COMING UP

INSIDE

Your Source for HOME CARE News, Policy and Advocacy Vol. 2, Issue 16 | April 17, 2017

See PALLIATIVE p. 3

Rediscover,Reimagine,Reinvent at HCA’sAnnual Conferencein SaratogaSaratogaSprings, NYMay 3 to 5

Moving BeyondPersonal Care toMeet the Challenge& Opportunities ofValue-Based CareNew York City, NYMay 18, 2017

For moreinformation on theseand other programs,please visit theeducation andevents section ofHCA’s website athttp://hca-nys.org/events-education/upcoming-events

See BUDGET p. 2

HCA Memo Details Final State Budget

HCA has prepared a memo for members outlining all of the key provisions of the newlyenacted state budget.

This memo (available at http://hca-nys.org/wp-content/uploads/2017/04/201718FinalStateBudgetMemoFINALVERSION.pdf) adds further flesh to our previousmember reports issued in e-mail alerts and in last week’s edition of the Situation Reportnewsletter. It provides: a summary of the prominent and new home care, MLTC and

National Experts in Palliative Care Featuredat HCA Annual Conference May 3-5 Palliative care enhances patients’ satisfaction, quality of care and outcomes, and itreduces costs: all aspects of the “Triple Aim.” Yet studies show that palliative care isalso underutilized. HCA’s Annual Conference on May 3 to 5 includes a must-attend pre-conference sessionfocusing on palliative care, presented by highly sought-after, accomplished names in thefield.

Palliative Care Experts Featured at HCA Annual Conference...........................1HCA Memo Details Final State Budget...........................................................1MedPAC Confirms Call for New HHPPS by 2021...............................................3A Message from HCA Sponsor Sandata..........................................................3Member Hiring Announcement....................................................................4Court Decision Issued on Live-In Case...........................................................5Reminder: HCA Sepsis Screening Tool Now Available......................................6Meet HCA’s Award Winners..........................................................................7

Plan-Provider Partnerships for Five-Star Quality.........................................8OMIG Issues 2017-2018 Work Plan.............................................................9New LHCSA Applications Addressed at PHHPC Meeting..............................10CMS Releases Updated Medicare Home Health HHPPS Booklet.................10Wound Care Institute Presents Journal Free for HCA Members..................11NGS Updates.........................................................................................11Early Intervention FAQs Posted................................................................12Resources...................................................................................12

OMIG

OMIG releases its 2017-18 workplan identifying focus areas foraudits and compliance, includingareas of concentration for homecare, MLTC.

LIVE-IN CASE

New Court decisionimpacts 24-hour, live-incases; HCA to hold 4/20conference call withmembers to discuss.

PAGE 5 PAGE 9PAGE 7

AWARDS

HCA is thrilled to announcethe winners of our annualawards, including the Caring,Advocacy and Ruth F. WilsonAwards.

SEPSIS

HCA reminds members thatthe sepsis tool is nowavailable for use. Please besure to sign the useragreement today.

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The Situation Report is a weeklypublication of the Home CareAssociation of New York State(HCA). Unless otherwise noted, allarticles appearing in The SituationReport are the property of theHome Care Association of NewYork State. Reuse of any contentwithin this newsletter requirespermission from HCA.

Joanne CunninghamHCA President

jcunningham@hcanys.org

Roger L. NoyesDirector of Communications,Editor of The Situation Report

rnoyes@hcanys.org

Al CardilloExecutive V ice President

acardillo@hcanys.org

Patrick ConoleVice President,

Finance & Managementpconole@hcanys.org

Andrew KoskiVice President,

Program, Policy & Servicesakoski@hcanys.org

Alexandra Fitz BlaisDirector of Public Policy

ablais@hcanys.org

Laura Constable Senior Director,

Membership & Operationslconstable@hcanys.org

Celisia StreetDirector of Education

cstreet@hcanys.org

Mercedes Teague Finance Manager

mteague@hcanys.org

Jenny KerbeinDirector of Governance &

Special Projectsjkerbein@hcanys.org

Billi Wilson Manager, Meetings & Events

bwilson@hcanys.org

Teresa BrownAdministrative Assistant

tbrown@hcanys.org

Volume 2, No. 16 April 17, 2017

Home Care Association of New York State (HCA)388 Broadway, 4th Floor, Albany, NY 12207

