CMS has proposed a new guideline that can/will impact reimbursement based on the concept of ‘Pay for Reporting‘.  There are a lot of nuances to this proposal and keep in mind that we are right now in 2014 still dealing with Year 1 of the 4-Years of Rebasing as well as considering all the other changes proposed within this Rule.

In concept, this is a reasonable idea; but then, so was Face-to-Face!  And, I think it can be reasonably extrapolated that the application of this requirement would be fraught with as many issues and problems as the F2F regulation has proven to be.

The biggest issue that HHAs have to deal with, with this timely billing concept, is not something that they can control, because it is not internal to HHAs!  The biggest issue is with getting signed orders from the doctor: and we cannot control that; no matter how hard we try!  Why don’t you set up a requirement that the doctors need to get their outstanding orders to a HHA signed and submitted to the HHA within 30-days of receipt of those orders or they begin to have a reduction to their payments also?  And just reducing and/or eliminating PCO is not going to do it!

Having us in the industry responsible for that which we have total control over is one thing, but there are too many issues arising for which we are becoming financially liable for that we do not have control over and that is very unreasonable and not normal in any other industry (government subsidized or not).  This is the kind of change that should be considered after rebasing, not in the middle of it!  You already recoup the RAP for all claims not submitted within 60 days after the end of an episode, so there is a form of control over timely-billing currently in place and with all the changes that occurring with rebasing and home health in general, this is not a necessary requirement at this time.  Why not go out and review the records at these agencies that are so delinquent in the billing process just to see where the problem is.  This is liken to a physician treating a symptom without adequate review of the patient’s condition and the cause remains, and although the symptom may be somewhat mollified, it will never go away and other more serious symptoms are likely to arise.

If it is going to remain, then:

  •  How does a PEP or a LUPA situation impact this calculation? Are they counted as “non-Quality Assessments”
    • Is this reasonable to the calculation?


  •  What about the exclusion of RFA4 (Recertification/Follow-up) and RFA5 (Other Follow-up)?
    • Is this reasonable to the calculation?