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In This Issue OASIS-C & Outcomes Solutions Toll-free: 1-855-CALL-DH1 www.decisionhealth.com 9737 Washingtonian Blvd., Ste. 200 Gaithersburg, MD 20878-7364 July 2013 | Volume 9, Issue 7 Get ICD-10 training at national OASIS conference This year’s annual National Quality Outcomes & OASIS-C Conference features sessions to help your agency prepare for ICD-10 and the new OASIS-C1 form. Plus, you’ll get guidance to become part of a care-transition partnership and improve overall OASIS accuracy. Get more details about this conference at: www.homecareoutcomesconference.com. Coding Corner M1024 change impacts bottom line, requires sharper coding practices Nearly six months after the new M1024 rules took effect, confusion persists about if and when it’s appropriate or necessary to assign codes there, and agencies are feeling a financial pinch from case-mix points no longer available for resolved conditions. VNA Home Health is losing a couple hundred dollars on the episodes in which the agency is no longer earning case-mix points in M1024 for resolved conditions, says Anne Anastasio, utilization review coordinator for the agency. Over time, that could add up to a sizeable impact on the bottom line. (see M1024 change, p. 8) Regulatory compliance Palmetto GBA to thoroughly review face-to-face encounter documentation More claims might be denied now that Medicare administrative contractor (MAC) Palmetto GBA has announced it will “begin a more comprehensive review” of face-to-face documentation. “Palmetto GBA encourages all providers to review their internal processes to ensure that all of the criteria for coverage have been met and documented in the medical record,” a Palmetto release states. (see Face-to-face, p. 9) Time for an ICD-10 impact assessment: Make sure you include all departments 2 Transition teams: Who’s involved and what’s their role? 3 Agencies use telehealth to reduce readmissions, partner with hospitals 3 Agencies’ use of telehealth: 2013 vs. 2007 4 CMS clarifies: OASIS depends on ability to ‘access’ medications 5 Answer M1030 correctly to secure accurate points for infusion therapy 6 Adopt infection controls for nursing bags to reduce patient risk 7 Heart failure program readmission worksheet Extra

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Page 1: Coding Corner - DecisionHealthdecisionhealth.com/static/pdf/HCC13012_3_issue.pdfstaff before and after the transition. Understand that the transition will be incredibly stressful for

In This Issue

OASIS-C & Outcomes Solutions • Toll-free: 1-855-CALL-DH1 • www.decisionhealth.com 9737 Washingtonian Blvd., Ste. 200 • Gaithersburg, MD 20878-7364

July 2013 | Volume 9, Issue 7

Get ICD-10 training at national OASIS conference

This year’s annual National Quality Outcomes & OASIS-C Conference features sessions to help your agency prepare for ICD-10 and the new OASIS-C1 form. Plus, you’ll get guidance to become part of a care-transition partnership and improve

overall OASIS accuracy. Get more details about this conference at: www.homecareoutcomesconference.com.

Coding Corner

M1024 change impacts bottom line, requires sharper coding practices

Nearly six months after the new M1024 rules took effect, confusion persists about if and when it’s appropriate or necessary to assign codes there, and agencies are feeling a financial pinch from case-mix points no longer available for resolved conditions.

VNA Home Health is losing a couple hundred dollars on the episodes in which the agency is no longer earning case-mix points in M1024 for resolved conditions, says Anne Anastasio, utilization review coordinator for the agency. Over time, that could add up to a sizeable impact on the bottom line.

(see M1024 change, p. 8)

Regulatory compliance

Palmetto GBA to thoroughly review face-to-face encounter documentation

More claims might be denied now that Medicare administrative contractor (MAC) Palmetto GBA has announced it will “begin a more comprehensive review” of face-to-face documentation.

“Palmetto GBA encourages all providers to review their internal processes to ensure that all of the criteria for coverage have been met and documented in the medical record,” a Palmetto release states.

(see Face-to-face, p. 9)

Time for an ICD-10 impact assessment: Make sure you include all departments 2

Transition teams: Who’s involved and what’s their role? 3

Agencies use telehealth to reduce readmissions, partner with hospitals 3

Agencies’ use of telehealth: 2013 vs. 2007 4

CMS clarifies: OASIS depends on ability to ‘access’ medications 5

Answer M1030 correctly to secure accurate points for infusion therapy 6

Adopt infection controls for nursing bags to reduce patient risk 7

Heart failure program readmission worksheet Extra

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Subscriber Information

EDITORIAL Have questions on a story? Call or email:

President: Steve Greenberg 1-301-287-2734 [email protected]

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DISTRIBUTION RIGHTS AND COPYRIGHT: All content is copyrighted and may not be excerpted or copied in part, nor do such rights provide for re-sale or competitive use of editorial. To request permission to make photocopy reprints of OASIS-C & Outcomes Solutions articles, call 1-855-CALL-DH1 or email customer service at [email protected]. Also ask about our copyright waiver, multiple copy and site license programs by calling the same number. Copyright violations will be prosecuted. OASIS-C & Outcomes Solutions shares 10% of the net proceeds of settlements or jury awards with individuals who provide essential evidence of illegal photocopying or electronic redistribution. To report violations, contact: Steve McVearry at 1-301-287-2266 or email him at [email protected].

