CMS Finalizes FY 2015 SNF Medicare Payment Rule

 CMS issued the final rule for FY 2015 Medicare payments.  As published previously the aggregate increase is 2%, which is the result of the 2.5% market basket increase and the .5% reduction from the multifactor productivity adjustment.  AHCA has assembled a thorough overview of the final rule which you can access by clicking here.  The final wage index will be posted to the following website: http://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/SNFPPS/WageIndex.html.  The final rule may be accessed at: http://www.ofr.gov/inspection.aspx.  To read the CMS release on the payment rule, click here.

Indiana Medicaid Rate Update – Reprocessing of Claims Has Begun for 1/1/14 and Forward

Regular updating of Indiana Medicaid NF rates had been held up for all of 2014 due to the pending State Plan Amendment (SPA) that proposed to increase NF rates by 2% effective 1/1/14 (i.e. to decrease the existing 5% cut to 3%).  CMS finally approved the rate increase SPA in late July that has set in motion a number of rate reprocessing activities.  Concurrent with the rate cut SPA being approved, CMS also approved an amended waiver for the Quality Assessment Fee that increases the fee.  This increase was required as it was found that the old fee structure failed the meet the Federal regulatory “B1/B2 test” that is a test to demonstrate Indiana’s QAF as “generally redistributive” when such a tax or fee is neither uniform nor broad based (Indiana’s tax is not uniform or broad based due to certain exemptions from the fee and due to a two-tiered fee structure).  See July’s IHCA Insights article for more detail on the QAF Waiver and the new rates by clicking here.

Indiana Medicaid through its contractor HP has already begun reprocessing rates for the 1/1/14 Rate Effective Date.  Indiana Medicaid released a timeline and reprocessing schedule on the website of Myers & Stauffer.  Click here for the rate plan release and click here for the nursing facility listing indicating what batch a particular nursing facility’s rate will be released.  Note that the release plan includes ICF/IIDs as those facility’s rates were also impacted by this SPA.

If you have any questions, please contact Zach Cattell at 317-616-9001 or zcattell@ihca.org.

ICD-10 Deadline Reset for October 1, 2015

The US Department of Health and Human Services (HHS), has just issued a final rule that finalizes Oct. 1, 2015, as the new compliance date for health care providers, health plans and health care clearinghouses to transition from ICD-9 to ICD-10.  According to Center for Medicare & Medicaid Services (CMS) Administrator, Marilyn Tavenner, the new “ICD-10 codes will provide better support for patient care, and improve disease management, quality measurement and analytics.”  HHS also points out that implementation of ICD-10 codes will better detect and prevent fraud waste and abuse and lead to greater accuracy of reimbursement for medical services.  AHCA will provide a more in-depth analysis of the final rule; but wanted to get this information out tonight.  To obtain a copy of the press release go to http://cms.hhs.gov/Newsroom/MediaReleaseDatabase/Press-releases/2014-Press-releases-items/2014-07-31.html.  To obtain a copy of the final rule go to https://s3.amazonaws.com/public-inspection.federalregister.gov/2014-18347.pdf (Note, this final rule has not been published in the Federal Register yet; but is expected to be printed on Monday, August 4, 2014).  To obtain additional information about ICD-10 go to http://www.cms.gov/ICD10.

CMS also released revised MLN Matters articles to follow the reset deadline of October 1, 2015. Those articles are as follows:

MM8350 – Diagnosis Code Reporting on Religious Nonmedical Health Care Institution Claims
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8350.pdf

MM8494 – Changes to the Laboratory National Coverage Determination (NCD) Software for ICD-10 Codes
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/MM8494.pdf

SE1240 – Partial Code Freeze Prior to ICD-10 Implementation
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1240.pdf

SE1408 – Medicare Fee-For-Service (FFS) Claims Processing Guidance for Implementing International Classification of Diseases, 10th Edition (ICD-10) – A Re-Issue of MM7492
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1408.pdf

SE1410 – Special Instructions for the International Classification of Diseases, Clinical Modification 10th Edition (ICD-10-CM) Coding on Home Health Episodes that Span October 1, 2015
http://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/Downloads/SE1410.pdf

Interact for Assisted Living

NCAL is excited to share that INTERACT for Assisted Living, a quality improvement program to reduce hospital readmissions, has been released! Interventions to Reduce Acute Care Transfers (INTERACT) was originally designed to improve the early identification, management, documentation and communication about acute changes in condition of skilled nursing center residents. The program has now expanded to include tools specifically targeted toward assisted living providers.  You can find all the new tools at the INTERACT website and via a link to the INTERACT website on the NCAL Quality Initiative website under “Resources” for the hospital readmission goal.  

