3.1
3.1 Statutory
Background
3.1.1 Under Title
10, United States Code (USC), Section 1079(i)(2), the amount to
be paid to hospitals, Skilled Nursing Facilities (SNFs), and other
institutional providers under the TRICARE program, “shall be determined
to the extent practicable in accordance with the same reimbursement rules
as apply to payments to providers of services of the same type under
Medicare.” Section 701 of the National Defense Authorization Act
for Fiscal Year 2007 (NDAA FY 2007) (Public Law 107-107) (December
28, 2001), added a new Section 10 USC 1074j, establishing a comprehensive,
part-time or intermittent home health care benefit to be provided
in the manner and under the conditions described in Section 1861(m)
of the Social Security Act (SSA) (42 USC 1395x(m)).
3.1.2 In the Calendar Year (CY)
2019 HH PPS Rate Update final rule (CMS-1689-FC), the Centers for Medicare
and Medicaid Services (CMS) finalized an alternative case-mix methodology
now called the PDGM which includes the payment reform requirements
mandated in section 51001 of the Bipartisan Budget Act of 2018 (BBA
of 2018), for home health services beginning on or after January
1, 2020. This rule also finalized a change in the unit of payment
from 60-day episodes of care to 30-day periods of care, and the
elimination of therapy thresholds for use in determining home health
payment, as required by section 51001 of the BBA of 2018. Based
upon the statutory provisions in the paragraph 3.1.1, DHA adopts
Medicare’s benefit structure and PPS for reimbursing HHAs that are
currently in effect under the Medicare program.
3.2 Reimbursement
3.2.1 Effective for periods of care
on or after January 1, 2020, the original HHA PPS case-mix system
is replaced with a new case-mix classification model known as PDGM.
Under the PDGM, a case-mix adjusted payment for a 30 day period
of care is made using one of 432 unique case-mix groups which are
called Home Health Resources Groups (HHRGs). These HHRGs are represented
as Health Insurance Prospective Payment System (HIPPS) codes. The
PDGM assigns the 30-day period of care into one of 432 case-mix
groups based upon the following five components:
• Timing: The first
30-day period of care is an early period of care. The second or
later 30-day period of care is a late period of care;
• Admission Source:
Admissions sources are either community or institutional. If the patient
was referred to home health from the community or an acute or post-acute care
referral source (inpatient, skilled nursing, inpatient rehabilitation
facility, long term care hospital, inpatient psychiatric facility)
in the 14 days prior to the HH admission;
• Clinical Group: The
primary reason the patient requires home care, represented by 12 distinct
clinical groups as determined by the principal diagnosis reported
on the home health claim;
• Functional Impairment
Level: The patient’s functional impairment level is based upon eight
Outcome and Assessment Information Sets (OASIS) items for activities
of daily living, the 30-day period of care shall be put into one
of three functional levels low, medium or high; and
• Comorbidity Adjustment:
If the patient has certain comorbid conditions/secondary diagnoses
reported on the home health claim, the 30-day period of care shall
receive a no, low, or high comorbidity adjustment.
3.2.2 The new case-mix model, PDGM,
for the HHA PPS shall apply to HHAs in all 50 states, District of
Columbia, Puerto Rico, U.S. Virgin Islands, and Guam.
3.2.3 Reimbursement shall follow
Medicare’s methodology, and revenue code 023 shall continue to be
present for all HHA PPS TRICARE Encounter Data (TEDs) in addition
to all other revenue code information pertinent to the treatment.
See the TRICARE Systems Manual (TSM),
Chapter 2, Addendum H for a list of valid
revenue codes. In addition, under the TRICARE HHA PPS all HH TEDs
shall be coded with Special Rate Code
V Medicare Reimbursement
Rate or Special Rate Code
D for a Discount Rate Agreement.
3.3 Composition Of HIPPS Codes
Under The PDGM
3.3.1 The distinct
five-position, alphanumeric HH HIPPS codes are created as follows:
• First
Position - A numeric value representing a combination of the referral
source (community or institutional) and the period timing (early
or late).
• Second
and Third Positions - Represents the clinical and functional domains
of the HHRG coding system.
• Fourth Position -
Represents the co-morbidity category that applies to the patient.
