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Know these 3 crucial differences between the old and new PCR program.<\/em><\/strong><\/span><\/p>\n Just when you thought Pre-Claim Review was in your rearview mirror, Medicare has put the reviled prepayment review program back in the fast lane.<\/p>\n On May 29, the\u00a0Centers for Medicare & Medicaid Services\u00a0<\/strong>issued a\u00a0Federal Register\u00a0<\/em>information collection proposal notice signaling its intent to resurrect PCR. \u201cCMS proposes initially implementing the demonstration in Illinois, Ohio, North Carolina, Florida, and Texas with the option to expand to other states in the Palmetto\/JM jurisdiction,\u201d says the notice published in the May 31\u00a0Federal Register<\/em>.<\/p>\n This proposal took many industry experts, who thought PCR was essentially dead, by surprise.<\/p>\n Reminder:<\/span>\u00a0<\/strong>The original PCR demo began in Illinois Aug. 3, 2016, and was set to begin in Florida in April 2017 and then expand to the remaining three states of Texas, Massachusetts, and Michigan. But CMS \u201cpaused\u201d PCR in Illinois and averted its implementation in Florida at the last minute on March 31, 2017.<\/p>\n The halt came after significant political pressure, including a letter to CMS from Florida lawmakers including U.S. Sen.\u00a0Marco Rubio\u00a0<\/strong>(R) and proposed federal legislation on the matter.<\/p>\n Now over a year later, CMS is back with a revised proposal.<\/p>\n Difference #1:<\/span>\u00a0<\/strong>CMS has swapped out two of the states proposed for inclusion in the demo. Instead of the original Illinois, Florida, Texas, Massachusetts, and Michigan, CMS wants to implement PCR in Illinois, Florida, Texas, Ohio, and North Carolina. That would trade the two states not served by HHH Medicare Administrative Contractor\u00a0Palmetto GBA\u00a0<\/strong>for two that are,\u00a0National Association for Home Care & Hospice\u00a0<\/strong>President\u00a0William Dombi <\/strong>says.<\/p>\n Difference #2:<\/span>\u00a0<\/strong>In the previous version of PCR, HHAs had to submit claims for prepayment review or take a 25 percent penalty (after an initial grace period). In the currently proposed version, \u201cproviders in the demonstration states may participate in either 100 percent pre-claim review or 100 percent postpayment review,\u201d the notice says.<\/p>\n Difference #3:<\/span>\u00a0<\/strong>CMS specifies that agencies that perform well won\u2019t be on PCR forever. \u201cProviders will continue to be subject to a review method until the HHA reaches the target affirmation or claim approval rate,\u201d CMS explains in the notice.<\/p>\n \u201cOnce a HHA reaches the target pre-claim review affirmation or post-payment review claim approval rate, it may choose to be relieved from claim reviews, except for a spot check of their claims to ensure continued compliance.\u201d<\/p>\n PCR Imposes Heavy Burden For Little Gain<\/strong><\/span><\/p>\n While Medicare has made some tweaks to the program, they aren\u2019t enough to relieve the heavy burden PCR will impose. \u201cResurrecting PCR would undoubtedly be a significant administrative and cost burden for providers already operating on razor-thin and ever-reducing reimbursement rates,\u201d says the\u00a0Home Care Association of Florida\u2019s Kyle Simon<\/strong>. \u201cMuch less burdensome approaches are available to CMS as the vast majority of \u2018improper payments\u2019 are due to minor documentation errors or omissions.\u201d<\/p>\n Reinstating PCR \u201cis a significant imposition of administrative cost for the providers,\u201d says consultant\u00a0Joe Osentoski\u00a0<\/strong>with\u00a0QIRT\u00a0<\/strong>in Troy, Michigan.<\/p>\n \u201cAny medium-size and up provider had to essentially dedicate at least one full-time employee to handle the prior version.\u201d Nothing about the program revisions will improve that, Osentoski expects.<\/p>\n PCR\u2019s burden will translate into access problems for patients, Dombi warns. \u201cThe program will be very costly to HHAs, as each claim would be subject to complex medical review that will involve significant paperwork and time for the HHAs,\u201d he says. PCR is likely to \u201ctrigger a \u2018chilling effect,\u2019 dissuading HHAs from serving Medicare patients,\u201d he fears.<\/p>\n HHAs in Illinois are hopeful that their PCR workload may be lifted due to the state\u2019s previous participation in the demo. \u201cMany of our agencies achieved 100 percent affirmation rates the last time,\u201d says\u00a0Sara Ratcliffe<\/strong>, executive director of the\u00a0Illinois HomeCare & Hospice Council<\/strong>. \u201cWill that be taken into consideration for this round? If so, the impact may be lessened but still it will be a disruption and another burden to comply with on the heels of implementing the new Home Health Conditions of Participation.\u201d<\/p>\n Another big change agencies must grapple with in the near future is Medicare payment reform, Simon adds.<\/p>\n Plus:\u00a0<\/strong><\/span>\u201cFlorida home health providers are disproportionately subjected to too many complex and burdensome Medicare pilot programs and demonstrations, including the Home Health Value-Based Purchasing Model, which is in effect in nine states,\u201d Simon notes.<\/p>\n And all this burden doesn\u2019t really achieve much, Simon maintains. The original PCR demo in Illinois \u201cdid not result in any substantive fraud or abuse findings; rather it turned into an audit of documentation,\u201d he says.<\/p>\n Note: The Federal Register notice is at\u00a0www.gpo.gov\/fdsys\/pkg\/FR-2018-05-31\/pdf\/2018-11492.pdf<\/a>.<\/em><\/p>\n Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":"