Hom e H Healt h Service ces and Fa Face-t o-Face Encount er - PowerPoint PPT Presentation

Hom e H Healt h Service ces and Fa Face-t o-Face Encount er Requirem ent s Guest Presenters – Alexandra Koloskus, JD Matt Colussi June 2017

Our r Mission I mproving health care access and outcomes for the people we serve while demonstrating sound stewardship of financial resources 2 2

Hom e e Hea ealt h S Ser ervices O es Over erview ew • Home Health services consist of skilled nursing, certified nurse aide (CNA) services, physical therapy, occupational therapy, and speech/language pathology services that are provided by a licensed and certified Home Health agency. • Home Health services are available to Colorado Medicaid clients who need intermittent skilled care in their place of residence or in the community. • Home Health services are divided into two service types:  Acute Home Health services are provided for the treatment of acute conditions/episodes (such as post- surgical care) for up to 60 days without prior authorization.  Long-Term Home Health is available for clients who require ongoing Home Health Services beyond the 60 day Acute Home Health period. Long-Term Home Health services require prior authorization. 3

Hom e e Hea ealt h S Ser ervices O es Over erview ew • Clients ages 20 and younger:  Are assessed for Long-Term Home Health services using the Pediatric Assessment Tool (PAT) and the client’s plan of care.  Through EPDST, may receive PT, OT and SLP in Acute and Long-Term Home Health periods. • Clients ages 21 and older:  For clients 21 years of age or older, PT, OT and SLP shall only be provided in the Acute Home Health episode. 4

Ut Ut iliza zat ion n and nd Expend ndit ur ure Trend nds Utilization & Expenditure Trends – Fiscal Years 2011 - 2015 Statistics FY 12-13 FY 13-14 FY 14-15 FY 15-16 Total Medicaid Clients 808,100 1,109,853 1,338,330 1,440,312 Total Expenditures $177,039,478 $207,317,907.20 $244,525,640.10 $276,181,802.47 Total Number of Clients Utilizing Benefit 13,190 15,845 18,962 20,813 Number of Providers 150 152 153 167 Acute Home Health Expenditures $18,779,047 $23,081,327.63 $30,893,384.77 $32,703,502.53 Long-Term Home Health Expenditures $158,181,727 $184,155,594.04 $213,543,191.91 $243,382,023.80 LTHH CNA Expenditures $115,023,319 $129,285,429.17 $147,780,736.30 $169,269,623.21 LTHH All Other Expenditures $43,158,408 $54,870,164.87 $65,762,455.61 $74,112,400.59 Number of Pediatric Clients Served (Ages 0-20) 4,290 5,510 6,449 7,402 Pediatric Expenditures $87,740,366 $90,235,982.04 $125,680,438.74 $149,695,107.39 Telehealth Expenditures $10,314.67 $20,122.70 $22,579.50 $9,044.54 5

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Fa Face-t o-Face Encount er Requirem ent s for Prescribing of H Hom e Healt h S Service ces CM CMS F Final R Rule: CM CMS 2 2348-F Guest Presenters – Alexandra Koloskus, JD Matt Colussi 7

Background • February 2, 2016 – CMS published a final rule revising the Medicaid Home Health service definition consistent with section 6407 of the Affordable Care Act to add two basic requirements: 1. For Home Health services, physicians or certain federally authorized non- physician practitioners (NPPs) document the occurrence of a face-to-face encounter with the Medicaid-eligible beneficiary within specific time frames. 2. Home Health services may not be limited to services furnished in the home and can now be provided in the community. • Colorado has a compliance date of July 1, 2017 8

1. Fa Face t o Fa Face ( F2 F2F) F) Encount er: For the initial ordering of Home Health services: I. The Ordering Physician must document the occurrence of a face-to-face encounter II. The encounter must be related to the primary reason the client requires Home Health services III. The encounter must occur no more than 90 days before or 30 days after the start of Home Health services 9

A. W ho Does es This s Apply To? • A face-to-face encounter is required for initial orders for Home Health services and for all episodes initiated with the completion of a start-of-care OASIS assessment on or after July 1, 2017. • A face-to-face encounter is NOT required for re-certifications of Home Health services. • Existing clients already receiving Home Health services will NOT require a new face-to-face visit (they will be ‘ grandfathered’ in). • Dual-Eligibile clients: If the source of payment for the client’ s care has changed from Medicare to Medicaid, and a face-to-face encounter was performed at the start of Home Health services, a new face-to-face encounter is NOT required. • In this circumstance, the Medicare F2F documentation will meet the Medicaid F2F requirement 10

B. W ho ho Can n Cond nduc uct a F2F Enc ncount unt er? Federally authorized practitioners include: a. The ordering physician. In order to be an ordering physician, the physician must be enrolled with Health First Colorado. b. The physician who cared for the patient in an acute or post-acute care facility (from which the patient was directly admitted to home health). c. The Non-Physician Practitioner (NPP): (1) A nurse practitioner (NP) or clinical nurse specialist (CNS) who is working in collaboration with the ordering physician or the acute/post-acute care physician; (2) A certified nurse midwife; (3) A physician assistant (PA) under supervision of the ordering physician. 11

C. F2F Docum en ent at ion Req equirem em en ent s The face-to-face encounter must be documented on the ordering physician’s plan-of-care and must include: a. The primary reason the patient requires Home Health services, b. The date of the face-to-face encounter and c. The identity of the practitioner (physician or NPP) who conducted the face-to-face encounter. 12

D. F2F Docum um ent nt at ion n Gui uideline nes  Clients discharged from a hospital to Home Health services are not required to receive a separate face-to-face encounter, as long as a physician or allowed NPP performs the face-to- face encounter in the hospital and communicates the clinical findings of the face-to-face encounter to the ordering physician in the community.  Clinical findings can be communicated in the form of clinical and progress notes and discharge summaries.  “There is no federal prohibition on a NPP documenting the face-to-face encounter and having the physician sign the documentation.” 13

Quest est ions? s? 14

2. Hom e Healt h h in n t he he Com m uni unit y Final Federal Rule Clarifies: I. Medicaid Home Health services cannot be restricted to homebound individuals II. Medicaid Home Health services can be provided outside of the home and in the community when the client is participating in normal life activities I. Other than in a hospital, NF, ICF-ID or any setting in which payment could be made under Medicaid for inpatient services that include room and board.  Utilization Review mechanisms still apply (LTC evaluations and Pediatric Assessment Tool) 15

Hom e Healt h h in n t he he Com m uni unit y Cont nt . • Non-Emergency Medical Transportation (NEMT) is available for transportation to and from medical appointments. • More information available in hyperlink and by emailing NEMT@ state.co.us • The face-to-face visit with a Federally authorized provider is reimbursable using procedure codes. Health First Colorado anticipates that the visits will be reimbursable office visits. 16

Quest est ions? s? 17

Depart m ent Updat es and I nfo • Home Health Rule 10 CCR 8.520 – Regulatory Efficiency Rule Review Process complete • Rule going to Medical Services Board in June to update face-to-face requirements, including HHIC, and to move BCS content into rule. Electronic Visit Verification (EVV) per 21 st Century Cures Act: • • Home Health by 2023, Personal Care by 2019 18

Depart m ent Updat es and I nfo Rate increases effective July 1, 2017- HH and PDN rates increased by 1/3 rd of the • gap between current rates and LUPA (Low Utilization Payment Adjustment). s- HH and PDN rates increased by 1/ 3 rd of the gap between current rates and LUP A 19

Quest est ions? s? Alexandra.Koloskus@state.co.us 20