OASIS-C & Outcomes Solutions is published monthly by DecisionHealth, 9737 Washingtonian Blvd., Ste. 200, Gaithersburg, MD 20878-7364. Price: $447/year. Copyright 2013.

ICD-10 readiness

Time for an ICD-10 impact assessment: Make sure you include all departments

The ICD-10 transition doesn’t just affect your coders. Take the time now to analyze how the coding change will impact other departments, such as clinical and billing, to ensure you’re prepared for a financial hit that could last for months after Oct. 1, 2014.

More than one quarter of the agencies that responded to a recent ICD-10 preparedness survey said they don’t expect to be ready by the time the deadline hits, accord-ing to the 156 respondents to a survey conducted by DecisionHealth’s Board of Medical Specialty Coding & Compliance (BMSC).

Due to CMS’ repeated delays of ICD-10, few agencies have thought in earnest about the transition’s financial and operational impact, says Ann Rambusch, president of Rambusch3 Consulting in Georgetown, Texas. “In home health, we kind of look up and say ‘We’ve got better things to do. We have one person who’s a coder, and he or she should take care of this,’” she notes. “But it doesn’t fall just on one person, it falls on the entire agency.”

As the administrator, it’s up to you to take the lead on a comprehensive ICD-10 impact assessment, she advises. Just 8% of the agencies said they have conducted an im-pact analysis, according to the BMSC survey.

If you haven’t already, you’ll need to put together a transition team to help you conduct this assessment, ad-vises Trish Twombly, senior director for DecisionHealth in Gaithersburg, Md. The team should include someone who has insight into your agency’s billing reports and financial dashboards and someone who can communicate with clinicians about the level of detail in their documentation. So far, only 18% of agencies have designated such a team, the survey shows. (For more on how agencies are structur-ing the team and its tasks, see p. 3.)

Questions to ask during the assessmentWork with the transition team to find answers to the

following questions during your assessment:

• HowwillwehandledashboardsandotherreportsthatincludeICD-9codes?You’ll have to assess whether you consider information in the reports important enough to your operations to transition them, Twombly notes. If there’s a report you don’t consider essential, you may be better off retiring it. As part of that decision, you may need to get in touch with your vendor to see what it takes to adapt the reports for ICD-10, and decide when that should happen. One report you’ll definitely want to transition: Your agency’s top 10 admission diagnoses. That report not only helps you monitor patient characteristics, it also can provide hints on staff training needs and marketing opportunities, Twombly says.

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• Whatlevelofdetaildoesourclinicaldocumentationcurrentlyinclude? Knowing that should help you assess who needs more training and how much. For example, laterality is key in ICD-10, so clinicians will have to document the exact location of any injury that must be coded. “Coders can’t guess at that,” notes Arlene Maxim, founder of A.D. Maxim & Associates in Troy, Mich.

• ArewepreparedforrevenuedisruptionsafterOct. 1,2014? Make sure you can have at least six months of operating cash on hand in case your transition doesn’t go smoothly, Rambusch recommends. Start now by putting together a letter of credit for your bank or other lender. In addition to basic operating cash, it’s a good idea to make room in the budget for temporary help from outsource coders, she advises.

• HowwillweadjustourproductivityexpectationsforcodersaroundtheICD-10transitiondate?For example, say your coders currently complete a record in 30 minutes. For six months to a year after the transition, you’ll have to revise your productivity expectations to reflect longer completion times, Rambusch advises. Ideally, it will take your coders no

Transition teams: Who’s involved and what’s their role?Fewer than one in five agencies have appointed ICD-10 transition teams, according to a recent survey with 156 respondents conducted by the Board of Medical Specialty Coding & Compliance (BMSC), a division of DecisionHealth in Gaithersburg, Md.

Those agencies that had transition teams in place listed the following team members: administrator, director of clinical services, chief financial officer, senior IT staff, QA/QI department representatives, billing coordinator, coders and marketers. Transition teams will:

•Develop a plan for training

•Assess readiness of billing and IT systems for the transition

•Provide an overview of necessary process changes at intake

•Work with appointed ICD-10 trainers

•Quantify lost productivity during the transition

•Assess the need for outside assistance with coding

•Determine education needs among referral sources

— Tina Irgang ([email protected])

more than an additional 10 minutes to complete a record, but it’s more likely that at least initially, you’re looking at completion times of up to an hour, she warns.

