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By MATTHEW HAY
HHBR Washington Correspondent
Oct. 1, 2000, is going to be the home health industry’s Y2K. That is the view of Jim Pyles, counsel for the Home Health Services and Staffing Association (HHSSA; Washington) after reviewing the Health Care Financing Administration’s (HCFA; Baltimore) proposed regulation for a home health prospective payment system (PPS).
"That is where the planes are going to fall out of the sky," asserted Pyles. "We are going to go cold turkey from one system to the other for every patient in the country on a system that nobody knows if it works."
However, the actual Y2K dilemma might yet stand in the way of the new system. In fact, some HCFA officials are reportedly still concerned that Y2K problems may delay implementation of the final rule for a home health PPS, which is scheduled to be published in July.
The home care industry received a much-needed boost last week when Congress voted to delay the 15% across-the-board reduction in home health reimbursement scheduled for Oct. 15, 2000. But that does not mean the industry is out of the woods by a long shot, according to Pyles.
"Under the best of circumstances, I think there is a real danger of a serious disruption in cash flow and services to patients," he asserted.
The most significant problem, according to Pyles, is that agencies will only have roughly 60 days to implement the new system once the final rule is published. "The start-up costs on this are going to be enormous," warned Pyles. "There are going to be a tremendous number of systems changes that are going to have to take place."
Pyles also predicted that there will not be major changes from the proposed PPS to the final rule. "I don’t think there is going to be much time for any significant change in design," said Pyles. But one change Pyles does expect to see is the current requirement for physician certification. The physician certification requirement included in the proposed rule mandates that once a home health agency categorizes a patient in one of the 80 case mix categories, the physician prescribing the care must then certify that that category is accurate.
"If they go forward with that, you won’t have to worry about how much agencies are going to get paid because no physician will prescribe home care," argued Pyles. "Physicians are simply not going to learn the intricacies of an 80-category home health classification system and put their practice on the line certifying its accuracy because if they are wrong, they would be subject to a $5,000 civil monetary penalty."
Regardless of any possible changes, industry experts are urging agencies to begin planning immediately. "We think the proposed regulation has all the information agencies need to assess whether they will fare positively or negatively under the PPS at least as a proposed system," said the National Association for Home Care’s (NAHC; Washington) Bill Dombi. One of the steps NAHC is recommending is for agencies to take the OASIS data they now have, categorize patients, and assess what the cost of care is for those patients for an episode of care consistent with the proposed episode definition.
The key is that agencies have to have good clean data from their OASIS assessments preferably dating back to May or June of this year in order to get one or two episode periods, according to Dombi.
"Agencies can also do the same going forward, and we are suggesting they take a sample of cases within their organization to get a sense of how they would be impacted if this PPS were in place today," added Dombi.
"The key is whether the rate is adequate enough to maintain care to the patient," said Dombi. "The first strategy we are recommending to agencies right now is to apply this system on a random sample basis within their own organization."