Tele: 518-426-8764; Fax: 518-426-8788; Website www.hcanys.org

The Situation Report: the Home Care Association of New York State

BUDGETfrom p. 1

hospice impacts; the overall health and Medicaidprovisions applicable to all providers; a more detailedanalysis of highlight provisions affecting HCA membersdirectly; reimbursement actions continued from prior-year budgets; and other health care actions that HCAmembers need to know about. Please be sure to sharethis memo with all of your key staff.

With the final budget now passed, the Legislature isadjourned until April 24, when it will resume its 2017session to deliberate on legislation.

This year’s final budget was unusual for itsprocedural complexity, including the initial passageof a stop-gap temporary budget extender bill(which is still unsigned) prior to the enactment of afinal budget.

The Governor resorted to this short-term extenderbill as major issues were still unresolved at thebrink of the April 1 fiscal deadline. By excludingmany of the larger and budget-wide impact issues,this extender bill provided a means to keepoperations running while negotiations continuedpast April 1. These larger issues were then laterincorporated into a final, all-encompassing“revenue bill” once agreements were ultimatelyreached.

In addition, critical health portions of the budgetagreement have been rendered via a “side letter” fromthe Governor to the Legislature, and not included in theactual budgetary or legislative language, making thereview process further unwieldy. The Department ofHealth, meanwhile, has stated its intent to enactcertain provisions administratively, absent underlyingbudgetary legislative language.

Members with questions about the memo or anyspecific budget provisions are welcome to contact anyof the HCA Policy staff.

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A message from HCA sponsor Sandata

In “Achieving Value through Palliative Care” on May 3, Dr. Todd R. Coté, Program Director for theUniversity of Kentucky’s Fellowship in Hospice and Palliative Medicine, will highlight the status ofhospice and palliative care in the current health care landscape. Dr. Coté is also Chief Medical Officer of Bluegrass Care Navigators (a large, nationally-recognizedhospice and palliative care organization). From this vantage point, he will review the value propositionthat palliative care continues to offer all of health care while exploring emerging trends in community-based palliative care. The palliative care focus will continue during the pre-conference session with palliative medicine andmedical marijuana expert Dr. Bernie Lee, Associate Chief Medical Officer of Metropolitan JewishHospice and Palliative Care, who will provide an overview of the risks and benefits of the use ofmarijuana in the palliative care setting. Dr. Lee will highlight the rules and regulations that health careproviders should know about New York’s Medical Marijuana Program. HCA’s Annual Conference is just a fewweeks away, so register now to achievethe value of receiving this pre-conference program AND the mainconference program featuring top-notcheducation sessions and networkingopportunities at this biggest, mostimportant HCA event of the year. Registertoday at www.hcaannualconference.com.

MedPAC Confirms Call forCMS to Implement NewHome Health PPS PaymentSystem by 2021

In a meeting this month, the MedicarePayment Advisory Commission(MedPAC) unanimously voted torecommend that the U.S. Centers forMedicare and Medicaid Services(CMS) implement a new home healthprospective payment system (PPS) by2021.

The vote comes a month after thecommission – which is tasked withrecommending rate adjustments forMedicare’s fee-for-service paymentsystem to Congress – submitted arecommendation in its March Report

PALLIATIVE from p. 1

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that CMS impose a 5 percent rate cut to the home health PPS for 2018.

MedPAC states that the new home health PPS would aim to combat payment issues embedded in thecurrent system, including incentives to provide certain types of care for certain patients.

“By rebalancing the financial incentives, the post-acute care (PAC) PPS will correct the current inequities inthe Skilled Nursing Facility (SNF) and home health PPS that favor some types of patients and providers overothers,” Carol Carter, PhD, principal analyst at MedPAC, said during the meeting.

While MedPAC is an influential voice on payment issues, Congress is not obligated to implement itsrecommendations, and oftentimes does not.

In January, HCA President Joanne Cunningham sent a letter to MedPAC’s Executive Director, Dr. Mark E.Miller, raising “grave concerns” regarding MedPAC’s home health recommendations for 2018 and the dataassumptions underlying them. The letter is at http://hca-nys.org/wp-content/uploads/2017/01/MedPAC2017ReporttoCongress.pdf.

In the letter, also cc’d to New York’s Members of Congress, Ms. Cunningham presented some New York-specific home health agency financial findings that vary substantially from MedPAC’s aggregate, nationaldata assumptions.

HCA supports a payment system that duly covers home health services and reimburses providerscommensurate with the needs of patients. The existing home health PPS has been subject to draconian ratecuts and faulty rebasing initiatives that are largely consistent with MedPAC’s problematic data assumptionsand recommendations.As such, HCA willcontinue to carefullyanalyze and weigh inon any furtheradjustments oroverhaul to the existingmethodology, ifpursued by CMS,especially changes thatwould worsen longtimepayment disparities orcreate altogether newones.

For further information,contact Patrick Conoleat (518) 810-0661 or atpconole@hcanys.org.

Chief Financial Officer

Oneonta, New York

Bassett Healthcare Network: At Home Care, Inc. (AHC), a nationally recognized and

progressive Medicare Certified Home Health Care agency, seeks to hire an executive level financial

leader.

Operating across five predominantly rural counties in Central NY, AHC is an integral healthcare network

partner. With a data driven integrated financial and clinical leadership approach, the individual will be

responsible for planning, oversight and directing all fiscal operations of the organization.

Candidate Qualifications

Experienced home health financial leader with McKesson Horizon IS experience, preferred

MS Office and accounting software experience required

A clear and concise communicator, written and oral

Education: bachelor’s degree in accounting or finance required; Masters or CPA, preferred

Competitive salary and benefit package offered.

For more information, or to submit a CV in confidence, please direct to:

Patricia Brown, Director HR; 25 Elm Street, Oneonta NY 13820

Or, E-mail: pbrown@ahcnys.org

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Court Decision Issued on Live-In Case

This week, the New York State Supreme Court, Appellate Division, First Department, issued a decision inNina Tokhtaman, etc. v. Human Care, LLC, holding that live-in home care aides are not necessarily acategory of employee who need only be paid for 13 hours of a 24-hour shift.

According to the court, live-in aides who fall outside of that category would be entitled to be paid for eachhour of a 24-hour shift. It is not clear if this decision will be appealed.

The Court found that a widely cited state Department of Labor (DOL) opinion letter (March 11, 2010)conflicted with DOL regulations [12 NYCRR, section 142-2.1(b)]. Thus the court refused to follow the DOLopinion. The regulations provide that the minimum wage must be paid for each hour an employee is“required to be available for work at a place prescribed by the employer,” except that a “residentialemployee – one who lives on the premises of the employer” – need not be paid “during his or her normalsleeping hours solely because he is required to be on call” or “at any other time when he or she is free toleave the place of employment.”

The March 11, 2010 state DOL opinion letter advised that all “live-in employees,” regardless of whether ornot they are “residential employees,” nevertheless “must be paid not less than for thirteen hours pertwenty-four hour period provided that they are afforded at least eight hours for sleep and actually receivefive hours of uninterrupted sleep, and that they are afforded three hours for meals.”

