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The Benchmark Email
...benchmarks, strategies and ideas for improving
your agency
A service of Fazzi Associates, Inc.
August 23, 2007
Summary of Final Refinements Compared to Current HH PPS Payment
System
Question: The new CMS PPS regulations have just
been released. They are significant and from what we can see, they have
major implications to agencies. Will Fazzi Associates have any special
trainings for its clients and subscribers?
Answer:
You are right! They are
significant. (See the CMS Chart below.) They have implications for every
agency in the country. They go into effect on January 1, 2008. And, you
can’t wait…you must act now.
Fazzi Associates has
been working with some of the nation’s most respected vendors and a team
of national experts to analyze the impact of the proposed and now final
regulations and to determine the best strategies and practices for
responding. In an effort to help our clients and subscribers, we will be
partnering with the nation’s leading real time data analysis, benchmarking
and performance improvement firm and a national financial expert to
present the single best and most comprehensive training on what to do. Our
focus will be on three things: to help you understand what the final rules
are, to help you determine specifically what they mean to your agency and,
most importantly, to provide you with evidence based recommendations,
strategies and best practice ideas for the changes you'll need to make to
thrive in this new environment.
The training is free.
It is our way of thanking and supporting a field that we care deeply about
and for which we have been part of for nearly thirty years. You will be
receiving updates on a regular basis leading up to the training.
Information will be also be available at fazzi.com.
Summary of Final Refinements Compared to Current HH PPS
Payment System (Glossary of Acronyms can be
found at bottom of page)
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Current HH PPS |
Final Rule with Comments |
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Home health
disciplines included in the National 60-Day Episode
rate:
- Skilled
nursing, home health aide, physical therapy, speech-language
pathology, occupational therapy, and medical social
services
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Home health
disciplines included in the National 60-Day Episode rate:
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For eligible
beneficiaries under a home health plan of care:
- National
60-day episode prospective payment for covered home health
services, adjusted for case mix and wage index. LUPA, SCIC, PEP,
and outlier adjustments allowed
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For eligible
beneficiaries under a home health plan of care:
- Unchanged.
LUPA, PEP, and outlier adjustments allowed; SCIC adjustment
eliminated
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Average
case-mix weights per episode:
- Since the
inception of the HH PPS, the increase in the average case mix,
nominal case-mix growth (which is the change that is not
due to changes in the underlying health status of Medicare home
health patient) is 11.75 percent.
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Average
case-mix weights per episode:
- To account
for the 11.75 percent increase in the nominal case-mix growth, we
are finalizing the proposed 2.75 percent reduction of the national
standardized 60-day episode payment rate for first 3 years
beginning in 2008 and a 2.71 percent reduction in the fourth year,
2011.
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National 60 Day Episode
rate($2,339.00 for CY
2007)
- Includes home
health market basket increase (3.3% for CY
2007)·
- Adjusted for
case-mix and wage-index
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National 60
Day Episode rate ($2,270.32for CY 2008)
- Includes home
health market basket increase (3.0% for CY
2008)·
- Adjusted for
case-mix and wage-index, and further adjusted for aggregate
changes in case mix for the nominal case-mix growth (2.75 percent
reduction per year for the first 3 years, 2008, 2009, and 2010,
and 2.71 percent reduction for 2011.
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Home health
market basket:
- Labor portion
= 76.775%
- Non-labor
portion = 23.225%
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Home health
market basket:
- Labor portion
= 77.082%
- Non-labor
portion = 22.918%
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Case-mix
regression model:
- Single
therapy threshold at 10 visits
- Did not
account for the timing of episodes;
- Single
equation model for weight calculation, with a single set of case
mix scores and single therapy threshold
- Model
r-squared = 0.29, initial episodes, .21 total episodes
- 160; Large
increase in payment for delivering at least 10 therapy visits in a
60-day episode
- 80 case-mix
groups
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Case-mix
regression model:
- Therapy
thresholds at 6, 14, and 20 visits Accounts for early episodes
(the first or second episode in a sequence of adjacent episodes)
and later episodes (third or subsequent episodes in a sequence of
adjacent episodes), regardless of whether the same home health
agency provided care for the entire series of episodes.
- Four-equation
model for weight calculation with scores allowed to vary by
episode type and with classification of episodes as
follows:
1) < 14
therapy visits occurring in early episode;
2) ≥ 14
therapy visits occurring in early episode;
3) < 14
therapy visits occurring in later episode;
4) ≥ 14
therapy visits occurring in later episode.
