Advocacy

AHCC’s advocacy team actively monitors, responds, and participates in industry initiatives to increase the awareness and visibility of the critical role post-acute care plays in the care continuum. AHCC advocates on behalf of membership in matters affecting home care.

Recent Efforts

AHCC Responds to 2023 HHPPS Proposed Rule

The Association of Home Care Coding and Compliance (AHCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on changes to the Home Health Prospective Payment System as outlined by the Centers for Medicare and Medicaid Services in the proposed rule issued June 23, 2022.

In these comments, AHCC encourages HHS and CMS to reconsider changes that will negatively impact home health reimbursement as well as conclusions the agency puts forth regarding the use of therapy in home health.

Read the rest of AHCC comments here.

AHCC Responds to 2022 HHPPS Proposed Rule

The Association of Home Care Coding and Compliance (AHCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on changes to the Home Health Prospective Payment System as outlined by the Centers for Medicare and Medicaid Services in the proposed rule issued June 28, 2021.

In these comments, AHCC encourages HHS and CMS to consider greater flexibility for home health telehealth visits, make telehealth utilization data publicly available, consider additional data sources before making future reimbursement reductions, and provide a more detailed examination of therapy utilization data.

Read the rest of AHCC comments here.

AHCC and BMSC Respond to 2021 HHPPS Proposed Rule

The Association of Home Care Coding and Compliance (AHCC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on changes to the Home Health Prospective Payment System as outlined by the Centers for Medicare and Medicaid Services in the proposed rule issued June 30, 2019.

In these comments, AHCC strongly encourages HHS and CMS to work with Congress to amend the Social Security Act to provide CMS with the statutory authority to permanently extend the policy that allows telehealth services furnished by all clinical disciplines, including physical therapy, in HHAs to be reimbursed under Medicare, as well as make permanent the flexibilities associated with the originating site geography, authorized originating site, and audio-visual technology to allow all Medicare beneficiaries to receive telehealth services from their home, whether that home is in the community or part of an institutional setting.

Read the rest of AHCC/BMSC comments here.

AHCC and BMSC Respond to 2019 HHPPS Proposed Rule

The Association of Home Care Coding and Compliance (AHCC) together with the Board of Medical Specialty Coding and Compliance (BMSC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on on changes to the Home Health Prospective Payment System as outlined by the Centers for Medicare and Medicaid Services in the proposed rule issued July 12, 2018.

As part of the proposed PDGM payment system, patients will be grouped into one of six clinical groups based on the principal diagnosis listed on the claim. We’re concerned that agencies will find that a significant portion of their claims include a principal diagnosis that doesn’t place the claim into one of the new clinical categories. AHCC and BMSC request that CMS specifically state in the regulations the process for resubmitting a denied claim so that providers will have a clear process to avoid improper claims denial and/or the risk of being perceived to be engaged in a non-compliant practice like upcoding.

Read the rest of AHCC/BMSC comments here.

AHCC Submits Comments on Proposed Review Choice Demonstration Project

The Association of Home Care Coding and Compliance (AHCC) together with the Board of Medical Specialty Coding and Compliance (BMSC), the credentialing arm of AHCC, recently submitted comments to CMS on the proposed Review Choice Demonstration Project.

The original Pre-Claim Review Demonstration Project caused many problems in Illinois due to operational issues. Reimbursement claims for legitimately necessary and compliantly supplied services were delayed and denied. There was a huge backlog of claims needing review that further delayed payment. Overall, in the early weeks and months of the project, home health agencies struggled to receive payment for legitimate claims due to “technical” documentation errors that did not alter the patient's eligibility or medical need for the services. It’s unclear how the new project will address these issues.

Read the rest of AHCC’s comments here.

AHCC and BMSC Submit Comments on OASIS-D

The Association of Home Care Coding and Compliance (AHCC) together with the Board of Medical Specialty Coding and Compliance (BMSC), the credentialing arm of AHCC, recently submitted comments to CMS on proposed changes to the OASIS.

Although we appreciate CMS’s attempts at providing a neutral change in that many items were deleted to make way for additional items, the deletion of many of the items will not save time in that, especially the best practices, the items will still need to be a part of the comprehensive assessment. For example, the agency will likely still assess for pain and for pressure ulcer risk, even if the actual OASIS items were deleted. CMS's estimate of the time saved is therefore inaccurate.

Read the rest of AHCC’s comments here.

AHCC Requests New Guidance for Coding Hypertensive Heart Disease with Heart Failure

The Association of Home Care Coding & Compliance has asked the CDC's National Center for Health Statistics to provide updated guidance when reporting codes from the Ischemic Heart Diseases category I20-I25 for patients with hypertension.

To read the letter, click here.

AHCC and BMSC Respond to Draft Interpretive Guidelines

The Association of Home Care Coding and Compliance (AHCC) together with the Board of Medical Specialty Coding and Compliance (BMSC) submitted comments on the draft interpretive guidelines for the revised Home Health Conditions of Participation (CoPs).

