KEPRO Contract to End as Ohio BFCC-QIO Effective June 8
Diane Deitz
Effective June 8, 2019, Ohio will have a new Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO). Livanta, which currently serves as the BFCC-QIO for states primarily along the West Coast and New England, will soon serve as Ohio’s BFCC-QIO. BFCC-QIOs offer information and assistance to providers, patients and families regarding Medicare beneficiary complaints and discharge appeals. Apparently Livanta has been awarded the BFCC-QIO contract for not only CMS Region 5 (which in addition to Ohio includes Illinois, Indiana, Michigan, Minnesota and Wisconsin) but also the contract for CMS Regions 2, 3, 7 and 9. KEPRO will serve the other CMS Regions of 1, 4, 6, 8 and 10. Again the effective date of the territory shift is June 8, 2019 and OHCA will share additional information about the transition as it becomes available. To learn more about Livanta, please click here.
CMS Claims Final Rule Will Streamline Medicare Appeals for Providers
Pete Van Runkle
The following article is by AHCA’s Patrick Connole
In a final rule published in the Federal Register on May 7, the Centers for Medicare & Medicaid Services (CMS) clarifies changes it has made to the appeals process in the Medicare program for providers, beneficiaries, and suppliers, which the agency believes will benefit stakeholders by streamlining the process. Titled “Medicare Program; Changes to the Medicare Claims and Medicare Prescription Drug Coverage Determination Appeals Procedures (84 FR 19855),” the rule is effective on July 8. CMS said the final rule revises regulations for appealing “adverse determinations regarding claims for benefits under Medicare Part A and Part B or determinations for prescription drug coverage under Part D.” The changes will reduce administrative burden on providers, suppliers, beneficiaries, and appeal adjudicators, CMS said. “These revisions, which include technical corrections, also help to ensure the regulations are clearly arranged and written to give stakeholders a better understanding of the appeals process.” In response, the long term and post-acute care profession backed the effort. For example, the American Health Care Association (AHCA) said, “AHCA supports efficiencies that facilitate the appeals process, reduce administrative burden, and ensure beneficiaries have access to the appropriate benefits.”
Some of the changes involve removing redundant steps in the appeals process, addressing which entities have to sign an application for an appeal, and condensing the time frame for action, among other measures in the new rule, CMS said. To read the rule, go to the Federal Register.
MDS Submission Reminders
Pete Van Runkle
Terry Moore of the Department of Medicaid asked us to remind members to include the center’s Medicaid provider number on all MDS submissions, even if the patient is in a non-Medicaid stay or is not a Medicaid patient. The department identifies Medicaid patients and stays by different indicators. She added that the state identification (license) number or the National Provider Identifier should not be used in this field. Ms. Moore also asked us to remind members that weekly MDS reports are available under the correspondence tab in the MITS portal so centers do not need to wait until the end of the quarter to check the accuracy of their MDS submissions. Once the weekly report is downloaded, it must be saved locally if needed for future reference because it disappears from the portal.
ODM Audit Reports for SFYs 2015-2016
Pete Van Runkle
Last week, the Department of Medicaid (ODM) sent SNFs across the state letters with audit (overpayment) reports covering State Fiscal Years 2015 and 2016. It is very important that any provider receiving a report respond to Medicaid using their form within 30 days. The response does not have to be accompanied by supporting documentation. A request for further review is sufficient, but it must be in by the deadline. The auditor then will work with the center to establish a schedule for providing documentation. Also, ODM this year is sending “no findings” letters to qualifying SNFs. OHCA long advocated for this step so members know where they stand. We appreciate ODM’s Mark Graves for implementing it.
CGS J15 Claims Issues Log
Diane Deitz
CGS has updated its J 15 Claims Processing Issues Log which provides a list of current, system-related claims processing issues. You will note, among other issues, that the Medicare Part B payment allowances for HCPCS code Q2038 (flu vaccine) is not yet available. We encourage facility billers to bookmark these pages and reference often.
