3.0 POLICY
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 calendar 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 (ADL), 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 United States (US), District of Columbia, Puerto Rico, US 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 calendar days. Episodes may be shorter than 60 calendar
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 calendar days. Periods of care may be shorter than
30 calendar 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 calendar 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% 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 (PT) or speech-language pathology
(SLP); or
• Have a continuing need for
occupational therapy (OT).
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 (CB)
3.8.1 Section 1842 (b)(6)(F) of the
Social Security Act requires 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 4 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 website 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 5.
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 (PEP) 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 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 Medicare CPM, Chapter 10, Sections 70.3
and 70.4.
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.