HOME CARE ALLIANCE OF MASSACHUSETTS
QI Committee Meeting
Wed. May 2, 2012
Berkshire VNA
Minutes of March 7, 2012 meeting at VNA of Greater Milford accepted.
Medical Review –
ADR’s/Denials - Many agencies getting LUPA’s, some w/a noticeable increase recently.
1 agency got a letter from their intermediary, Palmetto, saying they are behind in their reviews, but will get to them. Colleen suggested contacting Mary St. Pierre at NHAC as Palmetto is not following the regulations re time frames allowed for review.
1 rehab ADR pd, no issues. 1 claim denied x2 because on F2F, MD did not write re homebound status in the correct place, though it was on the form in another place. 1 denied because did not send a F2F w/ a recert, which is not required. Agencies are finding almost no denials are being overturned at Redetermination or Recon, going to ALJ, where they are generally being overturned. One agency just had a decision overturned at Recon, first one in a very long time.
RAC audits – Some agencies have gotten notified by mail re RAC findings of the first round, but some have not. No new RAC’s recently.
CERTS – No recent requests.
TPL’s – See end of minutes. Request made by some members to talk about this last, as some agencies don’t have TPL’s.
Surveys -
No Joint commission surveys.
DPH – Several recent surveys, 2 at exactly 3 years, 1was 8 months early. No deficiencies.
1 – Wanted full list of all pts, w/ dx, addresses, payor, and disciplines. Visits lined up, then surveyors wanted to change it all. Wanted HHA and wound care visits, complaint log. Wanted supervisionsof PTA’s and COTA’s. Showed surveyors their policy which was probably not adequate but they let it go. No HR requests.Visits were fine.
2 – 3 tiered survey, if pass first, then all set. Wanted HHA, wounds and multi disc. Focused on cleaning of equipment, alcohol not enough, need bleach.
3 –Wanted HR records of HHA and 2 RN’s, wanted charts printed out. Did look at cleaning of equipment but did not ask about cleaning of hand held device. Wanted charts printed out.
Face to Face Encounter Regulation -
Many agencies still having problems. NP’s signing, general agreement that if MD co-signs, that is OK. Dr’s writing “Can’t drive” for why homebound. 1 MD wrote re why pt needs home care “Because he needs it.” 1 agency said they would not take any more of an MD’s pts due to probs getting F2F: MD called agency w/ new referrals, saying he didn’t know anything about it (the problems w/ F2F);got a letter from a doctor who said that he wouldn’t do any more F2F, they need to get them from Hospitalist; d/c’d 2 pts for no F2F, then made a new SOC to get some visits covered. Discussion re is it worth it, depending on the # of visits and amt of $. 1 agency had thousands of dollars being held up as MD wouldn’t complete F2F or sign orders, despite doing everything possible to get him to do it. His name was brought up at a system meeting, and 2 of the higher-ups called him; he is much better now but still a problem. Same agency had another MD trying to charge VNA’s $20.00 to complete each F2F….
Regulatory/Alliance Updates –
PECOS – Now is updated monthly on-line. More user friendly but still has problems: looking at it on–line can freeze computer as there are so many names, but down-loading takes a long time.
Colleen is on a new committee, it is re a new initiative about Dual Eligible 18-64 years old pts, involves looking at coordination of care, quality of care and it would be monitored so may mean an end to TPLs. It is a huge project state project and has 5 sub-groups.
New Medicare Notice of Non-Coverage became mandatory as of yesterday, 5/1/12.
Colleen will ask Royce re teaching tool CD for home care SOC to see if all agencies can get a copy.
Upcoming Educational Programs/Conferences
Coding workshop,Intermediate level, Wed. 6/20/12 in Burlington.
Home Care Supervision /Plus – Management Training Program for supervisors and managers. Tues. 6/26/12, Norwood.
HHABN Teleconference by Sally Rosiello from NHIC – Wed. 5/30/12. Registration is required. Be sure to Ask Questions, as there is still a lot of confusion about how to fill out HHABN’s. Info from the last inservice and the Q and A’s were different. If it’s in writing, we have proof.
New England Home Care Conference and Trade Show 5/31 and 6/1/12, Foxwoods, Ct.
Jennifer from NashobaNsg Service got a call 2 weeks ago from the OIG, Fraud Prevention Unit re OASIS submission procedures. OIG will visit them on 5/15, to review 3 records from early 2010. 2 FBI agents came to see if the agency actually exists. Agency is not sure what it is all about. Discussion re how agencies make OASIS corrections. Most communicate w/ clinician (in person, by phone or Skype, depending) and document agreement w/ changes.
TPL’s - The lists of claims needing to be submitted for Medicare review (quarterly) has decreased significantly. TPL unit is not clear why but it does reduce their burden also.
Jamie met w/ Tim Burgers, Dayce Moore, and others at the TPL Unit to get a better idea of what is expected for TPL claims, especially re HHABN’s. Shefelt they were vague about a lot of things but they did say they will not recoup monies based on an invalid HHABN (and dated after 1/1/11) until after it has gone through the ALJ, who says it is invalid. HHABN’s continue to be an issue w/ CMS, different reviewers, Mass Health, ALJ’s and agencies. (Remember – HHABN Teleconference 5/30/12. See above.)
Also, Dayce said providers can appeal at any level, but provider could also send Mass Health info and they would include it in their file. Jamie wanted to know how providers could be guaranteed that we would be notified of ALJ hearings or OTR reviews, because if we don’t know, we are unable to participate even though we have the right. Mass Health said they are under no obligation to notify the provider, it is up to CMS. Recently, Jamie had to interrupt an ALJ hearing that had been going on for ½ hr, because ALJ office did not call her as planned. She insisted that they start over.
The (Not) Homebound Pilot program w/ Mass Health will not be open to all agencies until June of 2013, as Mass Health is re-vamping the process. Many claims from pilot agencies have been removed from the list requiring Medicare review, by proving up front that pt is not homebound per documentation from the pt’s chart. Most agencies in general have a lot less on the quarterly lists required for submission than before, but Jamie said “they raised the claim level to lower the burden on them,” and they won’t explain fully.
Next meeting – Wednesday, July 11, 2012 VNA of Cape Cod, Hyannis, Mass. Directions to follow.
Respectfully submitted,
Susan Frawley, QI RN
VNA of Cape Cod
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