1. The PFS also covers services of non-physician practitioners, such as physical therapists, occupational therapists, nurse practitioners, physician assistants, clinical social workers, clinical nurse specialists, nurse anesthetists and anesthesiologist assistants. The new PFS is based on the resource-based relative value scale system used by Medicare.

The new system implements the Medicare Multiple Procedure Payment Reduction (MPPR) on physical, occupational and speech therapy services. In addition, it applies various caps on the number of procedures that are reimbursable during a single therapy visit, requiring a written, pre-negotiated fee arrangement if the caps are exceeded. The final regulations are attached, as well as a list of procedures subject to the MPPR. For additional information, visit www.dir.ca.gov/dwc/OMFS9904.htm#6.

CHA News Article

CMS Revises Sections of Medicare Benefit Manual Due to Settlement Agreement

To clarify coverage policies following a recent settlement agreement, the Centers for Medicare & Medicaid Services (CMS) has revised portions of its Medicare Benefit Policy Manual on services provided by skilled-nursing facilities, inpatient rehabilitation facilities, home health agencies and outpatient therapy. Based on the settlement agreement, Jimmo v. Sebelius, CMS Transmittal 176 specifies that standards requiring potential for improvement may not be applied as a rule of thumb to determine Medicare coverage for services that require skilled-nursing care or skilled therapy services.  It also provides guidance on appropriate documentation. CMS notes that the transmittal, attached, does not represent an expansion of benefits or a change in Medicare’s longstanding policy on the need for skilled-nursing care and skilled-therapy services.

Overview

Long-Term-Care Hospitals

Long-term-care hospitals (LTCHs) provide hospital-level care for medically complex, long-stay patients. LTCHs meet the same requirements as general acute-care hospitals, but have significantly longer average lengths of stay of 25 days or greater. LTCHs may be freestanding facilities or be co-located within hospitals, and treat a wide variety of conditions, including respiratory failure with ventilator dependency, infections, complex wounds and trauma.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective long-term health care services.

CHA News Article

Senate Passes House SGR Patch
Legislation includes post-acute care provisions, California GPCI fix

Yesterday, the U.S. Senate passed H.R. 4302, the Protecting Access to Medicare Act of 2014, averting for one year cuts to physicians required by the sustainable growth rate (SGR). The bill, which passed the House last week, also contains a California-specific provision to make adjustments to the Geographic Practice Cost Index (GPCI), which sets locality for payments to physicians. For many years physicians in 14 California counties have experienced reduced payments because of the GPCI, and the legislation will allow for a more accurate locality adjustment in those counties beginning in January of 2017. In addition to the California GPCI fix, the legislation also includes several provisions of interest to providers of post-acute care services (select “Read more” below). President Obama has indicated he will sign the bill. A summary of the bill’s hospital-related provisions is available here.

CHA News Article

CDPH Revises LTC Facility Requirements for Posting Citations

The California Department of Public Health has issued a revision notice to long-term health care facilities, clarifying the posting requirements for citations. The new All Facilities Letter (AFL) 14-04 supersedes AFL 09-45. Certain subdivisions of Title 22 of the California Code of Regulations have been superseded by Health and Safety Code Section 1429 pertaining to placement and removal of citations. For more information, see the attached AFL 14-04.

CHA News Article

CMS Releases List of Measures Under Consideration for Future Rulemaking
CHA will work with the MAP to comment on measures

The Centers for Medicare & Medicaid Services (CMS) has released the attached list of measures under consideration for adoption in future Medicare rulemaking, as required by the Affordable Care Act (ACA). The Measures Application Partnership (MAP), convened by the National Quality Forum (NQF), will review the list and provide recommendations to CMS through a process that allows multiple stakeholders the opportunity to weigh in on measure selection before rules are finalized. For the first time in three years, the MAP will allow the public to comment prior to the beginning of its workgroups and coordinating committee meetings. The early public comment period ends on Dec. 9. In addition, as in previous years the public will have an opportunity to comment on the MAP’s recommendations to CMS, to be issued in January.

