To Receive CPE Credit

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1 2013 Hme Health PPS Final Rule Therapy Reassessments & M1024 Case Mix Cdes 12/18/12 Karen Vance, OTR Supervising Cnsultant T Receive CPE Credit Participate in entire webinar Answer plls when they are prvided If yu are viewing this webinar in a grup Cmplete grup attendance frm with Title & date f live webinar Yur cmpany name Yur printed name, signature & address All grup attendance sheets must be submitted t training@bkd.cm within 24 hurs f live webinar Answer plls when they are prvided If all eligibility requirements are met, each participant will be ed their CPE certificates within 15 business days f live webinar 2 1

2 2013 Hme Health PPS Final Rule Therapy Reassessments & M1024 Case Mix Cdes 12/18/12 Karen Vance, OTR Supervising Cnsultant Objectives List primary changes t therapy reassessment visit cunts in 2013 PPS Rule Explain advantage t discipline-specific missed therapy reassessment visits Describe hidden catch in cvered visit cunt after a missed reassessment Review elements required fr dcumenting a therapy reassessment Explain changes t using payment diagnsis field in OASIS C M

3 Plling Questin 1 Are yu ne f the fllwing disciplines? Physical Therapy Occupatinal Therapy Speech-Language Pathlgy Nne f the abve 5 Plling Questin 2 D yu have ne f the fllwing psitins in yur agency? Clinical manager/supervisr respnsible fr therapy Administratin Billing Nne f the abve 6 3

4 2013 Final Payment Rule CMS-1358-F Issued n Nvember 2, 2012 Nvember 8, 2012, Federal Register Prpsed rule CMS-1358-P Issued n July 6, 2012 July 13, 2012, Federal Register 7 Key 2013 Effective Dates New payment rates Effective fr hme health (HH) prspective payment system (PPS) episdes ending n & after January 1, 2013 New therapy reassessment & cverage requirements Effective fr HH PPS episdes beginning n & after January 1, 2013 New physician face-t-face (FTF) encunter requirements Effective fr HH PPS episdes beginning n & after January 1,

5 Therapy Reassessments Recap Reassessment requirements Must be perfrmed by qualified therapist Cannt be perfrmed by assistants Must ccur by each discipline At least nce every 30 days Prir t 14 th & 20 th cvered visits Must functinally reassess, cmpare resultant measurement t prir assessment measurements, & determine effectiveness f therapy 9 Therapy Reassessments Recap Single therapy discipline episdes Reassessments must ccur at least every 30 days 30-day perid may span episdes Reassessments must als ccur n exactly 13 th & 19 th cvered visits, unless Patient lives in rural area, r Dcumented circumstances beynd cntrl f therapist prevent reassessment frm ccurring n exactly 13 th & 19 th visit Must ccur n cvered visit 11, 12 r 13, & Must ccur n cvered visit 17, 18 r

6 Therapy Reassessments Recap Multiple discipline therapy episdes Reassessments must ccur at least every 30 days 30-day perid may span episdes Reassessments must als ccur by each discipline prir t 14 th & 19 th visits Based n cumulative ttal f all visits by all therapy disciplines Mre specificity t when reassessments ccur prir t in 2013 rule 11 Therapy Reassessments Recap Exceptin If n visit scheduled between cvered visits 14 & 19 by ne discipline & Last visit by that discipline was a reassessment, Then n reassessment required by that discipline prir t cvered visit 20 Example PT & OT prviding visits PT reassessment ccurs n visit 12 OT reassessment ccurs n visit 13 Only PT visits rdered between cvered visits 14 & 19 Only PT reassessment required prir t cvered visit

7 Plling Questin 3 In the last 2 years, did yur sftware adequately track the therapy reassessment visit cunt? Yes N Unsure 13 Reassessment Timing 2013 In cases where patient is receiving mre than ne type f therapy, qualified therapists must cmplete their reassessment visits during 11 th, 12 th r 13 th visits 17 th, 18 th r 19 th visits Rather than previusly undefined clse t Hwever, there is still an exceptin 14 7

8 Reassessment Timing 2013 Patients receiving mre than ne type f therapy If frequency f a particular discipline des nt make it feasible fr reassessment t ccur during specified time frame withut prviding an extra unnecessary visit r delaying a visit Still acceptable fr patient t be reassessed during visit scheduled clse t 14/20 th, but n later than 13/19 th cvered therapy visit 15 Missed Reassessment 2013 If required reassessment visit was missed fr any ne f the therapy disciplines therapy cverage wuld cease nly fr that particular therapy discipline Therefre, as lng as required therapy reassessments were cmpleted in a timely manner fr remaining therapy disciplines, therapy services wuld cntinue t be cvered fr thse therapy disciplines 16 8

9 Missed Reassessments 2013 Qualified therapist misses a reassessment visit Therapy cverage wuld resume with visit during which qualified therapist cmpleted late reassessment, nt visit after therapist cmpleted late reassessment In actuality, net effect is n different Final Rule Cmments Include Last visit by late reassessing discipline clsest t 13 th r 19 th Medicare-cvered visit nw a nncvered visit because reassessment requirement was nt met n that visit Example Visit 11 OT reassessment visit Visit 12 PT rutine visit Visit 13 ST reassessment visit Visit 14 OT rutine visit (cvered) Visit 15 ST rutine visit (cvered) Visit 16 PT reassessment visit (cvered) The rutine visit made by PT n visit 12 wuld be NON- COVERED 18 9