• Fifth Position - A
placeholder for future use, required only because the field used
to report HIPPS codes requires five positions.
position
#1
|
position
#2
|
position
#3
|
position
#4
|
position
#5
|
Source
& Timing
|
Clinical
Group
|
Functional
Level
|
Co-Morbidity
|
Placeholder
|
1 - Community
Early
|
A - Medial Management,
Teaching and Assessment (MMTA) Other
|
A - Low
|
1 - None
|
1
|
2 - Institutional
Late
|
B - Neuro Rehab
|
B - Medium
|
2 - Low
|
|
3 - Community
Late
|
C - Wounds
|
C - High
|
3 - High
|
|
4 - Institutional
Late
|
D - Complex
Nursing Interv.
|
|
|
|
|
E - MS Rehab
|
|
|
|
|
F - Behavioral
Health
|
|
|
|
|
G - MMTA Surgical
Aftercare
|
|
|
|
|
H - MMTA Cardiac
& Circulatory
|
|
|
|
|
I - MMTA Endrocine
|
|
|
|
|
J - MMTA GI/GU
|
|
|
|
|
K - MMTA Infectious
Disease
|
|
|
|
|
L - MMTA Respiratory
|
|
|
|
3.3.2 Using this structure, a second
period for a patient with a hospital inpatient stay during the period
(institutional late), in the Wounds group, high functional severity
and no co-morbidity shall be coded 4CC11. HIPPS codes
shall continue to be reported with revenue code 0023.
3.4 Unit of Payment
3.4.1 The episode or period of care
is the unit of payment for HHA PPS. The episode/period of care payment
is specific to one individual homebound beneficiary. It shall pay
all TRICARE covered home health services for the patient’s care,
including routine and non-routine supplies (NRS) used by that beneficiary
during the episode/period of care, with the exception of those services
described in Section 2. A beneficiary may be covered for an unlimited
number of non-overlapping episodes or periods of care.
3.4.2 For episodes beginning before
January 1, 2020, the duration of a single full-length episode is
60 days. Episodes may be shorter than 60 days. For home health services
that start on or before December 31, 2019, and end on or after January
1, 2020, episodes that span into 2020, the payment of unit shall
be the CY 2020 national, standardized 60-day episode payment amount,
and shall be case-mix adjusted using the CY 2019 HHA PPS case-mix
weights as posted on the CMS HHA Center website at
https://www.cms.gov/Center/Provider-Type/Home-Health-Agency-HHA-Center.html.
• For
such 60-day episodes, that are not classified as Low Utilization
Payment Adjustment (LUPA) episodes, which span into CY 2020, the
latest the 60-day episode payment amount shall cover is an episode
ending on February 28, 2020. If there is a continued need for home
health services at the end of the 60-day episode, any subsequent periods
of care shall be reimbursed at the 30-day national, standardized
payment amount, and adjusted using the appropriate CY PDGM case-mix
weight.
3.4.3 For periods of care beginning
on or after January 1, 2020, the duration of a period is 30 days.
Periods of care may be shorter than 30 days. Effective for periods
of care beginning on or after January 1, 2020, the payment of unit
shall be the CY 2020 national, standardized 30-day payment amount.
3.4.4 Under the PDGM, there are
no changes to the certification/recertification, completion of OASIS
assessments, or updates to the patient’s plan of care, all of which
shall continue on a 60-day basis
3.5 Split Percentage Payments
And Requests For Anticipated Payments (RAPs)
3.5.1 HHAs certified for participation
in Medicare on or after January 1, 2019, shall be responsible for
no longer submitting split-percentage or RAP payments. HHAs that
are certified for participation in Medicare effective on or after
January 1, 2019, shall still be required to submit a “no pay” RAP
at the beginning of care to establish the home health period of
care, as well as, every 30 days thereafter upon implementation of
the PDGM.
3.5.2 Existing HHAs, meaning those that certified
for participation in Medicare prior to January 1, 2019, shall continue
to receive RAP payments upon implementation of the PDGM. For split
percentage payments to be made, existing HHAs shall submit a RAP
at the beginning of each 30-day period of care. For 30-day periods
of care beginning on or after January 1, 2020, the upfront spilt
percentage payment shall be 20 percent for each 30-day period. Additionally,
contractors are not required to verify if the date the HHA certified
for participation with Medicare was before or after January 1, 2019.
3.5.3 The percentage payment for
the RAP shall be based upon the HIPPS code as submitted. Upon receipt
of the corresponding claim, grouping to determine the HIPPS code
used for final payment of the period of care shall occur at HHAs.