The defendants unsuccessfully argued that, based on the state’s opinion letter, a live-in aide need only bepaid for 13 hours of a 24-hour shift as long as the aide received the requisite uninterrupted sleep time andmeal periods. The court declined to follow the opinion in this case, noting, according to the court, that theopinion “fails to distinguish between ‘residential’ and ‘nonresidential’ employees,” and found that eventhough the live-in aide admitted to having worked 24 hours a day, seven days a week in the client’sresidence, the aide was not necessarily a “residential employee.” Consequently, the court held that if thelive-in aide can demonstrate that she was a nonresidential employee, she could recover unpaid wages forhours worked in excess of 13 hours a day.

The standard embodied in the DOL opinion letter, refused by the court, has been relied on by home careproviders and the state; thus, if this decision or a similar one is upheld, it will have major ramifications forthe delivery of 24-hour/live-in care.

Other cases that include this issue are working their way through the courts, including Andryeyva v. NewYork Health Care, Inc., on which HCA submitted an amicus brief and on which oral arguments were held inmid-January.

Free member call on court cases

On Thursday, April 20, at 10 a.m., HCA will hold a free, members-only conference call to discuss this April11 court decision that has major ramifications for the delivery of “24-hour live-in” care. To register for thiscall with legal experts and the HCA Policy team, please complete the online form at the link below andHCA will send you dial-in information in advance of the April 20 call. Register for the call at: https://www.surveymonkey.com/r/call24hourcases.

Frank Fanshawe, HCA’s counsel and partner at Jackson Lewis, contributed to this article.

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HCA Home Care Sepsis Screening Tool, Now Available For Use, to Be Featured atNational Leaders Forum HCA’s home care sepsis screening tool is being featured next week at the Visiting Nurse Associations ofAmerica (VNAA) National Leadership Conference in San Diego. The state Commissioner of Health and othersare actively engaging HCA on the merits of this tool as well. HCA applauds members who have been activelysigning up, and encourages others to do the same. While often misunderstood as an “in-hospital” occurrence, the vast majority (over 80%) of sepsis-relatedinfections occur in the home and community. Anyone can develop sepsis from illness or injury. However, thepatient population served by home care is among the highest risk for sepsis occurrence.

HCA’s new tool guides home care clinicians on sepsis-risk identification, screening and protocols. In a seriesof recent webinars, HCA also provided examples of how the tool can be readily integrated into a home careagency’s electronic medical records (EMRs). Participation in these webinars, conducted by HCA and IPRO,is a prerequisite for using the tool.

HCA is offering the tool as a free, direct benefit to HCA Members. HCA will soon make the tool availablefor non-HCA members at a modest fee. How to access the tool To access the tool, HCA members must first complete the user agreement, which is required by HCA to helpensure preparation for use, standardization and quality. The user agreement is available at http://hcaannualconference.com/wp-content/uploads/2017/03/HCASepsisToolUserAgreement.pdf. By signing it, licensees attest that they have viewed all of the HCA/IPROinstructional webinars for use of the tool, which is a prerequisite. (Users may view archived versions of thewebinars to satisfy this requirement. The archived webinars are available at http://atlanticquality.org/initiatives/sepsis-initiative/educational-eventswebinars/.) The user agreement also establishes important legal prohibitions on sharing the tool with outside entities.Licensees also agree to submit de-identified data in connection with using the tool, unless an agency lackscapacity to provide such data. A secure data portal managed by IPRO will be made available for data sharing.The data sharing will be used by HCA to further support provider use, implementation, effect, evaluation andimprovements to the process. It will also assist providers and HCA in promoting the value of this tool bothclinically and fiscally. Please see the user agreement for further details on these and other requirements. HCA, IPRO and partners will conduct initial teleconference meetings (anticipated to be approximatelymonthly) to review questions, answers and experiences. To take the next step, please do the following:

Read the user agreement, assure that your agency meets the requirements, and sign the agreement.

E-mail an attached version of the signed user agreement to sepsistool@hcanys.org.

