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 (HHC) 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 (HH) 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 HH 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 HH 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 HH 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 HH 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, United
States (U.S.) Virgin
Islands, and Guam.
3.2.3 The contractor shall
follow Medicare’s methodology
for reimbursement,
and
the contractor shall report revenue
code 023
on 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
,
the contractor shall code all HH TEDs
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 is coded with 4CC11. The
contractor shall ensure HIPPS codes are 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 the TRICARE Program covered HH 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
HH 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 HH 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 (POC),
all of which 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 no
longer submit 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 HH
Episode of Care (EOC),
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 split percentage
payment shall be 20 percent for each 30-day period. Additionally, the
contractor may not verify
if the date the HHA certified for participation with Medicare was
before or after January 1, 2019.
3.5.3 The contractor
shall base the percentage payment for the RAP based
upon the submitted HIPPS code. 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 With the removal of RAP payments
starting in CY 2021, the upfront split percentage payment shall
be zero percent for 30-day periods of care beginning on or after
January 1, 2021.
3.5.5 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.
Consistent
with Medicare’s CPM, HHAs shall no longer submit RAPs for periods of
care beginning on or after January 1, 2022. However, the preauthorization
process described in paragraph 3.9 and the TRICARE Operations Manual
(TOM), Chapter 7, Section 2, continues to apply on claims
with From dates on or after January 1, 2022.
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, the
contractor shall pay 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
contractor shall reimburse the 30-day
period of care
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,
the
contractor shall reimburse 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,
the
contractor shall classify it as a LUPA and
reimburse at
the per-visit amount. If the visit is three or more, then
the
contractor shall not
classify it as
a LUPA and
shall reimburse the full
30-day payment amount. Therefore,
the contractor shall
consider periods of care with one visit
as LUPA
claims, and also
reimburse 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(s),
maintains national standard visit rate tables that are used
in outlier and LUPA determinations. The contractor 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
HH benefits,
a beneficiary
shall meet the following
requirements:
• Be confined to the home;
• Under the care of a physician;
• Receiving services under a POC 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 (SLP);
or
• Have a continuing need for Occupational Therapy (OT).
3.7.2 For HHA
services to be covered, the individualized POC shall
specify the services necessary to meet the patient-specific needs
identified in the comprehensive assessment. In addition, the POC 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 is in accordance
with the POC.
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 HH services
while a beneficiary is under a HH 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 HH benefit,
with the exception of DME and therapy services provided by physicians.
3.8.2 The
contractor shall
continue to follow all CB instructions described in
Section 2.
3.9 Preauthorization
The contractor
shall use its authorization process (including data
entering screens) to designate primary
provider status and to maintain and update the
episode information/history of each beneficiary. The managed care
authorization system is used in lieu
of Medicare’s remote access inquiry system. The contractor
shall apply all requirements outlined in Section
5 to periods of care beginning on or
after January 1, 2020.
3.10 OASIS
3.10.1 HHAs shall still
collect and
encode OASIS
data (OASIS is the clinical data set that currently
is 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
Uniform Billing (UB
)-04
claim form for pricing).
3.10.2 Since
the TRICARE
contractor
does 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
its claims
processing system
(s), HHAs shall continue
to include the HIPPS 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.
Download updated
versions of this software package
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
contractor
shall ensure the abbreviated assessment located in
Addendum B is conducted
for eligible TRICARE beneficiaries who are under the age of eighteen
or receiving maternity care from a Medicare certified HHA. This
require
s the manual completion and
scoring of
an 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
(CSP) status under
the TRICARE
Program (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
CSP status
under the TRICARE Program (refer to
TRICARE
Policy Manual (TPM),
Chapter 11, Section 12.1, for the specific
qualifying criteria for granting
CSP status
under the TRICARE Program.)
3.12 Medical
Review Requirements
The
contractor 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 shall
not be institutionalized and receive HHC 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 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 contractor 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 are no longer updated
in Chapter 12. With the exception of CSPs,
the contractor shall reject an HHA
claim that is missing any of the required data elements listed in
the Medicare CPM, Chapter 10, Section 40.2. The contractor
shall process these claims according
to the rules described in Section 40.2.
3.15.2 The contractor
shall run all HHA claims through
the Medicare HH Pricer software and reimburse based
upon calculations made by the Pricer. The Pricer operates
as a call module within contractor’s
system(s),
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. The
contractor’s system(s) sends an
input record to the Pricer for all claims with covered visits, and
the Pricer sends the output record
back to the contractor’s system(s).
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
contractor 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
the Pricer
calculates
claims 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
days of download.
The
contractor shall maintain the last version of the
HH Pricer software for each prior
FY and
the most recent quarterly release.