SNF Provider Preview Reports - Now Available
Mandy Smith
CMS reports that Skilled Nursing Facility (SNF) Provider Preview Reports have been updated and are now available. The data contained within the Preview Reports is based on quality data submitted by SNFs between Quarter 4 – 2017 and Quarter 3 – 2018, for assessment-based quality measures, and between Quarter 1 – 2017 to Quarter 4 – 2017, for claims-based quality measures. Providers have until May 30, 2019 to review their performance data prior to the July 2019 Nursing Home Compare site refresh, during which this data will be publicly displayed. Corrections to the underlying data will not be permitted during this time; however, providers can request CMS review of their data during the preview period if they believe the quality measure scores that are displayed within their Preview Reports are inaccurate. For more information please go to the CMS SNF Quality Public Reporting webpage, NH Compare website, and Preview Report Access Instructions.
Restorative Nursing - MDS Exception Review
Mandy Smith
Recently OHCA heard from a provider experiencing an exception review that the RN assessment documentation for the initial assessment they had was not sufficient. As a reminder, this documentation needs to be performed by an RN and be clearly signed to initiate the program.
Per the MDS 3.0 RAI Manual and the CMS SOM, a restorative nursing program refers to nursing interventions that promote the resident’s ability to adapt and adjust to living as independently and safely as possible. This concept actively focuses on achieving and maintaining optimal physical, mental, and psychosocial functioning. A resident may be started on a restorative nursing program when he or she is admitted to the facility with restorative needs, but is not a candidate for formalized rehabilitation therapy, or when restorative needs arise during the course of a longer-term stay, or in conjunction with formalized rehabilitation therapy. Generally, restorative nursing programs are initiated when a resident is discharged from formalized physical, occupational, or speech rehabilitation therapy. The resident/representative must be included in the development of the restorative/rehabilitative care plan and provided the risks and benefits of the treatments. The comprehensive assessment must identify the current status of the resident’s ROM and mobility capabilities, which must be used to develop interventions. The decision on what type of treatments includes an evaluation of the cognitive ability of the resident to be able to independently participate, whether the resident requires assistance due to medical condition or cognitive impairments or loss of ability to follow treatment instructions. Care plan interventions may be delivered through the facility’s restorative program.
The following criteria for restorative nursing programs must be met in order to code O0500:
- Measureable objective and interventions must be documented in the care plan and in the medical record. If a restorative nursing program is in place when a care plan is being revised, it is appropriate to reassess progress, goals, and duration/frequency as part of the care planning process. Good clinical practice would indicate that the results of this reassessment should be documented in the resident’s medical record.
- Evidence of periodic evaluation by the licensed nurse must be present in the resident’s medical record. When not contraindicated by state practice act provisions, a progress note written by the restorative aide and countersigned by a licensed nurse is sufficient to document the restorative nursing program once the purpose and objectives of treatment have been established.
- Nursing assistants/aides must be trained in the techniques that promote resident involvement in the activity.
- A registered nurse or a licensed practical (vocational) nurse must supervise the activities in a restorative nursing program. Sometimes, under licensed nurse supervision, other staff and volunteers will be assigned to work with specific residents. Restorative nursing does not require a physician’s order. Nursing homes may elect to have licensed rehabilitation professionals perform repetitive exercises and other maintenance treatments or to supervise aides performing these maintenance services. In situations where such services do not actually require the involvement of a qualified therapist, the services may not be coded as therapy in item O0400, Therapies, because the specific interventions are considered restorative nursing services (see item O0400, Therapies). The therapist’s time actually providing the maintenance service can be included when counting restorative nursing minutes. Although therapists may participate, members of the nursing staff are still responsible for overall coordination and supervision of restorative nursing programs.
OHCA has an upcoming program on restorative titled Developing and Implementing Restorative Nursing Programs, which will be held at the OHCA office May 23, 2019 and August 22, 2019. You can find more information here.