Overview

Skilled Nursing Facilities / Distinct-Part Nursing Facilities

Skilled-nursing facilities (SNFs) have the staff and equipment to provide skilled nursing, medical management and therapy services to individuals, on a 24-hour basis, who do not require high-intensity services provided in the hospital setting.

CHA News Article

Senate Passes House SGR Patch
Legislation includes post-acute care provisions, California GPCI fix

Yesterday, the U.S. Senate passed H.R. 4302, the Protecting Access to Medicare Act of 2014, averting for one year cuts to physicians required by the sustainable growth rate (SGR). The bill, which passed the House last week, also contains a California-specific provision to make adjustments to the Geographic Practice Cost Index (GPCI), which sets locality for payments to physicians. For many years physicians in 14 California counties have experienced reduced payments because of the GPCI, and the legislation will allow for a more accurate locality adjustment in those counties beginning in January of 2017. In addition to the California GPCI fix, the legislation also includes several provisions of interest to providers of post-acute care services (select “Read more” below). President Obama has indicated he will sign the bill. A summary of the bill’s hospital-related provisions is available here.

CHA News Article

OIG Issues Report on Adverse Events in Skilled-Nursing Facilities

The Office of Inspector General (OIG) has issued a report that examines potentially avoidable adverse events at skilled-nursing facilities (SNFs). The report concludes that one-third of Medicare beneficiaries in SNFs experienced adverse events or temporary harm during their stays, and that 59 percent of the events were preventable. As a result of the report, the OIG recommended that the Agency for Healthcare Research Quality and the Centers for Medicare & Medicaid Services (CMS) work together to increase education and patient safety awareness at SNFs, and that CMS instruct surveyors to review facility practices regarding adverse events. A copy of the report is attached. 

CHA News Article

MDS Newsletter Includes Major Changes to RAI Manual Released by CMS

The California Department of Public Health (CDPH) has issued an All Facilities Letter (AFL) to remind skilled-nursing facilities that its MDS newsletters, California MDS Nuggets, are posted on the CDPH website. The AFL also notes that the December issue includes significant changes to sections G, K and O of the Resident Assessment Instrument Manual released by the Centers for Medicare & Medicaid Services in October and November 2013. For more information, see the attached AFL and related newsletter.

Overview

Subacute Care

Subacute-care units provide a specialized level of care to medically fragile patients. Subacute patients are individuals who do not need acute care, but who are too ill to be cared for by most skilled-nursing facilities. Frequently, these individuals are ventilator-dependent or require frequent respiratory treatments. While subacute beds are licensed as skilled-nursing beds, they are reimbursed differently and are subject to additional staffing and patient criteria requirements.

CHA provides state and federal representation and advocacy in the legislative and regulatory arenas to improve access to quality, cost-effective subacute-care services.

CHA News Article

CDPH Issues AFL on Informed Consent for SNF Residents

The California Department of Public Health (CDPH) has issued an All Facilities Letter (AFL) concerning the informed consent process for skilled-nursing facilities (SNFs). The AFL reaffirms that when SNFs admit a patient with “unchanged, preexisting orders for psychotherapeutic drugs, physical restraints, or the prolonged use of a device that may lead to the inability to regain use of a normal bodily function,” they must verify that the patient health records contain documentation that the patient gave informed consent for  the order treatment. The AFL and updated FAQs are attached.

CHA News Article

CMS Issues Guidance on CPR in SNFs

The Centers for Medicare & Medicaid Services (CMS) has issued to state survey agency directors information regarding CPR in nursing homes. CMS Survey & Certification memo 14-01-NH disallows nursing home policies that prohibit employees from administering CPR to residents. Effective Oct. 18, nursing facilities must provide basic life support to a resident who experiences cardiac arrest, in accordance with that resident’s advance directives or a do-not-resuscitate order. CPR-certified staff must be available at all times and must administer CPR prior to the arrival of emergency medical personnel. A copy of the memo is attached.

Commands