- Model
r-squared = 0.45
- Gradual
increase in payment between first and third therapy
thresholds
- 153 case-mix
groups
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Case-mix
model variables:
- M0110 did
not exist
- Included
M0175 (inpatient facility discharge), M0530 (incontinence) &
M0610 (behaviors observed)
- Excluded
M0800 (injectible medications)
- Included
M0230/240
- Included
M0245
- M0825:
included (exists as a “yes”/”no” question as to whether or not the
projected number of therapy visits for the episode meet the
threshold for a Medicare high-therapy case mix group)
- Scores not
given for infected surgical wounds, abscesses, chronic ulcers,
gangrene, dysphagia, tracheostomy, cystostomy
- Did not
include gastrointestinal, pulmonary, cardiac, hypertension,
cancer, blood disorders, or affective and other psychoses
diagnosis groups
- Points not
given for secondary diagnoses
- Points not
given for combinations of conditions in the same episode
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Case-mix
model variables:
- Creates
M0110 for new item to identify early and later episodes
- Excludes M0175, M0530 M0440& M0610
- Adds
M0800
- Modifies
format of M0230/240 to accommodate changes to payment
diagnoses
- M0246
replaces M0245 and now allows for multiple coding for both primary
and secondary diagnoses
- Includes
M0826 and replaces M0825 (identifies the number of projected
therapy visits for the episode, which affects the particular
case-mix group for which that episode will be grouped)
- Includes
scores for infected surgical wounds, abscesses, chronic ulcers,
gangrene, dysphagia, tracheostomy, and cystostomy.
- Adds
gastrointestinal, pulmonary, cardiac, hypertension, cancer, blood
disorders, and affective and other psychoses diagnosis
groups· Assigns
points for some secondary diagnoses
- Assigns
points for some combinations of conditions in the same
episode
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Wage
Index:
- Routine
update based on most recently available pre-floor/pre-reclassified
hospital wage index
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Wage Index:
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Non-routine
supplies (NRS):
- Included in
national episode rate as a fixed amount of $49.62, updated
annually as part of the national episode rate
- Case-mix
adjusted as part of the national 60-day episode rate
- Updated
annually, as part of the national episode rate, by the home health
market basket factor
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Non-routine
supplies (NRS):
- Based on a
NRS conversion factor of $52.35. (The original $49.62 from the
July 3, 2000 final rule, updated to 2008, adjusted to account for
the outlier target of 5%, and adjusted for the nominal change in
case-mix)
- Case-mix
adjusted separately based on 6 NRS severity groups payments ranges
from $14.12 to $551 per episode
- Unchanged
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LUPA Adjustment:
- Calculated if
episode has 4 or fewer visits
- No additional
payment for LUPA episodes that occur as the first or only episode
during a period of home health benefit use
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LUPA Adjustment:
- Unchanged
- Additional
$87.93 for LUPA episodes that occur as the only episode or the
first episode of a sequence of adjacent episodes; to be updated
annually by the home health market basket
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PEP adjustment calculation:
- Allowed for
partial episodes
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PEP adjustment calculation:
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Outlier adjustment:
- Fixed dollar
loss ratio = 0.67
- Loss-sharing
ratio = 0.80
- Outlier
expenditure target = 5 percent of total home health PPS
payments
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Outlier adjustment:
- Fixed dollar
loss ratio = 0.89
- Unchanged
- Unchanged
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Quality Data Reporting:
- Report data
on 10 quality measures
- HHAs that do
not submit quality data subject to 2 percent reduction in home
health market basket percentage increase for the next year
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Quality Data Reporting:
- Report data
on 12 quality measures
- Unchanged
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Average case-mix under the current case-mix system, based
on 20% sample of 2005 data:
- Proprietary
agencies: 1.2821
- Voluntary
non-profit agencies: 1.1875
- Rural
agencies: 1.2047
- Urban
agencies: 1.2520
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Average case-mix under the revised case-mix system, based
on a 20% sample of 2005 data:
- Proprietary
agencies: 1.2620
- Voluntary
non-profit agencies: 1.2334
- Rural
agencies: 1.1798
- Urban
agencies: 1.2616
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Glossary
of Acronyms
LUPA = Low itilization payment adjustment
SCIC = Significant changes in condition
PEP = Partial episode payment
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