10 Dcumentatin Requirements Must dcument measurement results f functinal reassessment cmpared t prir measurements Must dcument therapist s determinatin f effectiveness f therapy Must dcument why therapy shuld be cntinued r, if applicable, discntinued 20 10

11 Therapy Reassessment Dcumentatin Des nt require a fullblwn evaluatin t extent f initial evaluatin Des nt have t be n a particular frm Des require an interventin review, demnstrating effectiveness f interventin Des have t be recgnizable as a reassessment 21 Therapy Reassessment Elements Functinal Gals & interventins must satisfy, s what? assuring apprpriateness t patient Objective Terms used mean same thing, by any therapist, any time they are used Measurable Prgress measured is cuntable 22 11

12 Mnitr Cunt & Cntent Autmate visit cunt as much as pssible thrugh sftware 2013 will challenge that since sme visits will nt be identified as nn-cvered until after the fact Due t this, visit cunt may be a mving target Assure cntent satisfies requirements f functinal reassessment Clarificatin added t dcumentatin after review must be legally entered & ntated as late entry 23 Plling Questin 4 Can yu tell frm yur reassessments whether cntinued skilled therapy is justified? Yes N Partially 24 12

13 M1024 Payment Diagnses Changes 2008 Attachment D f OASIS C Guidance Manual encuraged a decrease in use f M1024 fr payment diagnses as a replacement fr crrespnding V cdes in M1020/M1022 PPS Gruper will be revised t accmmdate ICD 10 CM changes at which time payment diagnsis fields will be rendered irrelevant 25 13

14 M1024 Payment Diagnses Changes Fracture cdes will be nly cdes permitted in M1024, accrding t ICD 9 CM guidelines, cannt be cded as primary r secndary diagnses in hme health Fracture cdes must be paired with apprpriate V cdes appearing in primary r secndary fields 27 M1024 Payment Diagnses Changes Payment diagnsis field will permit reprting f reslved cnditins Related t plan f care that may be significant in describing patient But will restrict awarding f pints t fracture cnditins 28 14

15 M1024 Payment Diagnses Changes Gruper lgic will be revised fr categries Diabetes Skin 1 Neur 1 When submitted as a secndary diagnsis immediately fllwing a V cde in primary diagnsis field Replaces current scring reprted in payment diagnsis field 29 M1024 Payment Diagnses Changes Reslved cnditins that may have been reprted in M1024 will nt be given case mix cnsideratin Cntrversy regarding actual financial impact f limitatin 30 15

16 Quality Reprting Claims data are a mre rbust surce f data fr accurately measuring acute care hspitalizatins Claims-based Acute Care Hspitalizatin and Emergency Department Use Withut Hspitalizatin measures will replace the OASIS-based measure n Hme Health Cmpare Clarificatin in Final Rule states the calculatin using a new surce f data. The measure cncept has nt changed The OASIS-based measure will cntinue t be reprted n the agency-specific CASPER reprts Quality Reprting Emergent care rate calculated frm claims data Based n rlling 12 mnths f data Measure cmputed using nly paid Medicare claims data frm bth HH agencies & utpatient claims cded with emergency rm (ER) revenue center cdes Data exclusins HH stays including bth utpatient ER & inpatient acute claims during initial 60 days HH stays invlving multiple agencies & Medicare Advantage enrllment perids HH stays in which initial episde paid as a LUPA 32 16

17 Quality Reprting Acute care hspitalizatin rate based n claims data Beginning with January 2013 data refresh Based n rlling 12 mnths f data Measure cmputed using nly paid Medicare claims data frm bth HH agencies & acute care hspitals Data exclusins Planned hspitalizatins HH stays invlving multiple agencies & Medicare Advantage enrllment perids HH stays in which initial episde paid as a LUPA 33 Summary Mnitr cunt & cntent f therapy reassessment visits Sftware edits may nt capture visits deemed nncvered after the fact Guard against assessment dcumentatin rules Lk fr cntent that will satisfy requirements use yur clinical reasning 34 17

18 Karen Vance Supervising Cnsultant Cntinuing Prfessinal Educatin (CPE) Credits BKD, LLP is registered with the Natinal Assciatin f State Bards f Accuntancy (NASBA) as a spnsr f cntinuing prfessinal educatin n the Natinal Registry f CPE Spnsrs. State bards f accuntancy have final authrity n the acceptance f individual curses fr CPE credit. Cmplaints regarding registered spnsrs may be submitted t the Natinal Registry f CPE Spnsrs thrugh its website: The infrmatin in BKD webinars is presented by BKD prfessinals, but applying specific infrmatin t yur situatin requires careful cnsideratin f facts & circumstances. Cnsult yur BKD advisr befre acting n any matters cvered in these webinars

19 CPE Credit Up t 1 CPE credit will be awarded upn verificatin f participant attendance; hwever, credits may vary depending n state guidelines Fr questins, cmplaints r cmments regarding CPE credit, please the BKD Learning & Develpment Department at training@bkd.cm 37 19