CMS Announces Proposed Payment Changes for Medicare Home Health Agencies for 2016

This week, the Centers for Medicare and Medicaid Services (CMS) announced proposed changes to the Medicare home health prospective payment system for calendar year 2016 that will foster greater efficiency, flexibility and payment accuracy, and improve quality. Simione Healthcare Consultants is reviewing these changes, which reflect a broader strategy to create a health care system that supports higher quality, smarter spending and improved patient outcomes. Key areas of emphasis include: payment policy provisions, quality reporting and value-based purchasing.  Simione will publish a summary on the proposed rule at a later date.  

The Art of Ethics in Compliance and Clinical Activities

Home care and hospice organizations working to maximize their quality of care and financial performance are placing increasing emphasis on the development of ethics standards in their comprehensive compliance programs.  The role of ethics in compliance is paramount with the goals of sharing information and protecting organizations when individual and organizational values are challenged by patient/family concerns or quandaries about business practice.   

"We are operating in a high-risk environment where differences in values, opinions and preferences are pushing the limits for patients, families and providers," says Kathleen Hessler, RN, JD, Director of Compliance and Risk at Simione Healthcare Consultants. 

"How can you safely operate in an industry where what is legal, may be unethical, or what is ethical may be illegal? We recommend a clear process for 'doing the right thing', not simply because it is considered desirable, but because attention to values in a health care organization has significant implications for quality of care and reimbursement," Hessler explains.  

"A Medicare credit balance is an amount determined to be refundable to the Medicare program for an improper or excess payment made to a provider because of patient billing or claims processing errors."

Medicare requires agencies to submit this report regardless of whether or not there is a balance to be refunded. Simione Healthcare Consultants has submitted these on behalf of clients for a number of years, and has yet to report a credit balance due.  However, it is a necessary requirement that Medicare takes very seriously.  If you fail to submit a Credit Balance (CMS-838) form and/or certification page with all provider numbers identified, Medicare payments will be suspended as stated in 42 CFR 413.20(e) and 405.370.