NCAL is working closely with the INTERACT team on an official announcement but wanted to inform members of this exciting news now.  

Serving Alcohol to Residents – IHCA Guidance Released

Several members contacted the IHCA last month after a news story appeared in the paper and on TV concerning the State Excise police warning a skilled nursing facility for serving alcohol to its residents during a social hour.  IHCA has developed helpful guidance for your company to review.  If you have any questions, please contact me at zcattell@ihca.org or 317-616-9001.

QIO Program Changes

•    KEPRO – Beneficiary Complaints and Quality of Care reviews
The Centers for Medicare & Medicaid Services (CMS) has made dramatic changes to the Beneficiary and Family Centered Care (BFCC) Quality Improvement Organization (QIO) program.  Beginning August 1, 2014, the BFCC-QIO program will be managed by one of two organizations nationally.  The organization assuming the QIO work for Indiana will be KEPRO.  Health Care Excel will no longer be conducting QIO activities after July 31, 2014.  KEPRO will manage all beneficiary complaints and quality of care reviews to ensure consistency in the review process while taking into consideration local factors important to beneficiaries and their families.   Click here an information sheet about the changes to the QIO program and contact information for KEPRO. 

This change will impact your Notice of Medicare Noncoverage forms.  You will need to change the name and toll-free # for the QIO on those forms, but do NOT distribute the new number to patients prior to August 1, 2014.  Click here for information on KEPRO.  Your facility will receive additional information from KEPRO.

•    QSource – Quality Improvement Initiatives
IHCA is under the impression that QSource of Tennessee has been awarded the Quality Innovation Network (QIN) QIO for Indiana, replacing Health Care Excel.   QSource will be responsible for working with providers and the community on multiple, data-driven quality initiatives to improve patient safety, reduce harm, and improve clinical care at their local and regional levels.  A formal announcement is expected in the near future.

Residential Care Citation Update

In June 2014 the ISDH issued 40 Deficiency tags and 7 Offense tags to Residential Care Facilities.  Tag 273 concerning maintenance of food preparation and service areas in accordance with state and local sanitation standards was cited 7 times, and Tag 241 concerning the administration of medications by licensed nurses or QMAs was cited 5 times.  These continue to be the most cited tags in 2014 with Tag 273 issued 31 times and Tag 241 issued 21 times.

•    Citation Trends
It appears also that the ISDH surveyors are paying more close attention to hand washing when they survey residential care facilities.  Tag 414 was issued 3 times in June for failure of staff to wash hands after each direct resident contact.  The tag was also cited twice in March and April, and once in May, for a total of 8 citations in 2014.  The tag was only issued 6 times in all of 2013.  In addition, Tag 301 concerning the proper labeling of prescription drugs has been cited 3 times in June, once in March and once in May, for a total of 5 citations in 2014.  The tag was cited 6 times in all of 2013.  Tag 301 requires prescription drugs to be labeled with the resident’s full name, physician’s name, prescription number, name and strength of drug, directions for use, date of issue and expiration (when applicable), and the name and address of the pharmacy that filled the prescription.  Reasonable variations to these requirements can apply to units does packaging.  Lastly, Tag 154 has been cited 4 times in June, 3 times in May and 1 time in each of April and March, for failure to keep kitchen and dining areas clean and in good repair.  Though Tag 154 has been frequently cited in the past, including 20 times in 2013, it had not been cited in 2014 with much frequency until the last 2 months.

To review the June citations click here.

ISDH IJ/SSQC Update

The ISDH issued 4 citations at the IJ and SSQC levels in June related to two incidents.  The first incident involved a CNA having been found on the floor next to a resident’s bed after having fallen out of the bed, according to the resident.  It appeared upon investigation that the CNA had been lying in the resident’s bed.  Staff had observed this behavior of the CNA, but it was not immediately reported to the Administrator.  The resident alleged sexual abuse by the CNA.  F224, F225, and F226 were issued in this incident.  The second incident involved an elopement of a resident on a non-secured unit that was displaying exit seeking behaviors.  The facility had not yet implemented the physician order for a Wanderguard prior to the elopement.  The resident was a 5 of 5 on the BIMS and after the elopement was moved to the facility’s secured unit and a Wanderguard was put in place.

For a summary of the 2014 IJs/SSQCs and for the June 2567s, click here.