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Upon receipt of the user agreement, HCA will check your membership status, and, once confirmed andaccepted, send you the approved user agreement, the tool itself, and further instructions.

If you have any additional questions, please contact sepsistool@hcanys.org.

Meet HCA’s AwardWinners, And Cheerthem On At HCA’sAnnual Conference

HCA is proud to announce thewinners of our annualawards, which will bepresented during a ceremonyat HCA’s Annual Conferencenext month.

HCA’s Awards Committeefaced the difficult task ofselecting winners fromamong several exceptionalcandidates for our Caring;Advocacy; and Ruth F. Wilsonaward categories.

The finalists are mentionedon the next page, but thesummary of theirachievements, in this week’snewsletter, only scratch thesurface; we stronglyencourage all members toattend the award ceremonyon May 4 in Saratoga (as wellas the entire Mary 3-5 AnnualConference) to hear first-hand the compelling storiesbehind each award winner’sselection.

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This year’s Caring Award winners are: Amy Bowerman, Director of Patient Services/Director of QualityHome Care Services of the Mohawk Valley Health System, for her dedication to saving patients’ livesthrough sepsis intervention and commitment to quality enhancement; and Eileen Crawford, Home HealthAide at VNS of Westchester, for her selfless volunteerism and amazing “sixth sense” in spotting patients’problem health conditions, getting them the right interventions and performing lifesaving CPR for patientsduring medical emergencies.

Our Advocacy Award recognizes the home care staff at Mid-Hudson Regional Hospital who got their agencythrough a reorganizational transition following the closure of St. Francis Hospital and Health Centers,garnering a positive state Department of Health survey during the first week in their new network andardently protecting and supporting their patients throughout. A second Advocacy Award goes to RussellLusak, Senior Vice President at Selfhelp Community Services, for his leadership positioning home care inthe development of health information technology (HIT) policy and his work linking up HIT with value-basedpayment models addressing social determinants of health, an area of his expertise that he is especiallypassionate about.

HCA’s Ruth F. Wilson Award, our highest honor, goes to Sara Butterfield, Senior Director at IPRO. For years,Sara Butterfield has been a torch-bearer for the advancement of home care quality, promoting home care’sstatewide and national efforts in quality benchmarks, technical assistance and advocacy.

Please join HCA and colleagues in celebrating these exceptional award winners at our Annual Conference.Details are at www.hcaannualconference.com.

Plan-Provider Partnerships for Five-Star Quality‘Think Tank’ Session at HCA Annual Conference on May 4, 2017 from 2:15 to 3:15 p.m.

At HCA’s Annual Conference, just a few weeks away, HCA Executive Vice President Al Cardillo, LMSW, willmoderate a panel discussion tackling this question: How can managed care plans and providers synchronizetheir clinical efforts and quality/performance priorities to reach five-star excellence?

Hear from our panel of plan and provider quality leaders as they engage in discussion on the qualityindicators that are held in common, exploring the opportunities for garnering five-star outcomes throughplan-provider collaboration. Panelists will also highlight any potential system or policy barriers that mightinhibit such innovation. They include:

Amy Bowerman, RN, Director of Quality Improvement/Privacy Officer, Mohawk Valley HealthSystems-Home Care Services and Director of Patient Services-Senior Network Health

Sara Butterfield, RN, BSN, CPHQ, CCM, Director, Upstate Health Care Quality Improvement, IPRO

Dianna D’Amico, RN, MA, Director, NY MLTC, Empire BlueCross BlueShield HealthPlus

Take advantage of this panel session and many other exciting programs at HCA’s Annual Conference on May3-5, 2017, plus attend our Annual Awards luncheon, networking sessions, exhibits, town hall meeting withthe HCA Policy team and more. Reserve your seat today at www.hcaannualconference.com.

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OMIG Issues 2017-2018 Work Plan

The state Office of the Medicaid Inspector General (OMIG) announced its new 2017-2018 Work Plan, whichdetails the program integrity areas of focus in the Medicaid program for State Fiscal Year 2017-2018.

