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Postpayment review limits your documentation improvement options.<\/em><\/strong><\/span><\/p>\n Don\u2019t expect the changes in the Pre-Claim Review program to significantly ease the program\u2019s burden. Many problems continue to accompany the proposed demonstration project.<\/p>\n For example:<\/span>\u00a0<\/strong>In the revised PCR proposal, the\u00a0Centers for Medicare & Medicaid Services\u00a0<\/strong>would allow home health agencies to use 100 percent prepay or postpay review (see story, p. 162 in pdf<\/em>).<\/p>\n That doesn\u2019t really help matters, because most of the burden lies in gathering and furnishing to the Medicare Administrative Contractor reviewer the supporting documentation. Whether pre- or postpay, \u201cagencies will still have to gather and submit all of the information,\u201d points out\u00a0Sara Ratcliffe\u00a0<\/strong>with the\u00a0Illinois HomeCare & Hospice Council<\/strong>.<\/p>\n PCR\u2019s burden will persist \u201cbecause the face-to-face\/physician documentation requirement remains nebulous in clarity, inconsistent in its application by CMS\/MACs\/auditors, and labor-intensive for HHAs to obtain from physicians for reimbursement purposes,\u201d stresses the\u00a0Home Care Association of Florida\u2019s Kyle Simon<\/strong>. \u201cThese systemic issues and failures are what should be addressed and corrected, rather than adding an additional burdensome process.\u201d<\/p>\n The choices between pre- or postpay review \u201care in line with a \u2018Hobson\u2019s Choice\u2019 in that all options are problematic,\u201d judges\u00a0National Association for Home Care & Hospice\u00a0<\/strong>President\u00a0William Dombi<\/strong>. \u201cPostpay review may be a slight improvement over prepay review in that the HHA will have money in hand for services rendered with potentially better documentation, given that the care would have been provided allowing for the documentation to show a clear picture on Medicare coverage,\u201d Dombi tells\u00a0Eli<\/strong>. \u201cHowever, postpay reviews can be haunted by 20-20 hindsight in circumstances where the patient does not show the anticipated improvement.\u201d<\/p>\n Even worse:<\/span>\u00a0<\/strong>The option for postpay review \u201cwould severely handicap any ability to obtain or improve the face-to-face documents in the record,\u201d warns consultant\u00a0Joe Osentoski\u00a0<\/strong>with\u00a0QIRT\u00a0<\/strong>in Troy, Michigan. Thus, \u201cno agency in their right mind would risk taking the postpayment option,\u201d he believes. \u201cSo we are back to a repeat of prepayment reviews that hold up billing.\u201d<\/p>\n One good addition to the program is the specification that agencies that perform well will be able to get off review. \u201cWe had agencies that were getting between 90 percent to 100 percent affirmation rates within the first few months of PCR and were still required to submit 100 percent for PCR up until it was paused,\u201d Ratcliffe notes.<\/p>\n Many PCR Questions Remain<\/strong><\/span><\/p>\n However, at press time CMS hadn\u2019t issued any specifics on what performance level would qualify HHAs to be removed from PCR \u2014 or on many other details. One outstanding question was exactly when PCR would go live in which states.<\/p>\n \u201cGiven our experience last time in just one state, it would be a monumental effort to bring all states on at one time,\u201d Ratcliffe says.\u00a0Therefore, she expects PCR to roll out in a staggered fashion.<\/p>\n Since all the newly proposed demo states are served by the same MAC,\u00a0Palmetto GBA<\/strong>, \u201cI would be surprised if all the states could be implemented at once,\u201d Osentoski agrees. \u201cThey would have to be a staggered implementation with lessons learned from early states applied and supplied to later states.\u201d<\/p>\n Presumably, the industry will have at least until the notice comment period closes on July 30 before a PCR start date is announced.<\/p>\n Another area Osentoski would like to see CMS clarify is whether agencies subjected to PCR review will be excluded from other types of review. That is particularly important with the Targeted Probe & Educate program ramping up (see story, this page<\/em>).<\/p>\n What\u2019s next:<\/span>\u00a0<\/strong>NAHC is \u201ckeeping all options open in terms of what we will be doing\u201d in reaction to the PCR proposal, Dombi says. \u201cWe believe that there are much better alternatives than PCR to address any valid concerns on home health claims. The alternatives are much less burdensome and should be more effective.\u201d<\/p>\n Meanwhile, those who oppose the new program have 60 days to comment on the\u00a0Federal Register\u00a0<\/em>notice. \u201cBy being ready to comment and fight this \u2026 we can effect necessary change and allow CMS to know the hardships this proposal will cause,\u201d urges consulting firm\u00a0Kornetti & Krafft Health Care Solutions\u00a0<\/strong>in its member newsletter..<\/p>\n Source- SuperCoder<\/span><\/i><\/a><\/p>\n","protected":false},"excerpt":{"rendered":" Postpayment review limits your documentation improvement options. Don\u2019t expect the changes in the Pre-Claim Review program to significantly ease the program\u2019s burden. Many problems continue to accompany the proposed demonstration … Continue Reading →<\/a><\/p>\n","protected":false},"author":1,"featured_media":78,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[5],"tags":[11,12,13,14],"class_list":["post-286","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-reimbursement","tag-home-care","tag-hospice","tag-ltc","tag-snf"],"_links":{"self":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/286","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/comments?post=286"}],"version-history":[{"count":1,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/286\/revisions"}],"predecessor-version":[{"id":287,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/posts\/286\/revisions\/287"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media\/78"}],"wp:attachment":[{"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/media?parent=286"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/categories?post=286"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/advantagehcconsulting.com\/blog\/wp-json\/wp\/v2\/tags?post=286"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}