January
 
January — HHS O
ffice of Inspector General (OIG) is expected to release its 2014 Work Plan, which details where the OIG will focus its investigations.
Jan. 1 — Medicare payments to home health agencieswill be reduced by 1.05%, or $200 million, according to the 2014 PPS final rule.
Jan. 1 — CMS removes case-mix status from 170 current ICD-9 codes, including gastroesophageal reflux disease (GERD).
Jan. 1 — Hospices can begin voluntarily reporting new claims data. CMS finalized the new hospice data reporting requirements, which will require extra time to collect information from pharmacies, work with vendors to update systems and take precautions to prevent cash flow interruptions.
Jan. 1 — Hospices can begin submitting data on both hospice quality reporting measures (structural measure and Pain Measure — NQF No. 209) collected in calendar year 2013 for the 2015 payment update.
Jan. 6 — Medicare administrative contractors (MACs) have a green light from CMS to begin denying home health claims when the referring physician isn’t listed by national provider identifier (NPI) in CMS’ provider enrollment system, PECOS.
Jan. 7 — Changes to the Medicare Benefit Policy manual as a result of Jimmo v. Sebelius take effect.
Jan. 16 — Deadline for submitting third quarter 2013 data for the Home Health Consumer Assessment of Healthcare
Providers and Systems (HH-CAHPS) survey.
Jan. 16 — Deadline is 11:59 p.m. for filing your annual participation exemption request for HH-CAHPS if you served fewer than 60 eligible patients in the year ending March 31, 2013.
 
February
 
February — CMS will issue instructions that may tell surveyors how to determine when to impose a sanction and whether they should impose sanctions after one survey.
Feb. 4-5 — CMS training on the Hospice Item Set (HIS).
 
March
 
March — CMS is due to deliver a report to Congress suggesting revisions to the home health payment system that would improve service access among vulnerable patient populations. The report also could address “other areas of concern” in the PPS system, CMS notes.
March 3-7 — ICD-10 testing week.
March 19-20 — ICD-9-CM Coordination and Maintenance Committee meeting.
March 31 — Deadline for open enrollment for insurance for individuals through the states’ or federal health exchange. Individuals without insurance past this deadline will be penalized.
 
April
 
April 1 — Hospices must comply as of today with reporting the new claims data.
April 1 — Deadline for submission of data on both hospice quality reporting measures (structural measure and pain measure – NQF No. 209) collected in calendar year 2013 for the 2015 payment update.
April 1 — By now, agencies should have started testing ICD-10 codes and systems with their coding, billing and clinical staff.
April 14 — Hospices must begin to report data on the number and length of clinicians’ and aides’ visits and use of infusion pumps and drug prescriptions, using pharmacy and National Drug Codes.
April 17 — Deadline for submitting third quarter 2013 data for the Home Health Consumer Assessment of Healthcare Providers and Systems (HH-CAHPS) survey.
 
July
 
July — Proposed 2015 PPS rule expected.
July 1 — ICD-10 grouper comes out on or before today.
July 1 — Civil monetary penalties, payment suspensions for new admissions and an information dispute resolution (IDR) process will take effect for agencies penalized by surveyors.
July 1 — Hospices must begin complying with the completion and submission of the HIS admission and HIS discharge records for all patients admitted on or after this date.
July 1 — Edits to reject Medicare Advantage (MA) plan claims that do not have a HIPPS code for home health services will be activated.
July 1 — In addition to naming the referring physician on each claim, agencies must include the name and NPI of the practitioner who signed the face-to-face report.
July 17 — Deadline for submitting first quarter 2014 data for the Home Health Consumer Assessment of Healthcare Providers and Systems (HH-CAHPS) survey.
 
August
 
August — Hospice final rule expected to be released.
October
October — Freestanding hospices must provide more detailed cost data to CMS when new cost reporting requirements take effect as soon as October 2014 or as late as July 2015, depending on when the hospice’s fiscal year ends. Although no penalties are associated with noncompliance, failure to fill out a new cost report form fully and correctly could hurt agencies because CMS plans to use the cost report data to make payment reform decisions.
Oct. 1 — Claims with ICD-10 codes should be submitted for payment beginning today.
Oct. 1 — OASIS-C1 goes into effect.
Oct. 1 — The wage index for hospice takes effect.
Oct. 1 — Debility and adult failure to thrive can no longer be used as a primary diagnosis for hospices.
Oct. 16 — Deadline for submitting second quarter 2014 data for the HH-CAHPS survey.
 
November
 
November — Final 2014 PPS rule is expected.
November — Case-mix grouper released on CMS’ website.
 
 
Our 2013 predictions — how did we do?
 
As part of our annual HHL trends issue, we offer you a look at how last year’s predictions turned out. Here’s the result:
•• Prediction: CMS provided few indications about what rebased rates would look like, but an expert said a 1% annual payment reduction over three years is likely.
Result: False. CMS’ final 2014 PPS rule imposed the maximum allowed rebasing adjustment — minus 3.5% a year — on the Medicare home health benefit. If repeated in 2015, 2016 and 2017, the lost reimbursement for agencies will total $22 billion over the next four years, according to the National Association for Home Care & Hospice (HHL 12/9/13).
•• Prediction: Agencies received close scrutiny from auditors in 2012, and it was expected to continue. Result: True. Scrutiny actually increased. Medicare administrative contractors (MACs) Palmetto GBA and CGS in particular focused on widespread reviews of face-to-face encounter documentation, yielding an increased number of denials (HHL 6/17/13).
•• Prediction: The focus on readmissions in home health marketing will further evolve and help agencies forge longer-term partnerships with other providers.
Result: True. Of 172 respondents to HHL’s 2014 predictions survey, 41% said they’ve taken steps to partner with other providers to prepare for care transitions demonstrations, accountable care organizations (ACOs) or other payment model changes; 26% said they will in 2014. About 38% of the 2013 survey’s respondents took steps last year.
•• Prediction: The Affordable Care Act’s (ACA) insurance mandate will be a key issue in 2013; agencies must determine what insurance plan, if any, they plan to offer their staff if they have more than 50 full-time equivalent employees.
Result: False. The mandate to provide health insurance for full-time staff or pay a penalty was delayed for one year; as a result, the employer mandate now doesn’t go into effect until 2015. Many agencies were pleased, saying the mandate will be costly and potentially devastating (HHL 7/15/13). The ACA will be a key issue for agencies throughout 2014. They should have begun determining how to track all hours worked, regardless of the employee’s status, by Jan. 1, 2014 (HHL 8/12/13). This information is needed to report accurately to the IRS whether the employer mandate applies to your agency once it takes effect.