This Work Plan applies to providers, suppliers, and managed care organizations, along with otherstakeholders. It provides a roadmap for the year focusing on three main goals: 1) enhancing compliance,including provider compliance and monitoring of compliance programs by OMIG; 2) promoting innovativeanalytics using tools to detect fraud and waste as well as data mining and analysis, cost savings measures,and pre-payment reviews; and 3) “Fighting Fraud, Waste, and Abuse.”

Among its work in all areas of the Medicaid health care system, the Work Plan specifically identifies targetinitiatives in home health and community-based care services, long-term care services, and MedicaidManaged Care. Specifically, OMIG says it will:

Continue to work with the visit Verification Organizations (where applicable to certain home careentities) to standardize the reports in the VO portals and to identify areas of potential improvement.

Review and recover billings for claims identified as duplicative.

Continue to audit LTHHCP fee-for-service (FFS) Medicaid claims to verify per-visit and hourly ratescalculated for the various ancillary services provided, with a focus on LTHHCPs with both highMedicaid utilization and rate capitations. OMIG will also review rate add-ons, including fundsdedicated to worker recruitment, training, and retention.

Continue to conduct personal care and CHHA FFS audits, and will initiate CHHA Episodic PaymentSystem (EPS) audits.

Target compliance pertaining to minimum wage and Wage Parity laws. OMIG says it will “auditmanaged care organizations and contracted network providers’ records and reports to ensure thatfunds provided for employee wage increases are properly distributed to health care workers inaccordance with statutory requirements and the procedures established by DOH.”

Perform various match-based targeted reviews and other audits in managed care, identified throughdata mining, analysis, and other sources to recover overpayments and implement corrective actions.OMIG notes that its executive staff “launched a new project team approach to guide the agency’sprogram integrity efforts in Medicaid Managed Care. OMIG established a project management office(PMO) with a dedicated project manager and created five teams with specific areas of focus.”

Evaluate Value Based Payment VBP reimbursements from a program integrity perspective, “makerecommendations and update audit processes accordingly.”

The full 2017-2018 Work Plan with further details can be viewed at: https://omig.ny.gov/index.php/information/work-plan.

HCA will seek OMIG’s engagement to further provide details and helpful information to HCA membersregarding this plan.

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New LHCSA Applications Addressed at PHHPC Meeting

At the April 6 meeting of the Public Health and Health Planning Council (PHHPC), the PHHPCapproved all of the applications related to Licensed Home Care Services Agencies (LHCSAs).

These included:

Eight entities to establish a LHCSA;

Five entities to establish a LHCSA associated with an Assisted Living Program; and

Seven LHCSAs for a change of ownership.

The applications and background information are at http://www.health.ny.gov/facilities/public_health_and_health_planning_council/meetings/2017-04-06/.

At the meeting, the state Department of Health (DOH) confirmed that it is now acting on all LHCSAapplications; this replaces its past policy of only scheduling LHCSA applications on the PHHPCagenda that requested approval for a change of ownership, were affiliated with an ALP, or weresubmitted by counties.

HCA reminds members that DOH has recently posted LHCSA guidance materials and procedures forfiling policies and procedures manuals at https://health.ny.gov/facilities/home_care/guidance_docs_for_lhcs_applicants.htm.

CMS Releases Updated Medicare Home Health PPS Booklet

The U.S. Centers for Medicare and Medicaid Services (CMS) has recently updated a booklet on theMedicare home health prospective payment system (HHPPS).

The booklet includes the following information: background on HHPPS; consolidated billingrequirements; criteria that must be met to qualify for home health services; therapy services;elements of and updates to the HHPPS; physician billing and payment for home health services; andthe Home Health Quality Reporting Program.

HCA members can access CMS’s updated HHPPS booklet at: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/MLN-Publications-Items/CMS1243662.html.