• Andhowaboutproductivityexpectationsforclinicians?Given the additional level of detail clinicians will need to capture under ICD-10, they’ll need more time to conduct start-of-care assessments, Maxim notes. For example, if it currently takes three hours on average to complete the start-of-care OASIS, you’ll probably need to add another 30 minutes to that under ICD-10, she estimates. Add to that the fact that the implementation of ICD-10 will coincide with the implementation of OASIS-C1. “CMS has said it’s going to revise [items], so we have no idea what another part of this animal looks like,” Rambusch notes.

• HowdoourstaffmembersperceivetheICD-10transition? Many agencies will see increased turnover following Oct. 1, 2014, if they don’t adequately support staff before and after the transition. Understand that the transition will be incredibly stressful for coders and clinicians and everyone at your agency, Rambusch says. “That’s why it’s important to introduce ICD-10 gradually. It’s important to be leaders.” Engage even those staff members that won’t have a major role, and find ways they can support those who will be most significantly affected by the transition, she suggests. — Tina Irgang ([email protected])

Technology survey

Agencies use telehealth to reduce readmissions, partner with hospitals

As the home health industry seeks ways to work with hospitals to prevent readmissions, more and more agencies are turning to telehealth as a viable option.

More than 64% of home health agencies have some form of telehealth or will buy by the end of 2014, according to the 100 respondents to DecisionHealth’s recent technology survey. That’s compared with 52% of respondents on a similar survey six years ago.

The trend is going to continue, says Richard Brennan, VP for technology policy at the National Association for Home Care & Hospice. Telehealth can lead to a reduction of re-hospitalizations, and hospitals seeking partnerships are drawn to agencies that can do that.

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And agencies are finding that such reductions, along with a decrease in nursing visits and an increase in referrals, can justify the cost of telehealth, despite the lack of federal funding.

What’s more: The prices of telehealth units are dropping from when they were first introduced and their quality is improving, Brennan says.

For those agencies that have not yet bought in, the most common reasons remain: upfront capital expense (43%) and lack of Medicare reimbursement (32%).

Penalties make case for telehealthFor at least one hospital-based agency, the hospital

readmission penalties helped justify the technology’s cost for the larger health system it belongs to.

Diane Link had wanted to adopt telehealth at her agency, Westminster, Md.-based Carroll Home Care, for seven years. But it took a while to get Carroll Hospital Center to buy in to the idea. Ultimately, the combination of the hospital readmission penalties and the government’s increased focus on reducing hospital readmissions prompted Carroll Hospital Center to pay the $90,000 needed for the initial investment in telehealth.

Carroll Home Care received 24 telehealth monitors in September 2011 from San Francisco-based McKesson and Palo Alto, Calif.-based Bosch. From July 1 through April 28, patients on telehealth had no readmissions for congestive heart failure, cardiopulmonary or hypertension reasons, says Link, Carroll Home Care’s executive director. The agency has had an average of 5.5% of patients on telemonitors return to the hospital for other reasons.

The agency’s overall readmission rate has dropped 8% since it received the monitors nearly two years ago, she notes.

Next year, the agency hopes to double its number of monitors. Link says her agency has cut two to three nurse visits per episode as a result of telemedicine.

Reduced visits justify costsBut with or without the hospital readmission penalties,

the reduction in nursing visits justifies the cost for Pennock Homecare Services in Hastings, Mich.

A reduction in nursing visits, possible due to the telehealth equipment, is saving the agency roughly

$156,000 a year, estimates director Cynthia Poort. Her estimate comes from reducing one $200 nursing visit each week for 15 patients with telehealth units.

Poort’s agency started using telehealth six years ago, and she is pleased with the technology. Pennock’s rate of hospitalization has improved over a period of three years to 15% from 23%, and its number of nursing visits for telehealth patients has dipped from roughly three a week to one or two a week.

Over the past six years, Pennock has spent $57,000 on telehealth from vendor Honeywell HomMed of Brookfield, Wis. While the agency was fortunate to receive a $50,000 grant from the Pennock Foundation, the reduction in nursing visits would have covered the cost, even without grants, Poort says.

Technology survey

Agencies’ use of telehealth: 2013 vs. 2007Nearly two-thirds of home health agencies have some form of telehealth or will buy by the end of 2014, compared with about half of respondents on a similar survey six years ago.

Among respondents using telehealth, 46% have 51 or more devices; that’s compared with 25% six years ago. The results are based on 100 respondents to this year’s survey and 407 respondents to the 2007 survey.

