CMS states that the Health Information Exchange (HIE) initiatives are designed to encourage HIE among all health care providers, including … those who are not eligible for the EHR Incentive programs (this includes Home Health). This is in general a very good idea and...
CMS is also proposing to do this demonstration in 5 to 8 states and that ALL Certified HHAs in those 5 to 8 selected states MUST participate! The only way to opt out is to de-certify and/or close your doors! How comfortable are you with that? Comments: This...
CMS has proposed to implement a HHA Value-Based Purchasing Model beginning in 2016. But before you skip this as it doesn't apply to 2015, think again! Our opportunity to impact the implementation of this proposal is here and now! Ignore this and it will happen; to...
CMS has noted what their calculated rates are going to be for Year 2 of Rebasing as per the Proposed Rule for 2015 HH PPS. We have issue with the calculated costs for an episode for a number of reasons; applicable to the amounts as calculated per your original...
CMS has included several changes to the Face-to-Face Provision in the Proposed Rule for 2015 HH PPS. One that is definitely needed, one that could impact the referral source (albeit minimally, when compared to the impact to HH), and one that has the potential to be...
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...
CMS has proposed changes to the Case-Mix Weights for 2015. This would mean we would be operating with Case-Mix Weights that were different for the last three years! We as an industry cannot feel comfortable with the changes in the points scoring mechanism without...
Comments in regards to the Rural Add-on provision as noted in the Proposed Rule for 2015 HH PPS: Why should the Rural Add-on end on 12/31/15? If there is a viable need for it now, what is changing that makes it not necessary come 2016? I know there is...
CMS did not propose any changes to the Outlier Provision for 2015. I believe that this is the first time in several years that no changes have been proposed by CMS to this provision. However, that does not impact my following comment in regards to the Outlier...
Following are a couple of comments for CMS in regards to the changes they proposed for the LUPA Rate calculations for 2015: Why would the LUPA Wage-Index Budget Neutrality Factor for 2015 be 1.0000 when the 60-day Rate Wage-Index Budget Neutrality Factor was 1.0012? ...