Hospice Room and Board Billing Change; Aetna Notification
Pete Van Runkle
Effective July 1, 2019, the Department of Medicaid (ODM) is requiring MyCare Ohio managed care plans to switch from direct payment of hospice room and board claims to the SNF to the traditional method of paying the hospice, which in turn forwards the payment to the SNF. Three plans – Molina Healthcare, Aetna Better Health of Ohio, and United Health Care – currently pay SNFs directly for hospice room and board, reducing the administrative burden on hospices and SNFs. According to ODM, this change is required by federal law, notwithstanding that MyCare plans have been permitted, with ODM’s full knowledge, to make direct payments since the beginning of the duals demonstration in 2014. Look for information from the affected plans about the switchover. Aetna Better Health of Ohio shared with OHCA their notification to SNFs and hospice providers explaining the new billing process. Aetna’s Jason Smith wrote: “[w]e have posted our notice about the upcoming change on individuals receiving Hospice in a SNF and how room and board is to be billed. We plan to send this to SNFs by early next week but posted it online early. Additionally, we are mailing a hard copy to hospice providers. We are going to have our provider liaisons out in the field go out between now and June 30 to SNFs to make sure they are aware of the notice and billing change. The change will take effect July 1.” OHCA is working with the Ohio Council for Home Care and Hospice on a budget amendment to mandate that the state allow SNFs to bill for room and board, but it did not get into the House version of the budget.
Home Care: Renewal of the HHCCN
Erin Begin
Article from NAHC
The Office of Management and Budget (OMB) has approved the Home Health Change of Care (HHCCN) Form, CMS-10280. Effective July 1, 2019, all Home Health Agencies (HHA) will be required to use the renewed form with the expiration date of 4/30/2022 on the bottom. Please note that HHAs may continue to use the old form up until July 1, 2019 but we encourage HHAs to begin transitioning to the renewed form. There have been no changes made to the form. HHAs may find the form and the form instructions in the download section of the website.
Home Care: Legislation to Stop PDGM Rate Cuts Introduced in the House of Representatives
Erin Begin
On May 8, a legislative effort backed by NAHC was introduced to reduce the 6.42% base rate cut for Home Health services under PDGM. The reduction is based on assumptions of expected behavioral changes from the Home Health Agencies. The legislation asserts that the rate changes should be based on actual behavioral changes and also requires that no more than 2% reductions in rate occur in any given year. To learn more, access the full article here.
Hospice: Hospice Care Inclusion for Medicare Advantage
Erin Begin
Earlier this year, CMMI announced that it will begin testing hospice under Medicare Advantage starting in CY2021. In April, 2019, CMS confirmed that it would not unbundle Hospice Care under Medicare Advantage benefit. They also addressed provider concerns regarding access to care, stating that the Medicare Advantage PPO patients will have access to all Hospice Care providers. This does not, however, address issues with HMO or other restrictive network Managed Care Plans. CMS has affirmed that they will not interfere with Medicare Advantage Contracting. There has been an RFI issued to the provider community on recommendations to preserve the integrity of the hospice benefit and voice concerns regarding access to care.
Hospice: FY2020 Proposed Hospice Wage Index and Payment Rate Update Now Available
Erin Begin
On April 25, 2019, the Department of Health and Human Services released its proposed changes to the Hospice Payments for FY2020. Major changes include rate increases from Continuous Home Care, Inpatient Respite and General Inpatient levels of care, with a reduction for Routine Home Care by 2.71%, which comprises a large majority of hospice services billed in the state of Ohio. The rule also includes a major change to the election statement requirements, in an effort to provide transparency to patients and caregivers regarding non-covered services. You can view the full report here.
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Managed Care/Home Health/SNF: Medical Mutual of Ohio Notice of Changes in Prior Authorization Requirements
Erin Begin
Medical Mutual of Ohio recently released a notification to its contracted providers stating that all prior authorizations, with the exception of pharmaceutical, chiropractic services, therapies and radiology, will be required to go through Navinet effective June 1, 2019. They have since clarified that the current practice of Skilled Nursing facility authorization requests will also be excluded, and will continue to be submitted through ReviewLink. Additionally, Home Health Care therapies are not considered excluded, and should be submitted through Navinet. Outpatient or Part B Physical, Occupational and Speech therapies will continue to be submitted through Evicore (as needed), as described in the original notice, which can be accessed here.
