Wednesday, March 5, 2014

Nursing Facility Satisfaction Survey Informational Webinars Offered in March

The Indiana Family and Social Services Administration (FSSA), through its Division of Aging (DA) and Office of Medicaid Policy and Planning (OMPP), cordially invites you to participate in an informational webinar regarding the Nursing Facility Satisfaction Surveys to be conducted in July, August, and September 2014. Press Ganey, the vendor performing the resident, family member and friend, and employee satisfaction surveys will host the webinars.

The one-hour webinars are scheduled for the following dates and times:
  • Tuesday, March 18, 2014, at 2 p.m. Eastern Time
  • Monday, March 24, 2014, at 10 a.m. Eastern Time
  • Friday, March 28, 2014, at 10 a.m. Eastern Time
You may participate in any or all sessions. During the webinar, you will receive information about the upcoming survey process and how your residents, their family and friends, and your employees will be surveyed. Please contact Cher Dial at cdial@pressganey.com to request a webinar meeting invitation.

OIG Issues Report Concerning Adverse Events in Skilled Nursing Facilities

The HHS Office of Inspector General (OIG) recently released a report estimating 22 percent of Medicare beneficiaries experienced adverse events during a stay at a Skilled Nursing Facility (SNF).  The physicians involved in the OIG study indicated that 59 percent of these adverse events were likely preventable, and were related to substandard treatment, poor monitoring, or delay of care.  The OIG is recommending increased awareness be raised by regulators concerning SNF safety and to promote a list of events to help staff better recognize harm.  In addition, the OIG is recommending that survey agencies review nursing home practices to identify and reduce adverse events.  Additional analysis of the OIG report will be forthcoming, and to read the report visit http://oig.hhs.gov/oei/reports/oei-06-11-00370.pdf

CMS Places Moratoria on Home Health Agency Enrollment

On February 4, 2014, CMS announced new moratoria pm Home Health Agency (HHA) enrollment in Ft. Lauderdale, FL, Detroit, MI, Dallas, TX, and Houston, TX.  CMS also extended the existing moratoria in Miami, FL and Chicago, IL.  The moratoria are in place for 6 months, though CMS may lift or extend the moratoria.  Prospective HHA applications that were not approved prior to January 30, 2014 will be denied by the Medicare Administrative Contractor.  For more information, see https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-14-10.pdf.

CMS Announces Pause in Recovery Audit Contractor (RAC) Audits

On February 18, 2014, CMS announced on its website that it is “pausing” RA audits in preparation for the procurement of new RA contracts and to “allow CMS to continue to refine and improve the Medicare RA Program.”  To obtain a complete copy of the announcement go to http://www.cms.gov/Research-Statistics-Data-and-Systems/Monitoring-Programs/Medicare-FFS-Compliance-Programs/Recovery-Audit-Program/Recent_Updates.html.

Specifically, CMS states in the announcement that it is in the procurement process for the next round of RA Program contracts.  According to CMS, it is important that the agency transition down the current contracts so that the RAs can complete all outstanding claim reviews and other processes by the end date of the current contracts.  In addition, a pause in operations will allow CMS to continue to refine and improve the RA Program.   Several years ago, CMS states that it made substantial changes to improve the RA program, and it will continue to review and refine the process as necessary. Providers should note the important dates below:

• February 21 is the last day an RA may send a postpayment Additional Documentation Request (ADR)
• February 28 is the last day a MAC may send prepayment ADRs for the RA Prepayment Review Demonstration
• June 1 is the last day a RA may send improper payment files to the MACs for adjustment

Any questions from providers should be directed to RAC@cms.hhs.gov.

CMS Updates Health Care Facility Emergency Preparedness Checklist

CMS issued Survey & Certification Memorandum 14-12 along with an updated Emergency Preparedness Checklist (click here for a copy of the memo and updated checklist).  The checklist is a recommended tool by CMS for health facility emergency planning.  The updates include changes to development of evacuation plans, review of emergency plans, and the addition of sections concerning adoption of emergency planning templates and collaboration with local emergency management agencies and healthcare coalitions.  Once the S&C letter is released by CMS with more details, it can be located at https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Policy-and-Memos-to-States-and-Regions.html.

President Obama Releases His FY2015 Proposed Budget

President Obama released his FY2015 budget proposal on March 4, 2014. As it regards the long term care profession, this budget looks similar in many ways to past years. The President did not propose any cuts to the provider tax, as had been proposed in some previous years. This year’s budget does propose significant cuts to Medicare, including reducing the market basket, cutting bad debt reimbursement and more. AHCA/NCAL will continue to oppose these deep cuts and does not expect them to become law. 

Below is a short summary of the budget provisions in the President's FY2015 budget that have direct impact on our profession.

• Post-acute care market basket cuts
     o The budget reduces the home health, IRF and LTCH market basket update by 1.1% each year 2015 through 2024, with the floor set at a rate freeze. The budget reduces market basket updates for SNFs, but accelerates SNF cuts beginning with a -2.5% update in FY2015 and a reduction to -0.97 % in FY2022. This is projected to save $97.9 billion from 2015-2024.

• Reduce Medicare coverage of bad debts
     o The President proposes reducing bad debt payments from 65 percent generally to 25 percent for all eligible providers over three years beginning in 2015. This proposal will save approximately $30.8 billion over 10 years.

• Hospital Readmissions
     o The budget connects SNF payments to reduced hospitalizations. Beginning in 2018, payments to SNFs with high preventable readmission rates would be cut by up to 3 percent. This is projected to save $1.9 billion in the next 10 years.

• Therapy multiple procedure payment reduction and therapy caps
     o The President's budget notes the already-enacted reduction to Medicare payments to physicians when multiple therapies are provided to the same patient on the same day. The budget notes that reduction is estimated to save $2.4 billion over 10 years.
     o The budget also notes the already-enacted extension for the exceptions process for outpatient     therapy caps.
     o While both items are noted, nothing new is proposed for either area.

 Equalize payment for certain conditions commonly treated in IRFs and SNFS
     o The budget's proposals include adjusting payment updates for certain post-acute care providers and equalizing payments for certain conditions commonly treated in IRFs and SNFs, which is estimated to save $1.6 billion over 10 years.
     o Specifically, the President's budget proposes to reduce payment disparities in the IRF and SNF settings for three conditions beginning in 2015:  hips and knees, pulmonary conditions, and other conditions as determined by the Secretary.

• Implement bundled post-acute care payment
     o Beginning in 2019, at least half of the payments for LTCHs, IRFs, SNFs and home health services would be bundled. Payments would be bundled for at least half of the total payments for post-acute care providers. A permanent and total cumulative 2.85 percent cut would be applied by 2021. This is projected to save $8.7 billion from 2015-2024.

• Value-based Purchasing
     o While it is budget neutral, it is important to note that the President’s Budget implements a value-based purchasing program for several additional provider types, including home health, SNFs, ambulatory surgical centers and hospital outpatient departments beginning in 2016. At least two percent of payments must be tied to the quality and efficiency of care.

• Strengthen the Independent Payment Advisory Board
     o The budget requires IPAB cuts to take effect when Medicare spending growth exceeds Gross Domestic Product (GDP) +.5%. Current law is GDP +1%. This is estimated to save $12.9 billion over 10 years.

• Medicaid
     o As was the case last year, there are no proposals to reduce or eliminate the provider assessment authority in the President's budget.

AHCA/NCAL will conduct a more detailed review and analysis of the President's budget proposal.