Preparing for PDGM: A Must-Do Checklist to Evaluate Your Agency’s Readiness
Overview PDGM Framework General Checklist Revenue Cycle August 2018 2
PDGM Framework
PDGM Details Medicare History IPS: 1998 - 2000 Reduced per-visit payment rates Established beneficiary cost limit for home health agencies PPS: 2000 – 2019 Introduced episodic billing (60-day episodes) Refined in 2008 Reimbursement based on episode timing, clinical/functional OASIS scores, therapy volume, and supply volume PDGM: Beginning 2020 Reduces billing period to 30 days Aligns reimbursement with resource use 4
What is PDGM? Summary of Changes Implementation date proposed to be for periods of care beginning on or after January 1, 2020 Budget neutral – huge win compared to the estimated $950M reduction in payment of HHGM Replaces 60-day payment episodes with 30-day periods OASIS still only required every 60 days Return of sudden change in condition (SCIC) adjustments 5
What is PDGM? Summary of Changes (Cont’d) Eliminates the use of the number of therapy visits in payment determination Increase total number of case-mix weights from 153 to 432 Modification to visit thresholds for low utilization payment adjustments (LUPAs) Model based on claims and cost report data Estimated 959,410 (14.2%) claims excluded due to non- linked OASIS 7,458 cost reports 6
What is PDGM? Patient-Driven Groupings Model 7
General Checklist
Preparing for PDGM General Checklist Educate staff in all departments Determine agency’s estimated revenue impact Understand which PDGM components will have the largest impact on your agency (positive and negative) Prepare/budget for cash flow delays during PDGM transition Contact your Senators and Representatives to support legislation to eliminate the behavioral adjustment (8.01%) 9
Operational Impact General Checklist Create an internal PDGM steering committee Develop reporting on key indicators driving reimbursement under PDGM Evaluate current processes and workflows Are these sustainable under PDGM? Perform a coding/OASIS audit Identify potential impact of QE, comorbidities, etc. Establish strong interdepartmental communication 10
Preparing for PDGM Leveraging Technology Contact your EMR and ask what they are doing to prepare What new functionality/reporting will be made available? When will these new features be released for testing? Will your current workflows still be viable after EMR updates made? Documentation Management/Orders Tracking Facilitate compilation, storage, and review of referral documents Streamline start of care workflow Allow for documentation to be analyzed based on specific categories (i.e. referral source) Maximize use of e-fax or electronic communication 11
Preparing for PDGM Leveraging Industry Resources HCA NY, NAHC, and other advocacy groups Several seminars, webinars, and workshops available There are expert organizations that can assist providers with preparation Consulting groups have purchased Limited Data Set (LDS) from CMS 12
Revenue Cycle
Operational Impact Intake Understand the impact of your primary referral source Analyze current marketing and referral relations strategies Includes education to referral sources Obtain as much information as possible at time of referral Strong communication with Scheduling Department Develop Intake checklist Key Metrics to Monitor Percentage of current referrals that are institutional vs. community Most common clinical groupings referred by each referral source 14
Operational Impact Patient Management Determine appropriate visit frequency at start of care Therapy still plays an important role in the care plan Streamline identification process for HIPPS Allows for more effective LUPA management Ensure timely completion of OASIS/visit documentation 15
Operational Impact Patient Management Establish processes to continuously assess patient during care ROC assessment/SCIC will change HIPPS under PDGM Key Metrics to Monitor Turnaround time for OASIS completion/submission to CMS Estimated LUPA percentage under PDGM Average length of stay 16
Operational Impact Coding Accurate and complete coding is essential Will determine Clinical Grouping and Comorbidity Adjustment Develop strong education back to clinicians on issues identified in coding/OASIS audit Include all pertinent diagnoses – up to 25 on claim 17
Operational Impact Coding Be cognizant of diagnoses that fall under the Questionable Encounter (QE) classification Estimated 14% of periods would be classified as a QE in current claims data set If significant change in condition occurs, recognize that coding may need to be updated Key Metrics to Monitor What percentage of periods would fall under a QE status? What percentage of periods would qualify for a comorbidity adjustment? 18
Operational Impact Orders Tracking Shorter billing period makes quick turnaround on signed orders even more important Incorporate face-to-face documentation into orders process Plays a role in accurate coding and timeliness of billing Evaluate how quickly agency is getting new orders to physicians Minimize use of hard copy mail submissions Minimize delays in checking signed orders into EMR Educate physicians on new regulations and increased urgency on orders receipt 19
Operational Impact Orders Tracking Establish streamlined process for following up on outstanding orders Follow-up at the physician level Reach out to physicians every seven (7) days until orders are returned signed Utilize phone calls on top of resubmission of orders Develop escalation process if orders not being signed (i.e. courier) Key Metrics to Monitor Average days after start of episode that 485 is sent to physician Volume of verbal orders generated after start of episode Average turnaround time for receipt of signed physician orders 20
Operational Impact Supply Management Ensure all supplies are still added to claims/cost reports These will be factored into rate setting for clinical groupings Remain cognizant of the differences in reimbursement between clinical groupings CMS will allow for remote patient monitoring on cost reports How does this factor into care delivery, case management, and supply utilization? Key Metrics to Monitor Timeliness of supply entry into EMR Delays in billing due to untimely entry of supplies Volume of claims submitted without appropriate supplies included 21
Operational Impact Billing Evaluate if staffing levels/productivity can support increase in claim volume Streamline pre-bill audit process to account for shorter timeframe to resolve issues prior to final claim Monitor claims to identify Medicare processing errors Analyze impact of RAP changes Payment decreased to 20% of expected amount in 2020 22
Operational Impact Billing Develop strong communication of billing issues to other revenue cycle departments Maintain strong non-Medicare collections processes to help support agency during cash flow interruption Key Metrics to Monitor Days to RAP/final claim Frequency of billing Claim volume on outstanding accounts receivable Volume of unbilled claims 23
Operational Impact Finance Adapt accounting model to 30-day period format 24
Questions? Mike Freytag Brian Harris Managing Principal Consulting Director MikeFreytag@BlackTreeHealthcare.com BrianHarris@BlackTreeHealthcare.com (610) 536-6005 ext. 704 (610) 536-6005 ext. 732 Outsourcing Education Consulting
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