Of special interest to our members, AHCC and BMSC asked for clarification concerning:

• How agencies can demonstrate that transfer and discharge policies of the HHA were provided to patients in “a language they understood and in a manner which accommodated any disability.”
• How a significant change in the patient’s condition will impact the 60 day period for review of subsequent plans of care.
• Whether therapists are permitted to perform the drug regimen review.

To read the AHCC/BMSC comment letter, click here.

AHCC and BMSC Respond to 2018 HHPPS Proposed Rule

The Association of Home Care Coding and Compliance (AHCC) together with the Board of Medical Specialty Coding and Compliance (BMSC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2018 Home Health Prospective Payment System Rate Update and 2019 Case-Mix Adjustment Methodology Refinements.

Of special concern to our members, the proposed rule outlines plans to:

• Remove the therapy threshold “bonus” payments without factoring in therapy cost calculations elsewhere in the payment system.
• Group home health beneficiaries into six new clinical groups as part of the home health groupings model for payment.
• Return claims that don’t fit into one of the six clinical groups to providers for re-coding.

To read the AHCC/BMSC comment letter, click here.

The Home Health and Hospice ICD-10 Transition Workgroup Closing the Coding Guidance Gap

Happy New Year from the Association of Home Care Coding & Compliance (AHCC), a member of the Home Health and Hospice ICD-10 Transition Workgroup, a consortia of associations formed to support agencies as they adapt to the new language, logic and specificity of ICD-10.

October 1, 2015 has come and gone. The sky didn’t fall, but many home health agencies did stumble as they grappled with software glitches, struggled with insufficient documentation from referral partners and from their own clinicians, and with the internal coding-knowledge gaps that surfaced. Agencies also continue to receive conflicting and/or inapplicable guidance from the American Hospital Association’s (AHA) Coding Clinic, CMS’ designee for official ICD coding guidance and clarifications. These inconsistencies can lead to payment delays or claim denials.

Through all of these new ICD-10 challenges, AHCC has been on the front lines providing guidance and resources to its members and the home care community in general. Working closely with the Coding Clinic, the confusion over the use of A as the seventh character indicating initial encounter by home health agencies was brought to light. Acting as advocate, the Transition Workgroup worked with CMS to ensure that the January 1, 2016 release of the home health Grouper reflected the Coding Clinic’s guidance around use of the seventh character A. But this instance is by no means the only time when new guidance has caused confusion for the industry.

Many times guidance issued by the Coding Clinic is not easily interpreted by or adapted to home health or hospice. The ICD-10 Transition Workgroup is working closely with the Coding Clinic to address this concern and have crafted a solution.

The Coding Clinic has agreed to accept industry queries from the board of the Association of Home Care Coding & Compliance (AHCC) and the board of its’ credentialing body, the Board of Medical Specialty Coding & Compliance (BMSC), on behalf of the industry. As the BMSC board is comprised of eight of the nation’s leading home health and hospice coding experts, the Coding Clinic has further agreed to accept with those queries a recommended response and the rationale for that response. The Coding Clinic Editorial Advisory Board will consider the query as well as the recommended response before issuing guidance.

Members of the Transition Workgroup associations are encouraged to submit their coding questions to a special dedicated address for AHCC's Board review, follow up, and response with subsequent guidance issued by the Coding Clinic's EAB. This process funnels all industry coding questions through one channel and disseminates resulting guidance at one time for more efficient and effective resolution.

The Board of Medical Specialty Coding & Compliance announces the launch of the Home Care Coding Specialist - Hospice (HCS-H) Credential Exam

Gaithersburg, MD – The leading home health and hospice association, The Association of Home Care Coding & Compliance (AHCC) and its credentialing body, the Board of Medical Specialty Coding & Compliance (BMSC), announces the launch of its third home health professional credential, BMSC's Home Care Coding Specialist -Hospice (HCS-H) certification.

The certification exam tests a candidate’s ability to apply knowledge of CMS coding conventions and guidelines related to the use of ICD-10-CM codes in the hospice setting, including proper sequencing of diagnosis codes.

On October 1, 2014, coding rules changed for hospice providers. No longer can hospice use as principal diagnosis the codes that are most commonly selected for hospice patients, debility and adult failure to thrive, but must select codes specific to the terminal diagnosis. Hospice coders also now are required to assign all other relevant diagnoses. Further, as in all provider settings, hospice coding specialists are expected to code to the highest level of specificity. Failure to meet the new, more rigorous, coding guidelines will result in delayed or denied claims.

The hot lights of regulatory scrutiny now are trained on hospice providers, as they have been on home health providers for nearly a decade. And, correct code selection and sequencing has become a critical factor in ensuring that hospice providers are properly and compliantly reimbursed for end-of-life support provided.

“Today, more than at any time before, it is imperative that hospice agencies have on staff a coding specialist with the unique knowledge and skills needed to ensure compliant hospice coding,” says Tricia A. Twombly, BSN RN HCS-D HCS-O HCS-H COS-C, CHCE, AHIMA approved ICD-10-CM certified trainer, ICE Certified Credentialing Specialist and CEO of BMSC and Senior Director with DecisionHealth. “Hiring coders who have earned the HCS-H credential will give administrators confidence that the agency is meeting the requirements of the law.”