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Medicaid Proposes Changes to EVV Rule
Debbie Jenkins
The Ohio Department of Medicaid has proposed changes to OAC 5160-1-40 Electronic Visit Verification (EVV). The rule is actually being rescinded and a new rule with the same name and number is being brought forth. Key changes include the addition of PASSPORT, managed care (both traditional and MyCare Ohio) and ID/DD IO and Level One waiver services, additional language regarding the data collection application and updated training requirements. Please send any comments on the proposed rule to Debbie Jenkins.
Also, remember that Phase 2 EVV training is now available. You can register for training on the ODM website. Training is available in classroom sessions, instructor led webinars or self-paced online modules. As soon as a representative from your agency completes the training, you will be able to begin ordering EVV devices for your clients and training staff. Once staff are trained and devices are received (if you are utilizing the Sandata device), staff can begin utilizing EVV. It will be mandatory for providers to meet the EVV requirements in August, so the sooner staff begin to use the system, the more time they will have to get over the learning curve and accurately comply with these regulations.
Technical Issues Disrupt EVV Phase 2 Webinar
Debbie Jenkins
OHCA has been made aware of technical issues with the first instructor-led webinar for EVV Phase 2 training that was held on Wednesday May 8. Apparently, Sandata had some hick-ups with audio and by the time they were resolved most of the participants hung up. If you attempted to participate in the May 8th webinar and were unable to hear the presentation in its entirety, please contact the EVV Provider Hotline at 855-805-3505 to reschedule your webinar.
National Skilled Nursing Care Week Begins Sunday, Mother's Day
Steve Mould
National Skilled Nursing Care Week (NSNCW) is next week, May 12-18. The 2019 theme is "Live Soulfully," which will celebrate skilled nursing centers, and their residents and staff, by showcasing how they achieve happy minds and healthy souls. Every day, skilled nursing centers assist frail, elderly, and disabled individuals in living their happiest lives. Whether it's planting, cooking, reading or listening to music, staff at our nation's centers pay it forward by dedicating themselves to improving quality of life for residents. AHCA has several resources at ahcancal.org/NSNCW to help you celebrate NSNCW, including graphics, a planning guide, sample social media posts, newsletter template, and more. Use the hashtag #NSNCW on social media to share how you're celebrating and follow us on Facebook here and Twitter here. Be sure to save your best photos for submission to the OHCA Photo Contest later this year!
Why Members Should Consider HealthCap for their Professional Liability Needs
Diane Deitz
OHCA wants to take this opportunity to remind our members that AHCA/OHCA have a preferred partnership with HealthCap to offer our members the highest quality professional liability coverage for competitive, discounted pricing. Why did AHCA/OHCA endorse HealthCap and why should you, as a member, consider their service? Because HealthCap is the premier program solely dedicated to providing liability insurance to senior care communities since 2001. HealthCap clients have both lower claims frequency and lower claims severity than other major liability insurance carriers. Their integrated risk management approach helps their clients have the fewest claims in the industry. When claims do occur, HealthCap settles for half the industry average. The company is owned and governed by its members – the senior care communities HealthCap insures. HealthCap has grown to a top-5 liability insurance provider to the long-term care sector since 2001 with more than 1,900 insured communities. Plus AHCA/OHCA members receive a 10% discount on their HealthCap premiums. HealthCap clients also receive: risk management services that make a financial difference, an annual on-site risk consult, unlimited telephone support, accredited in-service education, access to their Resource and Education Center and access to QA Reader – HealthCap’s innovative risk management service. To learn more about HealthCap, please contact Michael Kalamanor Clete Richardson, 614-224-0772.