3.5.4 HHAs shall submit RAPs in
accordance with the policies and instructions set forth in the CMS
Internet-Only Manuals (IOM) Publication # 100-04, Medicare Claims
Processing Manual (CPM), Chapter 10, Section 40.1.
3.6 LUPA
3.6.1 For periods of care beginning
on or after January 1, 2020, if an HHA provides fewer than the threshold
of visits specified for the period’s HHRG, they shall be paid a
standardized per visit payment instead of a payment for a 30- day
period of care. This payment adjustment is called a LUPA. Under PDGM
each of the 432 case-mix groups has a visit threshold ranging from
two to six visits to determine whether the period of care meets
the LUPA threshold.
3.6.2 Under PDGM, if the LUPA threshold is met, the
30-day period of care shall be reimbursed at the full 30-day national,
standardized payment amount listed in
Addendum C (CY 2020), Figure 12.C.2020-3.
For periods of care that do not meet the LUPA visit threshold, reimbursement
shall be at the appropriate CY per-visit payment amount. For example:
If the LUPA visit threshold is three, and a period of care has two
or less visits, it shall be classified as a LUPA and reimbursed
at the per-visit amount. If the visit is three or more, then it
shall not be classified as a LUPA and reimbursement shall be the
full 30-day payment amount. Therefore, periods of care with one
visit are considered LUPA claims, and also reimbursed at the per-visit
payment amount.
3.6.3 The HH pricer software, which is used to process
all HHA PPS claims and operates as a call module within the contractors’
claims processing system, maintains national standard visit rate
tables that shall be used in outlier and LUPA determinations. The
contractors shall process and pay LUPA claims based upon the guidance
and methodologies set forth in the Medicare CPM, Chapter 10 “Home Health
Agency Billing”.
3.7 Benefits
And Condition Of Coverage
3.7.1 To qualify for home health benefits, a beneficiary
must meet the following requirements:
• Be confined to the
home;
• Under
the care of a physician;
• Receiving services
under a plan of care established and periodically reviewed by a physician;
and
• Be
in need of skilled nursing care on an intermittent basis or physical
therapy or speech-language pathology; or
• Have a continuing
need for occupational therapy.
3.7.2 For HHA services to be covered,
the individualized plan of care shall specify the services necessary
to meet the patient-specific needs identified in the comprehensive
assessment. In addition, the plan of care shall include the identification
of the responsible discipline(s) and the frequency and duration
of all visits as well as those items listed in the CMS IOM Publication
# 100-02, Medicare Benefit Policy Manual, Chapter 7 “Home Health
Services”, that establish the need for such services. All care provided
shall be in accordance with the plan of care.
3.7.3 All requirements outlined
in
Sections 1 and
2 shall continue
to apply to periods of care beginning on or after January 1, 2020.
3.8 Consolidated Billing
3.8.1 Section 1842 (b)(6)(F) of
the Social Security Act requires Consolidated Billing (CB) of all Medicare
home health services while a beneficiary is under a home health
plan of care authorized by a physician. DHA will follow Medicare’s
policy and law concerning CB which requires that only the primary
HHA overseeing the plan bills for services under the home health
benefit, with the exception of DME and therapy services provided
by physicians.
3.8.2 The contractors shall continue to follow all
CB instructions described in
Section 2.
3.9 Preauthorization
The contractor’s authorization process (including
data entering screens) shall be used in designating primary provider
status and maintaining and updating the episode information/history
of each beneficiary. The managed care authorization system shall
be used in lieu of Medicare’s remote access inquiry system. All
requirements outlined in Section 5 shall apply to periods of care
beginning on or after January 1, 2020.
3.10 OASIS
3.10.1 HHAs shall
still be responsible for the collection and encoding of OASIS data
(OASIS is the clinical data set that currently shall be completed
by HHAs for patient assessment), in accordance with
Section 3. This
information provides a mechanism for objectively measuring facility
performance and quality. It is also used to support the HHA PPS
(i.e., generate the HIPPS code and claim-OASIS matching key output
required on the CMS 1450 UB-04 claim form for pricing).
