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The Home Health industry continues to evolve: the updated Conditions of Participation (CoPs) in 2018, then OASIS-D and the Review Choice Demonstration (RCD) in 2019, and now the Patient-Driven Groupings Model scheduled for 2020, just to name a few!  Change can be exhausting, so it is comforting to know that some things aren’t changing...like documentation!

Following the recent NAHC Financial Management Conference in Chicago, HealthPRO Heritage representatives in attendance outlined principal key concerns affecting home health agencies going forward into PDGM implementation. 

On July 11, 2019, Centers for Medicare & Medicaid Services (CMS) issued the 2020 Home Health Prospective Payment System (PPS) Proposed Rule (effective January 1, 2020). While many of the provisions in the original Patient-Driven Groupings Model (PDGM) remain unchanged, the home health experts from HealthPRO Heritage at Home offer the following summary of important updates:

As PDGM edges closer, there is rising concern and tension around the submission of claims that contain primary diagnoses that do not fall into one of the 12 clinical groupings established by CMS. Such primary diagnoses are known as "Questionable Encounters" (QEs). QE codes are "too vague," meaning the code did not provide adequate information to support the need for home health services. CMS listed 43,287 eligible primary diagnoses codes in their PDGM Grouper Tool. 

Under PDGM, claims for QEs will be sent back to the agency as "Return to Provider" (RTP) since CMS will not be able to assign the 30-day period to one of the 12 PDGM clinical groups. 

Examples of the Top 25 QE Codes:

Start preparing TODAY to guarantee your agency's success in the future. With ~6 months to go, ask yourself: Are you on track for the transition to PDGM? Do you have the right therapy partner?

HealthPRO Heritage at Home has compiled the following PDGM Preparation Checklist that can help organize a plan of action for home health agencies affected by the future of PDGM:

It can be easy to get lost in the details of PDGM and forget how vital outcomes and ratings are in driving overall agency success.  It’s one of the biggest reasons why appropriately managing therapy in PDGM is a key competency.

In HealthPRO Heritage at Home's recent survey with the National Association for Home Care and Hospice regarding therapy in PDGM, 48% of respondents anticipate less therapy utilization. Agencies should be cautioned on cutting therapy utilization given the focus on functional assessment and outcomes.  Functional assessments - completed best by a skilled therapist - will contribute significantly to payment in PDGM, while also continuing to drive publicly reported outcome measures and star ratings.

HealthPRO Heritage at Home partnered with the National Association for Home Care and Hospice (NAHC) to conduct a survey of home health providers to gather industry feedback on therapy utilization under PDGM. HealthPRO Heritage co-sponsored the survey as part of its ongoing effort to bring strategies and solutions to agencies as they prepare for PDGM. Nearly 700 people took the survey and were made up of representatives in every state from freestanding, institutional, health system and government based agencies from both for and not-for profit settings. 

The Patient-Driven Groupings Model (PDGM) is a game changer, requiring home health providers to explore new business models based on the introduction of new risks and potentially significant financial impacts.

HealthPRO Heritage at Home is leading the industry in readiness for the January 1, 2020 change to the Patient-Driven Groupings Model (PDGM). Success for both our partner agencies and employees will be driven through knowledge and implementation of process and strategy around PDGM.

Coding will be instrumental to your agency’s success under PDGM. Performing an audit of your coding practices now will provide the opportunity to educate your staff on accurate and cohesive coding guidelines and targeted aspects of the OASIS to ensure you are prioritizing both patient needs and accurate reimbursement.