OHCA Regional Meeting Scheduled for May 17 in Warren
Kathy Chapman
OHCA Regional Meetings are specifically designed to give the busy long-term services and supports professional, in a brief but informative luncheon program, an opportunity to learn about key topics affecting assisted living and skilled nursing providers today and to interact with OHCA staff. OHCA Regional Meetings will be held the third Friday of each month. The next meeting is scheduled for May 17 in Warren, Ohio at The Avalon Inn and Resort. Please see the remaining 2019 schedule below. Each Regional Meeting begins at 11:30 a.m. and will include:
- An update from OHCA staff or invited guest speakers
- An open forum for Q&A, feedback, and general discussion
- A shared meal
- 1.5 CEs for NHAs, CEALs, Nurses, and Accountants
Please watch for information in your email and in Bites; registration and additional details are available at www.efohca.org.
- December 20 – Findlay
- November 15 – Akron
- October 18 – Dayton
- September 20 – Bellville
- August 16 – Cambridge
- July 19 – Independence
- June 21 – Perrysburg
- May 17 – Warren
Free Dementia, Compassionate Touch Training Available for Nursing Facility Staff
Kathy Chapman
AGE-u-cate Training Institute (www.AGEucate.com) has been awarded $760,189 in Civil Monetary Penalty funding by CMS to help 140 Ohio nursing facilities improve care to residents with dementia. The three-year project is to improve the quality of care and quality of life of long stay nursing facility residents in Ohio who have dementia or dementia-related conditions. This will be achieved with Dementia Live, an experiential learning program simulating cognitive and sensory impairments, giving participants a real life experience of living with dementia. The program includes:
- On-site Dementia Live Training -- ATI trainer will come to the facility to conduct the Dementia Live Experience (simulation) followed by Empowerment/ Skills Development session for direct-care and support staff.
- DL On-line Coach Training (Train-the-trainer component) -- Following onsite training, two to four staff are enrolled in online Coach Training.
- In-House DL Training -- DL Coaches facilitate on-going in- house training for additional staff and family caregivers.
- Results Measurement and Reporting -- ATI will collaborate to identify the impact on approximately ten residents who have dementia and exhibit physical, verbal or other behavioral symptoms and/or resistance to care.
- Project Support -- To help ensure sustainable success, you will receive support in the form of on-line and phone support and updated supplemental materials.
An additional $688,000 was awarded for “Compassionate Touch: A Practical Approach to Ease Behavioral Symptoms.” This project will directly benefit nursing home residents in 140 Ohio facilities by providing non-pharmacological strategies, i.e. skilled touch techniques and specialized communication, which will strike at the underlying causes of negative, behavioral expression in participating residents: improving their overall quality of life. Compassionate Touchâis an approach combining skilled touch and specialized communication shown to prevent behavioral expression in people with dementia and reduce job stress in care-partners.
For details and more information please click here or contact Mary Petersen, Manager of Strategic Projects 817-857-1157.
National Emerging Leadership Summit
The 10th annual National Emerging Leadership Summit (NELS) for Health and Aging Services Executives will be held in Washington, D.C. from July 16 – 18, 2019. The three-day summit, unique in its kind, is geared towards the enrichment of leadership skills for emerging health service executives working in skilled nursing facilities, assisted living centers, continuing care retirement communities, life plan communities, rehabilitation hospitals, home- and community-based services, and more. Summit participants will enjoy an engaging, interactive experience that is focused on hearing their voice and helping them grow professionally, all while crafting solutions to improve the field of health and aging services and the profession of administration and leadership therein. The complete Summit package includes approximately 19 CE credits for administrators from the National Association of Long-Term Care Administrator Boards (NAB), admission to all speaker events and presentations, breakfast and lunch each day, a reception with past NELS attendees and leaders in health and aging services, and a unique Washington, D.C. group event and dinner one evening. Lodging information at the host hotel, with the NELS discounted rate, will be provided upon application and acceptance (each participant will reserve his/her own room in the room block). For more information and how to apply to attend the 2019 NELS Summit, please visit the NELS website.
Other Upcoming Educational Programs
Kathy Chapman
OHCA is sending a regular email listing upcoming educational programs to avoid cluttering members' email with individual programs; please check the www.efohca.org website for details on the listed programs and check regularly for complete program listings.