2013 2007

Do you use telehealth?

Actively use and happy 41% 32%

Rarely use, will not replace 5% 5%

Actively use, will upgrade by end of next year 8% 6%

Don’t have but will buy by end of next year 11% 8%

Don’t have and not interested 6% 12%

Wish list 30% 36%

If you use telehealth, how many telehealth devices do you have in the field?

1-25 36% 48%

26-50 18% 27%

51-100 26% 16%

101-200 12% 6%

201-300 6% 1%

More than 300 2% 2%

Source: DecisionHealth’s 2013 and 2007 technology surveys

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When Pennock began using telehealth, some staff members weren’t on board. The equipment back then wasn’t as light as it is now, and staff members didn’t initially believe the equipment’s readings were accurate.

But a few good experiences — where staff saw that the equipment helped prevent congestive heart failure patients from needing re-hospitalization — changed opinions, Poort says.

Leverage telehealth to boost referralsAgencies can use telehealth as a marketing tool to

increase referrals from hospitals. Follow these steps to best position your agency to do that:

• Sendamailertohospitalsshowingthemhowyourtelehealthunitscanhelpthemreduce30-dayreadmissions.In that mailer, request that hospital staff schedule an appointment with your agency, says Arlene Maxim, founder of A.D. Maxim & Associates in Troy, Mich.

• Providespecificpatientexamples.One example of a readmission reduction at Methodist Affiliated Services’ Home Care, Hospice and Palliative Services in Memphis, Tenn., involved an elderly patient who viewed her daily call from her telehealth nurse as her social visit for the day, says Sally Aldrich, the agency’s administrator and chief nursing officer. Through the relationship, that patient learned to become more compliant with medications, and her heart failure stabilized, Aldrich says. When your sales staff shares stories like this with the hospitals, they’re more likely to work with your agency. — Josh Poltilove ([email protected])

OASIS Tip of the Month

CMS clarifies: OASIS depends on ability to ‘access’ medicationsBy: Ann Rambusch

Consider your patient’s ability to safely access medication from the area in which medication is routinely stored when answering M2020 and M2030 (Management of oral medications and injectable medications). This will help you secure accurate case-mix points and correct risk adjustment.

Patients are not safe to administer medications independently if:

• Medications are routinely stored in the refrigerator, and patients require someone to assist them to walk to the location where the medications are routinely stored; or

• Someone must retrieve the medications and bring them to the patient.

That’s the latest clarification from CMS in its April 2013 quarterly Q&As (OOS 6/13).

(M2020) Management of Oral Medications: Patient’s current ability to prepare and take all oral medications reliably and safely, including administration of the correct dosage at the appropriate times/intervals. Excludes injectable and IV medications. (Note: This refers to ability, not compliance or willingness.)

0 – Able to independently take the correct oral medication(s) and proper dosage(s) at the correct times.

1 – Able to take medication(s) at the correct times if:

(a) individual dosages are prepared in advance by another person; OR

(b) another person develops a drug diary or chart.

2 – Able to take medication(s) at the correct times if given reminders by another person at the appropriate times.

3 – Unable to take medication unless administered by another person.

NA – No oral medications prescribed.

(M2030) Management of Injectable Medications: Patient’s current ability to prepare and take all prescribed injectable medications reliably and safely, including administration of correct dosage at the appropriate times/intervals. Excludes IV medications.

0 – Able to independently take the correct medication(s) and proper dosage(s) at the correct times.

1 – Able to take injectable medication(s) at the correct times if:

(a) individual syringes are prepared in advance by another person; OR

(b) another person develops a drug diary or chart.

2 – Able to take medication(s) at the correct times if given reminders by another person based on the frequency of the injection.

3 – Unable to take injectable medication unless administered by another person.

NA – No injectable medications prescribed.

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When answering M2020 or M2030, also make sure you consider physical, sensory or environmental barriers that may prevent patients from accessing their medications on their own.

Note: M2030 is worth anywhere from one to three case-mix points depending on the episode timing and therapy use.

Considerthisscenario:Mr. J gets an insulin injection twice a day. He is able to correctly prepare and self-administer his insulin, including safely disposing of syringes. However, the patient has an unsteady gait and requires the assistance of a caregiver to access the kitchen where his insulin is stored in the refrigerator. How should you answer M2030?

Answer: Response 3 - Unable to take injectable medication unless administered by another person.

Discussionandguidance:Clinicians should consider environmental barriers when responding to M2030 (Management of injectable medications). Although the patient is able to prepare and self-administer his insulin, he is unable to ambulate safely to the kitchen without assistance.

