1. Update to EPM changes Proposed rule changes announced in August:
reduction in mandated geographic areas from 67 to 34
Eliminating the cardiac bundles and the hip fracture bundles – at least for now
Allowing individual clinicians to be a provider
Hospitals in the voluntary areas must elect to participate by Jan 31, 2018
Medicare Advantage updates – on the rise; expected to increase by 30% in next 6 years
Source of changes to program:
Publication # CMS-5524-P
August 15, 2017

2. HH Proposed Rule Effective January 2019
HUGE changes to payment
Reduces ‘episode’ from 60 days to 30 days
Uses a ‘groupings model’ = 6 new clinical groups to categorize patients based on their Primary reason for HH services
Revises functional levels in OASIS
Changes LUPA’s, VPB and QRP
Source: publication # CMS-1672-P
July 28, 2017

3. Home Health Groupings Model (HHGM - Proposed)
30 day periods
Uses clinical characteristics to drive payment (patient centered)
Primary diagnosis, functional level, co-morbidities, admission source and timing
Eliminates therapy thresholds
Based on cost per minute + routine supplies
1st 30 days = early episodic payment
2nd 30 days = late unless there is a gap of >60 days between episodes (SNF criteria!)
Admission source is where the referral came from in the 14 days prior to the start of HH care (community vs institutional)
6 clinical groups
3 functional levels which indicate higher or lower costs to the agency

4. HHGM continued 6 clinical groups:
Musculoskeletal rehab
Neuro/stroke rehab
Wounds
Complex nursing
Behavioral health
Medication management, teaching, assessment
There will be adjustments for comorbidities
CMS is promoting ‘front loading’
Especially with heart disease and new musculoskeletal diagnoses
Also with care transition times such as hospital to home or SNF to home
LUPA thresholds vary based on payment group
Each 30 day episode is placed into one of 144 HHRG’s
Propose using 10% of visits or 2 visits whichever is higher
Approximately 7% of 30 day periods would be LUPA’s

5. Section GG Traditional Medicare only/ SNF setting
Shows functional improvement for quality performance and payment with 2% penalty attached if submission doesn’t occur by deadline
Beginnings of ensuring equal playing field across PA settings and certainly among SNF’s
Resident can use assistive devices – does not affect coding
When assessing ability to walk or wheel 50 feet with 2 turns:
Turns must be 90 degree turns
Can be in same direction or opposite

6. Key Points
Admission and Discharge performance ratings are NOT based on staff assessment of potential ability (so cannot copy rehab goals)
Assesses need for assistance and establishes d/c goals for self care and mobility
Items focus on self care and mobility – entire team must set these
Admission performance
Discharge performance
Discharge goals
Definition of ‘helper’
Must be employed or contracted by facility
Does not include students, hospice personnel, family, private caregiver, etc..
Cannot code using occurrences from these non-staff personnel

7. Section GG Admission Coding
Look back day and assess ‘usual’ performance
Important to not just rely on therapy evaluations as we know patients often are different outside of therapy
Requires TEAM to look at 3 full days and determine the persons usual performance, not the best or worst
Admission coding is CRITICAL to setting the stage for payment & outcomes
Coding Tips:
Stay away from use of Dash (means you have no information)
Discern between 07/08/09 codes and have documentation to support choice
07= patient refused around the clock for the 3 days in the lookback period
08= patient cannot currently perform due to medical reasons but was able to prior to illness/injury
09= patient never performed activity therefore no goals for this now