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.