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Posted by: Robert Markette A more interesting point from the article I read, and this is a sentiment CMS has expressed elsewhere, the grouper is only intended to give agencies an approximation of how the new rule will impact their reimbursement. In other words, you will have to wait until the rule is final and the new PPS system is in effect to determine how your bottom line is altered. This strikes me as a bit unfair. The comment period for the PPS rule expires in July and, in my opinion, agencies will want to know how the new rule actually impacts their revenue before the comment period ends. They would also want to be able to more fully explore how the new PPS rule works so that they can offer more accurate suggestions on how the new HHRG, therapy threshold and other aspects of the rule should be altered to more accurately reimburse them. Agencies that do not have accurate information may not realize, until its too late, how badly the new rule will alter their income or how CMSs assumptions fail to consider key real world issues. Although generalizations about agency specific impacts are hard to make, it appears that reductions in reimbursement are likely to be the norm. The same article discusses how software companies are creating their own tools to analyze the impact of this rule. Again, the discussion in the article makes it clear that the impact to each agency may be very agency specific. Factors such as your current average therapy range will determine whether or not you suffer a reduction under the rule. The article mentioned that payment reductions also appear to result from the expansion to 153 case mix categories. The consultant who was interviewed seemed surprised by this result. Those of you who have seen my previous posts on the new PPS know that the PPS revisions appear to be, in my opinion, a concealed rate reduction. As such, you would expect the expansion of categories to reduce reimbursement. It this hidden reduction, that makes the lack of an accurate toy grouper so troubling. Unless your software company provides you with a tool to analyze your data, you may be surprised to find your reimbursement decline next year. Without information as to how the 153 categories and therapy threshold impact your reimbursement, you may find it difficult to provide clear comments to CMS about why their proposed revisions do not result in more accurate reimbursement. (In other words, why the assumptions they made are incorrect.) When you do see how the new PPS results in reimbursement changes and how inaccurate the new system is, it will be too late to comment. This is why it is unfair for the toy grouper to be inaccurate. Home health agencies may be denied the opportunity to provide relevant comments in the hopes of altering a massive regulation that will dramatically affect them. Seems counter to the concept of due process inherent in notice and comment rulemaking. |
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[08/15] Catalyst Pharmaceutical Partners Reports Second Quarter 2008 Financial Results Topics
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July, 2007 Web ResourcesFindLaw |
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The information you obtain at this site is not, nor is it intended to be, legal advice. You should consult an attorney for individual advice regarding your own situation. Copyright © 2008 by Home Care Law Blog Gilliland & Markette LLP. All rights reserved. You may reproduce materials available at this site for your own personal use and for non-commercial distribution. All copies must include this copyright statement. | |