These OASIS items cover what patients need to be safe when accessing and taking their medications. Arranging for this patient to have a portable refrigerator close by for insulin storage could eliminate the patient’s need to walk to the kitchen to access his insulin and could increase his safety. At the next OASIS data collection time point, the patient could be scored a “0,” demonstrating improvement in his status if an environmental barrier has been successfully addressed.

Anddon’t forget to consider how the patient accesses water or other beverages necessary to swallow his medication when evaluating M2020 (Management of oral medications).

About the author: Ann Rambusch, RN, MSN, HCS-D, COS-C, is the president of Rambusch3 Consulting, Georgetown, Texas. She is a member of the Board of Medical Specialty Coding & Compliance (BMSC), is one of the lead technical advisors in the creation of the HCS-O exam and is an AHIMA-approved ICD-10 trainer.

OASIS accuracy

Answer M1030 correctly to secure accurate points for infusion therapy

Clinicians should mark Response 2 (Parenteral nutrition) in M1030 (Therapy at home) regardless of the clinician’s involvement in the TPN therapy.

Failure to answer this item correctly could result in a loss of appropriate case-mix points. This question is worth up to 15 case-mix points depending on the episode timing and therapy need.

To prevent that from happening, be sure to train clinicians on the correct use of this item using scenarios provided by Judy Adams, president of Adams Home Care Consulting in Asheville, N.C.

Patient scenario No. 1 for M1030A patient is referred to home health because of high

blood pressure/hypertension. The patient also has Crohn’s disease, but that’s not the reason home health services are ordered. The Crohn’s disease results in intestinal inflammation, which results in a need for temporary parenteral therapy that will run from 7 p.m. to 7 a.m. each night and is managed by the patient’s family.

Answerandrationale: Response 2 (Parenteral nutrition) is correct. Since family members are often in charge of setting up and performing the parenteral infusion services and clinician involvement is limited, nurses don’t always make the connection that this is something that should be documented on the OASIS, Adams notes. But the item doesn’t ask about who is giving the services, it just matters that the services are occurring in the home.

(M1030) Therapies the patient receives at home: (Mark all that apply.)

1 – Intravenous or infusion therapy (excludes TPN)

2 – Parenteral nutrition (TPN or lipids)

3 – Enteral nutrition (nasogastric, gastrostomy, jejunostomy, or any other artificial entry into the alimentary canal)

4 – None of the above

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More tips to answer M1030• Answer‘yes’regardlessofwhoprovides the IV,

TPN or enteral nutrition.

• IVtherapyincludes intrathecal, epidural, subcutaneous, central line or peripheral IV meds, fluids or flushes and dialysis at home, whether via implanted pump or external infusion device.

• Parenteraltherapyincludes nutritional fluids or lipids for patients who are unable to absorb adequate food sources through the digestive system provided by home health staff, the patient or caregiver. Patients receiving parenteral nutrition also need periodic flushes to their IV line to maintain patency.

• WhenpatientsarereceivingbothinfusiontherapyandTPN at home through lumens in multi-lumen catheters, Responses 1 and 2 are appropriate, according to CMS’ April 2011 Q&A No. 3.

• Whenonelumenisused for both, Response 2 is appropriate, according to CMS’ January 2011 Q&A No. 53.4.

• WhenIVorenteral therapy is ordered PRN and the assessment indicates a need for therapy now, Response 1 or 3 is appropriate.

• Don’treportMammoSite® breast brachytherapy (balloon catheter radiation) in M1030. It is a type of radiation treatment and since the saline and radiation seed remains in the balloon catheter, it is not an infusion and not reported in M1030, according to CMS’ July 2012 Q&A No. 3.

• Ifapatienthasaperitonealdialysiscatheter and there is an order to flush it while in the home to maintain patency, Response 1 is appropriate, according to CMS’ January 2012 Q&A No. 4.

• MarkResponse3forenteralnutrition when the patient has a PRN order for Ensure through a g-tube AND the patient meets the parameters for administration of the feedings based on findings of the comprehensive assessment, or has met the parameters and/or received enteral nutrition at home in the last 24 hours. Don’t mark Response 3 automatically based on just a PRN order at the start of care, according to CMS Q&A 53.5, category 4.

Infection control

Adopt infection controls for nursing bags to reduce patient risk

Implement procedures to prevent pathogen transmis-sion via nursing bags and link compliance to clinicians’ annual performance evaluations to reduce the risk of patient infections.

“Bags can harbor pathogen organisms, which can contribute to a patient infection,” says Mary McGoldrick, a home care and hospice consultant with Home Health Systems, Inc. in Saint Simons Island, Ga. “If I improperly place my dirty bag on your table, for example, those pathogens can be transferred.”