3.10.2 Since TRICARE
contractors shall not have the capability to incorporate the HH
Grouper logic (which uses OASIS data from the CMS quality data repository
to assign a HIPPS code) into their claims processing system, HHAs
shall continue to include the HIPPS code and Treatment Authorization
code on claims by inputting OASIS data through a Grouper program
in their billing software or in the CMS-provided Java-based Home
Assessment Validation and Entry (jHAVEN) tool. The jHAVEN software package
contains a Grouper module that generates a HIPPS code for a particular
60-day episode or 30-day period of care based upon the beneficiary’s
condition, functional status and expected resource consumption.
Updated versions of this software package may be downloaded from
the CMS web site at
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/HomeHealthQualityInits/HAVEN.html.
3.11 Maternity And Children Under
18
3.11.1 The abbreviated
assessment located in
Addendum B shall
be conducted for eligible TRICARE beneficiaries who are under the
age of eighteen or receiving maternity care from a Medicare certified
HHA. This shall require the manual completion and scoring of a HHRG
Worksheet for pricing and payment under the PDGM. OASIS assessments
are not required for authorized care in non-Medicare certified HHAs
that qualify for corporate services provider status under TRICARE
(e.g., those HHAs specializing solely in the treatment of beneficiaries
under the age of 18 or receiving maternity care).
3.11.2 If a Medicare-certified
HHA is not available within the service area, the contractor may authorize
care in a non-Medicare certified HHA that qualifies for corporate
services provider status under the TRICARE Program (refer to the
TRICARE Policy Manual (TPM),
Chapter 11, Section 12.1, for the specific
qualifying criteria for granting corporate services provider status
under the TRICARE Program.)
3.12 Medical Review Requirements
The contractors shall continue to use and adhere
to the medical review requirements as outlined in
Section 8.
3.13 HHA PPS Claims With Inpatient
Claim Types
3.13.1 Beneficiaries
cannot be institutionalized and receive home health care simultaneously.
The contractors shall reject an HHA claim, if it finds dates of
service on the HH claim that falls within the dates of an inpatient,
SNF or swing bed claim (not including the dates of admission and
discharge and the dates of any leave of absence). The HHA shall
submit a new claim removing any dates of service within the inpatient
stay that were billed in error.
3.13.2 If the
HHA claim is received first and the inpatient hospital, SNF or swing
bed claim comes in later, but contains dates of service duplicating
dates of service on the HHA claim, the contractors shall adjust
the previously paid HHA claim to non-cover the duplicated dates
of service.
3.14 NRS
Effective January 1, 2020, the NRS payment
amounts apply to only those 60-day episodes that begin on or before
December 31, 2019, but span the implementation of the PDGM and the
30-day unit of payment on January 1, 2020 (ending on February 28,
2020). Under the PDGM, NRS payments are included in the 30-day base
payment rate.
3.15 Data
And Pricer
3.15.1 The data
elements required to submit a claim will no longer be updated in
Chapter 12. With the exception of Corporate Service Providers (CSPs),
the contractors shall reject an HHA claim that is missing any of
the required data elements listed in the Medicare CPM, Chapter 10,
Section 40.2. These claims shall be processed according to the rules
described in Section 40.2.
3.15.2 All HHA
claims shall run through the Medicare HH Pricer software and shall
be reimbursed based upon calculations made by the Pricer which operates
as a call module within contractors’ systems, as is the current
process. The HH Pricer makes all reimbursement calculations, including percentage
payments on RAPs, claim payments for full Episodes or Periods of
Care, and all payment adjustments, including LUPAs, Partial Episode
Payment adjustments, significant change in condition adjustments,
and outlier payments. Contractors’ systems shall send an input record
to the Pricer for all claims with covered visits, and the Pricer
will send the output record back to the contractors’ system.
3.15.3 The data,
input/output record layout, and decision logic provided in
Section 7 will no longer be updated, beginning
January 1, 2020. The contractors shall format the interface with
the Medicare HH Pricer according to the record layout in the Medicare
CPM, Chapter 10, Section 70.2, and shall ensure that RAPs and claims
are calculated by the Pricer according to the logic described in Chapter
10, Sections 70.3 and 70.4 of the Medicare CPM.
3.15.5 The contractors
shall install the latest Medicare HH Pricer software from CMS’ website:
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PCPricer/HH.html and
replace the existing HH Pricer with the updated HH Pricer within
10 calendar days of download. Contractors shall maintain the last
version of the HH Pricer software for each prior fiscal year and
the most recent quarterly release.