- The Essential MDS 3.0 Course -- May 21, 22 / Lewis Center / CEs: 11
- Developing and Implementing Restorative Nursing Programs -- May 23 / Lewis Center / CEs: 6
- Mental Health: Caring for Residents with Bi-Polar Disorder & Personality Disorders -- May 28 / Webinar / CEs: 1
- How to Prepare a Business for Sale: A Three-Year Game Plan June 5 / Webinar / CEs: 1
- Managing Reimbursement and Quality Metrics -- June 6, 7 / Lewis Center / CEs: 13
- The Millennial in the Backseat -- June 12 / Webinar / CEs: 1
- Assisted Living (RCF) Rules & Survey Preparedness -- June 18 / Warren / CEs: 6
In the News
Steve Mould
OHCA is providing In the News, a summary of stories of interest to busy LTC Administrators and others in 100-words-or-less. The compilation is provided by Drew Vogel, CNHA, FACHCA, a long-time OHCA member with nearly 30 years' experience as an administrator. Prior to that he spent 25 years as a radio reporter, honing his skill at condensing news reports. As the Ohio Mentoring Coordinator for the American College of Health Care Administrators Drew provides this compilation to ACHCA members nationally and is making it available to OHCA members, as well. The latest issue is available here, and on the OHCA Website here.
Association News/Services
Congressional Briefing: Online Registration Deadline Extended
Steve Mould
If you have not yet registered for this year's AHCA Congressional Briefing June 3-4 in Washington, DC, it is not too late. The online registration deadline has been extended to May 13. The Congressional Briefing provides two invaluable days of networking with your colleagues; in-person meetings with your Members of Congress; updates on what's happening in Washington; excellent speakers and guests. You can also earn CEs! For details and registration please go to Congressional Briefing.
Save $100 on AHCA LTC Career Center Job Postings
Steve Mould
Is your organization seeking high-quality, professional individuals to be a part of your team? Expand your exposure through the LTC Career Center today! The Center offers a national network of nearly 300 health care associations with millions of members. Through May 31, AHCA is offering members a savings of $100 on your job posting with Promo Code GRAD100. Your final price for national network exposure:
- $250 for a 30-day Posting (with promo code)
- $500 for a 90-day Posting (with promo code)
There is no limit on the number of times the code can be used. For details, please go to the AHCA LTC Career Center.
Deficiency Free Facilities
Steve Mould
As part of an ongoing effort to recognize member facilities for their quality improvement efforts, the Association recognizes members that have completed their annual survey with no deficiencies. Please be aware that ODH has suspended its practice of sending providers deficiency free letters, and no longer provides OHCA a list of deficiency free surveys so that we can recognize our members who achieve this success. OHCA would like providers to notify the association if they have a health and LSC deficiency free survey by contacting OHCA Communications Director Steve Mould and providing him their 2567 report. For recognition from OHCA, deficiency free is considered having no citations in certification, licensure and life safety code. To order "We' re Deficiency Free!" buttons for your staff, please download the order form and mail or fax your order to the Association offices.
Heroes Needed!
Steve Mould
Nominate your Hero of Long-Term care today! The OHCA Heroes of Long-Term Care program honors individual long-term care employees for their service to residents, the facility, and to their community. Heroes are nominated from long-term care employees across the state. The program is also intended to provide good news opportunities for use in local and statewide markets. Program details and copies of the Heroes of Long-Term Care nomination form are available at Heroes of Long-Term Care.
Free Job Posting Available to Members
Steve Mould
Members may post openings in the "Job Opportunities" section of the OHCA website for 30 days at no cost. To post an opening, go to the Long Term Care Careers page at www.ohca.org log in and post the job through your account. You will need to be logged into the site with your user name and password before you attempt to post a position. For additional information contact Stephen L. Mould, APR (smould@ohca.org), 614/540-1325.
OHCA News Bites
OHCA News Bites is distributed electronically each week (except for holidays and special occasions). Member representatives who would like to be added to or deleted from the distribution list should send an email to Debbie Jamieson (djamieson@ohca.org), including the individual's name, company, and email address. Individuals will be added to the email listing for all of OHCA's electronic bulletins and publications.