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There are no specific written requirements from The Joint Commission or CMS on proper techniques for storing or safeguarding a nursing bag, says Barbara Citarella, president and CEO of RBC Limited in Staatsburg, N.Y. This is due in part to the fact that there is no single, hard-and-fast method to prevent pathogen transmissions via nursing bags, McGoldrick notes.

Liability related to nursing bags also is less than clear-cut.

“Proving a direct linkage between a contaminated bag and an infection would be difficult …, though not impossible,” McGoldrick says.

Still, proper bag technique is important, and Joint Commission surveyors and others performing site visits typically will expect agencies to have general infection control policies and bag procedures in place, and for nurses to be trained and in compliance with those policies and procedures.

“Infection control practices should be part of job performance” and should be monitored as part of performance assessment, Citarella recommends.

What should bag procedures look like?The key starting point is preventing the bag from

coming into direct contact with the floor or another bare surface in the home, Citarella notes. Place a barrier between the bag and surfaces to prevent the spread of germs. Newspapers or paper towels are generally acceptable, though McGoldrick says using a plastic bag or other moisture-proof barrier can prevent wicking. Barriers can also improve patient confidence.

“From an aesthetics standpoint, it’s nice to use a barrier under your bag before you put it on the table,” McGoldrick says.

Be sure to use a barrier — or avoid bringing your bag into the home altogether — under the following circumstances, McGoldrick recommends:

• The nurse’s or patient’s home is infested with pests, such as bed bugs;

• The nurse or patient is sick because of a drug-resistant organism, which can live for days and potentially be transmitted; or

• Pet excrement is present in the home or car.

In the case of bed bugs and other insects, if the nurse’s

home is contaminated, place the bag in a plastic bin or other large container while in the car to contain the spread of the pests.

Other guidelines for good bag technique from McGoldrick, Citarella and a policy created by the Health and Home Care Services division of the New York City Health and Hospitals Corporation (http://tinyurl.com/7lsx3lq):

• Cleanbagsatleastquarterly with soap, alcohol or another approved substance.

• Keeptwocompartmentsinthebag: one for equipment and one for unused cleaning supplies.

• Don’tplaceorcarryanycontaminatedequipmentor material in the bag.

• Keepwheelsontheflooratalltimesif the nursing bag has them.

• Don’topenbagflapswide enough for them to touch the floor.

• Discardanydisposablebagbarriersbefore leaving the patient’s home.

• Don’tletthebagtouchthepatient.

• Practicegoodhandhygiene after touching the bag and before touching the patient.

• Don’treachintothebagwithsoiledgloves.

• Cleanequipmentwithsoap,alcoholoranotherapprovedcleaningsolution before placing it back in the bag at the end of the visit. — Scott Harris ([email protected])

M1024 change(continued from p. 1)

Coders also are reporting that the change has led them to sharpen their coding practices and to investigate more closely whether diagnoses are really resolved, which in some cases has helped to retain potentially crucial case-mix points that would have otherwise been lost under the new rule.

Risk adjustment confusion persistsMany home health coders still are questioning

whether they should assign diagnoses in M1024. Additionally, many coders remain confused about

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whether they’ll actually see some benefit from doing so, says Jan Ungacta, a consultant with Aegis Home Care Resources in Buda, Texas.

For the first few weeks of 2013, coder Kaylin Chenault says she still assigned resolved condition codes in M1024 in hopes of receiving risk adjustment. However, she has since discontinued this practice, and now she only codes fractures in M1024 per the new rule, says Chenault, clinical coding manager at Pathways Home Health and Hospice in Sunnyvale, Calif.

There doesn’t seem to be any way for CMS’ grouper software to pull risk adjustment from any codes besides fractures placed in M1024 so there’s no reason to place resolved conditions in that slot, says coding expert, Lisa Selman-Holman, principal of Selman-Holman Associates and the coding service CoDR — Coding Done Right in Denton, Texas.

If the grouper is not triggered to move to M1024 except with the V54.1 and V54.2 codes, then it cannot capture risk adjustment for anything else. Additionally, the majority of the time, risk adjustment already will be awarded for resolved conditions from M1010 and M1016, Selman-Holman says.

While there doesn’t appear to be any explicit penalty for continuing to assign resolved conditions in M1024, Ungacta doesn’t think it’s good practice to continue coding practices that do not align with the new rules.

Furthermore, it’s a better coding practice to get out of the habit of assigning resolved conditions in M1024, since it won’t exist with ICD-10, she says.

Coding change: Cancer and GI The new M1024 rules are forcing even veteran

coders to change some of their thought processes when coding, particularly in cases involving cancer and GI diagnoses.

Consider a patient who came to home care after having surgery to remove both her breasts due to breast cancer. Scouring the record, veteran coder Vonnie Blevins, coding and billing manager for Excellence Healthcare in Houston, noticed in tiny handwriting that the patient was undergoing chemotherapy, indicating that her cancer was still an active condition and should be coded as such.

