The shift from PPS to the Patient Driven Groupings Model (PDGM) has forced most home health providers to optimize how they deliver patient care in order to ensure financial viability.
To understand why this has occurred it is worth quickly revisiting the key aspects of the PDGM framework that went into effect January 1, 2020.
INTRODUCING THE PATIENT DRIVEN GROUPINGS MODEL
The major impact of PDGM was how providers are paid by Medicare for home health services rendered. Prior to January 1, 2020 the Prospective Payment System (PPS) was the governing set of regulations. Under this model the amount of revenue per patient was based on a combination of the anticipated clinical, functional, and service utilization needs of the patient along with a quality and performance variable. Revenue was provided through a Request for Anticipated Payment (RAP) to Medicare which was expected to cover 60 days of treatment.
Under PDGM there were a number of significant changes made to this payment model:
- RAP episodes changed from a 60-day to a 30-day period. The change from 60-day episodes to 30-day periods means that agencies must plan, deliver, document, and bill for care twice as often.
- The first 24-48 hours from start of care (SOC) will be critical to optimize reimbursement: a HHA clinician must assess the patient’s needs and document a plan of care (POC) as soon as possible.
- Billing will be every 30 days under PDGM, which means that the initial Request for Anticipated Payment (RAP) and the final claim will occur in a much shorter time-span. A second RAP for a second 30-day period must be submitted on or after day 31.
- Service utilization (largely in the form of therapy visits) was eliminated from the payment calculation.
- Many agencies and providers have drastically cut therapy services for patients as a result of this change. However, the elimination of the therapy threshold does not mean that therapy services will no longer be paid for (and more importantly that they are not needed for the patient to progress). The new model now ties therapy payments to patient clinical characteristics and patient needs, particularly through the new Functional Impairment Level in determining the case mix group for the patient.
- A defined list of 432 mix case groups was created with a base payment attached to each. These case mix groups are based on”
- Timing: The first 30-days are “early”, everything else is “late”.- Source: “Institutional” or “Community”. Basically, did the patient have an acute or post-acute stay within 14-days of start of care (SOC).
- Functional Level. OASIS codes will be utilized to determine if classification is “low impairment”, “medium impairment” or “high impairment”.
- Comorbidity Adjustment. “no adjustment”, meaning none of the 11 comorbidity diagnoses apply, “low adjustment”, meaning there is 1 qualifying comorbidity, and “high adjustment”, indicating 2 or more qualifiers.
- Clinical Grouping. Patients will be assigned to 1 of 6 major clinical groups, based on principal diagnosis.
- Timing: The first 30-days are “early”, everything else is “late”.- Source: “Institutional” or “Community”. Basically, did the patient have an acute or post-acute stay within 14-days of start of care (SOC).
- OASIS assessments must still be completed within five days of admission and again within the last five days of the certification period (no later than 56-60 days from SOC). However, if there is a significant change in the patient’s condition that impacts HHA services, CMS will require a new RAP along with supporting OASIS documentation and physician orders.
- As part of this coding process it is imperative that agencies correctly code their patient to this highest paying diagnosis code present in the patient as the principal diagnosis to optimize revenues. However CMS has put all providers on notice that inappropriate elevations of a diagnosis (such as making a higher paying secondary diagnosis a primary diagnosis on the RAP) are likely to trigger reviews or audits.
Documentation Is Critical
PDGM is one step in an ongoing journey to reduce fraud and inefficiency in the delivery of Medicare and Medicaid based services. An additional component which is slowly being rolled out state by state is the implementation of Review Choice Demonstration (RCD),
RCD is designed to give applicable organizations options for compliance. Those options include:
- Pre-claim review
- Post-payment review
- Opt-Out of voluntary review (which comes with a hefty 25% payment reduction).
A focus on accurate documentation underpins the RCD project (and directly ties to more accurate case mix grouping for the patient via PDGM). For both RCD and PDGM, it is therefore imperative that:
- The OASIS assessment is accurately completed and transmitted on time.
- A compliant Face-to-Face (F2F) certification is collected before any services are provided;
- That correct orders detailing the diagnosis and treatment required is signed and dated by the referring medical provider;
- That an accurate Start of Care (SoC) is performed to validate the orders, identify all necessary information for optimal coding, and to support the generation of a Plan of Care (PoC) that will demonstrate patient progress, achieve a quality outcome, and be a profitable episode for the provider with no errors in the event of a review or audits.
Achieving Quality and Profitability in Home Health
In order for home health providers to deliver maximum quality profitably under these new payment structures and regulatory requirements, there are six main areas of business operations that must be reviewed: