Statement on CMS Review Choice Demonstration for Home Health Services
Wednesday, May 30, 2018
Posted by: Kyle Simon
For more information, contact:
Kyle Simon Director of Government Affairs and Communications
Based on the Federal Register notice, it is unclear when or what the Centers for Medicare & Medicaid Services’ (CMS) timeline would be to implement its proposed pre-/post-claim review demonstration program. But, it's obvious that Florida – yet again – is at the front of the line for implementation.
Florida home health providers are disproportionately subjected to too many complex and burdensome Medicare pilot programs and demonstrations, including the Home Health Value-Based Purchasing Model, which is in effect in nine states.
HHAs in our state are now in year three of the five-year HHVBP while also preparing for an overhaul of the Medicare payment methodology. Last year, Florida successfully dodged the PCR demonstration that went into effect in Illinois but did not result in any substantive fraud or abuse findings, rather it turned into an audit of documentation.
Resurrecting PCR would undoubtedly be a significant administrative and cost burden for providers already operating on razor-thin and ever-reducing reimbursement rates. Much less-burdensome approaches are available to CMS as the vast majority of “improper payments” are due to minor documentation errors or omissions.
On its face, the option for providers to choose between pre- or post-payment review is unlikely to have an impact on the level of burden for providers. This is because the face-to-face/physician documentation requirement remains nebulous in clarity, inconsistent in its application by CMS/MACs/auditors, and labor-intensive for HHAs to obtain from physicians for reimbursement purposes. These systemic issues and failures are what should be addressed and corrected, rather than adding an additional burdensome process.
If CMS' latest announcement were to become final, one practical and constructive policy change that would ensure a smoother implementation would be to permit non-physician practitioners to certify Medicare home health services as called for under the Home Health Care Planning Improvement Act pending before Congress.