Missing that detail and failing to code the breast cancer as an active condition would have cost the agency up to 10 case-mix points, depending on episode timing and therapy utilization.

Correctly determining whether the condition is still active in cancer cases is “the biggest issue” in regards to the new landscape of M1024, says Anne Anastasio, utilization review coordinator for Inova VNA Home Health in Fairfax, Va.

Tips for M1024 compliance• Don’tassumethecancerdiagnosisisnolonger

active just because the body part affected by cancer was removed, Blevins says.

• Codecancerasanactivecondition unless the physician specifically states that it is eradicated, Blevins advises.

• Encourageclinicianstoaskpatientsaboutwhetherthey’llbeundergoingfurthertreatment to determine if cancer is still an active diagnosis that should be coded, Anastasio says.

• Codecase-mixlossgroups(Skin1,Neuro1andDiabetes)inthefirstsecondaryslot(M1022b)whenappropriate. And avoid piling up V codes in the top six diagnoses, Blevins warns.

• Scourreferralsanddocumentationtofindtherightdiagnoses. This is essential under the new rules, because a missed diagnosis could cost your agency valu-able case-mix points. — Megan Gustafson ([email protected])

Face-to-face(continued from p. 1)

The more thorough review will be included in an additional documentation request (ADR) on the back end of the process, believes Mary St. Pierre, VP for regulatory affairs with the National Association for Home Care & Hospice. “They’ll send out an ADR, and on every single one, they’ll look at face-to-face” documentation, she says.

Previously, when targeting something unrelated for medical review, Palmetto might have checked to see if face-to-face encounter documentation was there, but might not have examined it for quality, St. Pierre says.

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As a result of Palmetto’s more comprehensive review, she says, it will likely issue more complete denials of individual claims.

Often, a physician’s description in face-to-face encounter documentation is “sorely lacking,” St. Pierre notes.

St. Pierre says the biggest issue that agencies continue to struggle with involves physicians not properly showing how specific clinical findings support homebound status. Other issues involve the brief narrative describing how the patient’s condition supports the need for services and the fact that the certification statement must be signed by the same physician who documents the face-to-face encounter, she adds.

Documentation that just lists the patient’s diagnosis or recent procedures or injuries alone would not be adequate. And it’s not enough to include statements such as “taxing effort to leave home” without specific clinical findings that show what makes patients homebound. The documentation of the face-to-face encounter has to be clearly titled, and the certification has to be signed by the certifying physician, according to Palmetto.

Marketing staff make inroads with docsOne thing that helps McLaren Home Care Group in

Davison, Mich., with getting face-to-face documentation corrected and thoroughly filled out involves assigning marketing staff to go to physicians’ offices and offer advice and help.

The strategy makes inroads with those doctors, says Christie Herrick, the agency’s regional palliative care manager.

McLaren’s marketing staff is provided a document explaining how doctors should fill out forms, highlighting what sorts of responses are needed, Herrick says. The same marketer will work consistently with the same doctor or physicians’ group, establishing a relationship.

“That’s been probably a big part of our success, having somebody go out there — not just for the face-to-face but all the orders,” she says.

Roughly 60% of McLaren’s patients come from its hospital system. For those patients, McLaren works with case managers.

The case managers put face-to-face forms on the chart at the hospital for the physician. McLaren educates

the case manager, and the case manager can walk the doctor through the process.

Tips to educate physiciansUse these tips to ensure face-to-face encounter

documentation will be filled out thoroughly, accurately and quickly:

• Trainyouragency’smarketingstaffondocumentationrequirements. Have them visit the doctor’s office to work individually with the doctor or their staff to correct the form, suggests Judy Adams, president of Adams Home Care Consulting in Chapel Hill, N.C. Consider having your agency’s marketers retrieve the forms from physicians so they can quickly review the documentation and immediately begin the correction process.

• Provideexamplesofcompliantface-to-faceanswersthatrelatetoaphysician’sspecialty. Some specialists don’t refer nearly as many patients as other physicians, so they may not understand the need for face-to-face encounters, Adams notes. A cardiologist, for example, could benefit from the following sample: “The patient needs to be monitored closely by a clinician because he has had an irregular heart rate and increased symptoms of heart failure, and the patient is homebound due to restrictive activity as a result of the heart condition.” If all of your examples are general, it’s going to be difficult for the specialist to understand and relate them to his or her individual experience, Adams says. — Josh Poltilove ([email protected])

Boost home health referrals by educating physicians about TCM

W W W

Physicians will get paid an average of $231.36 more for helping patients transition into the home and identifying the need for home health. Seize this opportunity to educate physicians

about the billing requirements for the new transitional care management (TCM) codes and gain referrals. During this 60-minute training, home health marketing and sales expert Lori Moshier will help you boost your home health referrals for TCM patients, and build stronger physician relationships. Purchase a copy of the CD at: https://store.decisionhealth.com/Product.aspx?ProductCode=TA2368CD.