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

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Wound Care Education Institute Presents Journal Free for HCA Members

HCA has partnered with the Wound Care Education Institute (WCEI) to provide both onsite and online skinand wound care courses at an HCA-member discount for your professional staff.

WCEI is also offering free access for HCA members to see WCEI’s quarterly digital journal, Wound Central,available at https://www.woundcentral.com/. You will need to register as a new user to access the journal.

This issue of the journal focuses on lower extremity wounds. Featured articles include:

A review of the evidence for adjustable compression wrap devices

Differentiating between red legs and cellulitis

Healing of chronic sickle cell-disease associated foot and ankle wounds using transdermalcontinuous oxygen therapy

Onsite and Online Wound Care Training for Your Clinicians

More information on WCEI’s five-day onsite and online courses is available on a dedicated page of HCA’swebsite at http://hca-nys.org/hca-and-wcei-partner-on-wound-care-education-courses. These coursesoffer an evidence-based approach to wound management and current standards of practice, withdiscounted rates for HCA members. Upcoming onsite courses in New York will take place at the followinglocations:

April 24-28, 2017Catholic Health Services144 Genesee StBuffalo, NY 14203

Sept. 11-15, 2017Marriott East Elmhurst102-05 Ditmars Blvd.East Elmhurst, NY 11369

NGS Updates

National Government Services (NGS), New York’s Medicare Administrative Contractor (MAC), has recentlyposted the following information to its website.

Information for Providers who Submit Multiple Faxes in Response to an ADR Request – In aneffort to assist providers in avoiding unnecessary denials when responding to a medical reviewadditional documentation request (ADR), NGS states that providers should use a fax cover sheetwhen submitting multiple documents, noting the total number of pages and an identifier, such as

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the DCN, HICN, and/or a copy of the ADR letter. If faxing more than one batch of documents, besure to include that on the cover sheet, (i.e., batch 1 of 3, batch 2 of 3, etc.).

If the fax submission is not working, please choose an alternative method of delivery, (i.e.,USPS, CD, esMD, NGSConnex). Additional information is available on NGS’s website under theMedical Policy and Review tab/Medical Review.

Reminder: Only Zero Charges Allowed on Revenue Line 0023 – NGS says it has receivedmany claims recently billed with charges other than zero on the 0023 revenue line. Yet, bothrequests for anticipated payments (RAPs) and episode final claims must be billed with zerocharges on revenue line 0023. Any charges other than zero cause claims processing errors andare out of compliance with home health billing guidelines.

The U.S. Centers for Medicare and Medicaid Services (CMS) Claims Processing Manual (https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/clm104c04.pdf) states thattotal charges are required for this revenue line and “The HHA reports zero charges on the 0023revenue code line.”

For further information, contact Patrick Conole at (518) 810-0661 or pconole@hcanys.org.

Early Intervention FAQs Posted

The state Department of Health (DOH) has posted Frequently Asked Questions (FAQs) on the EarlyIntervention (EI) program.

The FAQs are on the Health Commerce System (https://commerce.health.state.ny.us/public/hcs_logout.html) and also athttp://hca-nys.org/wp-content/uploads/2017/04/Early-Intervention-FAQs_April-2017.pdf.

The FAQs cover: contents of a session note; record retention requirements; use of electronic records;changes in eligibility; transfer of cases; use of ICD-10 codes; provider continuing educationrequirements; components of a quality assurance plan; and others.

Resources

“Medicare Provider Education: Oversight of Efforts to Reduce Improper Billing NeedsImprovement,” by the U.S. Government Accountability Officehttp://www.gao.gov/assets/690/683312.pdf

“Health Care: Telehealth and Remote Patient Monitoring Use in Medicare and Selected FederalPrograms,” by the U.S. Government Accountability Officehttp://www.gao.gov/products/GAO-17-365

For more information, contact Andrew Koski at (518) 810-0662 or akoski@hcanys.org.