Non-compliance could lead to a 2% decrease in payments in the future years. CMS has recently issued a notice stating that if you’ve received a letter indicating your non-compliance with the program’s requirements, you’ll be subject to a 2% payment cut in the next fiscal year for Home Health. Additionally, this memo mentions that you have until November 13, 2023, to send a reconsideration request via e-mail if you believe that the letter contains inaccurate data and that you have met the requirements of the Home Health Quality reporting program.
The requirements for avoiding the 2% reduction in payments are often misinterpreted. There are two main components to consider in determining compliance. First, you must fully meet the Home Health CAHPS survey requirements, with your vendor properly and promptly submitting all necessary data. Second, and often more confusing, is the OASIS data aspect. A specific calculation requires that 90% of your OASIS transmissions qualify as Quality Assessments, which means the OASIS must fall within a quality care episode. These episodes are determined from the Start of Care to Transfer or Discharge, and from Resumption of Care to Transfer or Discharge. When evaluating your compliance, they will examine all transmitted OASIS data, ensuring at least 90% fit within a quality episode.
An OASIS can be considered as not in a quality episode where there’s no follow-up after the initial Start of Care assessment. In a hypothetical scenario of 50 patients, if thirty of these patients had a new Start of Care OASIS submitted during the time period of calculation and there were no subsequent OASIS submissions for them, those initial assessments would negatively impact the calculation of whether the assessments fit into a quality episode of care. Only if there was a subsequent Transfer or Discharge, would those assessments be deemed compliant with a quality episode. Similarly, if you have instances of Resumption of Care without any subsequent OASIS, those situations would also count against you in this calculation.
Remember, if you initiate a Start of Care and then proceed with multiple recertifications, as long as those recertifications are submitted, the Start of Care remains compliant. It only becomes non-compliant when only the Start of Care is submitted without any follow-up, or perhaps a few recertifications are submitted but then nothing else. There must eventually be an end point. If there’s a gap where recertifications aren’t being submitted and there’s no Transfer or Discharge, those assessments will negatively affect the calculation.
To review the details of this calculation, please click here.
Should you have any questions about the Home Health Quality Reporting program, feel free to contact Healthcare Provider Solutions.
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