© 2013 DecisionHealth® • www.decisionhealth.com • Toll-free: 1-855-CALL-DH1

& Outcomes SolutionsOASIS-C Tool of the MonthJuly 2013 | Vol. 9, Issue 7

Tool: Heart failure program readmission worksheetThis tool will assist the heart failure program nurse to evaluate patients who were previously admitted with heart failure and who are now admitted again. The intent of the review is to identify the cause of the readmission and any needs that the patient may require assistance with to prevent future readmissions. The data obtained will be used to aid heart failure patients in managing their disease and improving the services provided to patients and the community. Patient-specifi c information will remain confi dential under the HIPAA privacy law.

Note: These are the fi rst two pages of this tool. To view the complete tool, go to: www.decisionhealth.com/OOS/OOS_0713_tool.pdf.

Readmit date:

Primary readmit diagnosis:

Heart failure information:

EF: ___________% Date of EF: ___________ UTD

NYHA class: I II IIIA IIIB IV UTDSelect applicable: ICD PM CRT-D CRT-P

Loop monitor None

Previous medical history Select all that apply: COPD HTN DM CAD Other: ________________________________ UTD

Functional status: Independent Some assistance Dependent

Lives at: Home alone SNF Home with family or caregiver Home health Nursing home Hospice (IN-PT) LTAC Hospice (OUT-PT)

Current admission status: Admit weight: ___________ kg UTD

Discharge weight: ___________ kg UTD

Has a cardiologist? Yes No UTD Seen before readmit? Yes No UTD

F/u appointment scheduled? Yes No UTD # Days after previous DC: ___________

Type of admission: Foreseen or planned (TX F/U) Unforeseen (new problem) Unforeseen (R/T prev. Admit)

Did out-pt issues contribute to this admit? No YesIf yes, select all that apply: Noncompliance (meds)

Noncompliance (self-care) Lack of support Financial issues Did not attend F/U appt.

Any urgent care/ED visits between DC and this admit? No Yes (# days after DC: ___________)

Number of days DC to admit: ___________ UTD

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© 2013 DecisionHealth® • www.decisionhealth.com • Toll-free: 1-855-CALL-DH1© 2013 DecisionHealth® • www.decisionhealth.com • Toll-free: 1-855-CALL-DH1 © 2013 DecisionHealth® • www.decisionhealth.com • Toll-free: 1-855-CALL-DH1

& Outcomes SolutionsOASIS-C Tool of the MonthJuly 2013 | Vol. 9, Issue 7

Tool: Heart failure program readmission worksheetThis tool will assist the heart failure program nurse to evaluate patients who were previously admitted with heart failure and who are now admitted again. The intent of the review is to identify the cause of the readmission and any needs that the patient may require assistance with to prevent future readmissions. The data obtained will be used to aid heart failure patients in managing their disease and improving the services provided to patients and the community. Patient-specifi c information will remain confi dential under the HIPAA privacy law.

Note: These are the fi rst two pages of this tool. To view the complete tool, go to: www.decisionhealth.com/OOS/OOS_0713_tool.pdf.

Readmit date:

Primary readmit diagnosis:

Heart failure information:

EF: ___________% Date of EF: ___________ UTD

NYHA class: I II IIIA IIIB IV UTDSelect applicable: ICD PM CRT-D CRT-P

Loop monitor None

Previous medical history Select all that apply: COPD HTN DM CAD Other: ________________________________ UTD

Functional status: Independent Some assistance Dependent

Lives at: Home alone SNF Home with family or caregiver Home health Nursing home Hospice (IN-PT) LTAC Hospice (OUT-PT)

Current admission status: Admit weight: ___________ kg UTD

Discharge weight: ___________ kg UTD

Has a cardiologist? Yes No UTD Seen before readmit? Yes No UTD

F/u appointment scheduled? Yes No UTD # Days after previous DC: ___________

Type of admission: Foreseen or planned (TX F/U) Unforeseen (new problem) Unforeseen (R/T prev. Admit)

Did out-pt issues contribute to this admit? No YesIf yes, select all that apply: Noncompliance (meds)

Noncompliance (self-care) Lack of support Financial issues Did not attend F/U appt.

Any urgent care/ED visits between DC and this admit? No Yes (# days after DC: ___________)

Number of days DC to admit: ___________ UTD

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OASIS-C & Outcomes Solutions

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July 2013

12 11

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