The HCS-H credential joins the Home Care Coding Specialist—Diagnosis (HCS-D) and the Home Care Clinical Specialist—OASIS (HCS-O) as the gold-standard of professional certifications for home care coding and clinical specialists. BMSC has been credentialing home care professionals since 2003 with the launch of HCS-D, and HCS-O in 2011, both nationally accredited by the National Commission on Credentialing Agencies (NCCA).

AHCC successfully led effort to resolve 7th character issue with CMS

Gaithersburg, MD 10-29-15 – We spoke, they listened. The Association of Home Care Coding & Compliance (AHCC), a division of DecisionHealth, and its credentialing body, the Board of Medical Coding & Compliance (BMSC), proudly announce that due to its efforts the Prospective Payment System (PPS) Final Rule includes a critical correction.

In its final rule, CMS says it will reissue the PPS payment logic (grouper) to award case-mix points for certain initial encounter codes (seventh character “A” codes), effective Jan. 1, 2016, but retroactive to all claims with a M0090 date on or after Oct. 1, 2015. In determining which diagnosis codes would be appropriate for home health to indicate that care is for an initial encounter, CMS and the cooperating parties developed a revised translation list which will be posted to CMS’ website, although the federal agency did not say when.

Here’s how we did it. Knowing that soon-to-be-released AHA Coding Clinic guidance regarding use of the 7th character A (initial encounter) would have a devastating impact on home health agency revenue, AHCC went to work. We made phone calls and we sent letters signed by AHCC and BMSC board members to the key stakeholders within CMS outlining the issue, the impact, and the urgency to find a remedy.

We also reached out to the leading home health and hospice associations to get their support in petitioning CMS to address the issue. We also invited them to become part of the Home Health and Hospice ICD-10 Transition Workgroup to proactively identify emerging ICD-10 issues and to work collaboratively with the Coding Clinic and CMS to quickly resolve those issues.

The Alliance for Home Health Quality and Innovation (AHHQI), the National Association of Home Care & Hospice (NAHC), the National Hospice and Palliative Care Organizations (NHPCO), and the Visiting Nurses Association of America (VNAA) joined the workgroup. And, Dr. William Rogers, CMS ICD-10 Ombudsman, agreed to meet with the group regularly to quickly resolve issues as they arose.

“Home health and hospice now have a seat at the coding guidance table,” says Tricia Twombly, BSN, RN, HCS-D, HCS-O, COS-C, CHCE, AHIMA approved ICD-10-CM certified trainer, ICE Certified Credentialing Specialist and CEO of BMSC. “The community of providers has a voice through AHCC and through the ICD-10 Transition Workgroup. We are being heard. These are exciting times.”

Consortia of home health and hospice associations team up with CMS Ombudsman to ease ICD-10 transition

Washington, DC – On Thursday, October 8, 2015 the leading home health and hospice associations and CMS’ ICD-10 ombudsman, Dr. William Rogers, agreed to work together over the next 18-to-24 months to provide support to agencies as they transition to ICD-10.

Members of the workgroup include: Alliance for Home Health Quality and Innovation (AHHQI), Association of Home Care Coding & Compliance (AHCC), National Association of Home Care & Hospice (NAHC), National Hospice and Palliative Care Organizations (NHPCO), and Visiting Nurses Association of America (VNAA).

Led by AHCC, a division of DecisionHealth, the ICD-10 Transition Workgroup will be the conduit through which ICD-10 transition-related questions and concerns are channeled with the intent of supporting the Ombudsman in his efforts to quickly reach resolution. Members of the AHCC board, and its credentialing body the Board of Medical Specialty Coding & Compliance (BMSC), are recognized as the country’s foremost authorities on compliant coding for home health and hospice. Each of them has more than 20 years of coding experience in the subspecialty, and each has been providing ICD-10 education and training to the industry for the past two years.

“I welcome the support of the Home Health and Hospice ICD-10 Transition Workgroup as the healthcare industry goes through this critical period,” says Dr. Rogers. “It’s important that all providers be properly paid for the services they provide, but because home health payments are tied directly to the code selection and sequencing it is particularly important that issues be addressed in a timely manner.”

Dr. Rogers welcomes the industry to submit ICD-10 questions directly to him via the Ombudsman email box, ICD10_Ombudsman@cms.hhs.gov, but says that having AHCC’s home health and hospice coding experts preview the questions may accelerate the response time.

“Speaking for the workgroup, we couldn’t be more pleased that Dr. Rogers has agreed to work with the industry to quickly review and resolve ICD-10 coding questions,” says Tricia A. Twombly, BSN RN HCS-D HCS-O COS-C, CHCE, AHIMA approved ICD-10-CM certified trainer, ICE Certified Credentialing Specialist and CEO of BMSC.

AHCC and BMSC working to resolve 7th character conundrum

The board members of the Association of Home Care Coding (AHCC) & Compliance and the Board of Medical Specialty Coding & Compliance (BMSC), the credentialing arm, are aware of the 7th character issue and are presently working with CMS to resolve it.

To date, CMS has acknowledged that there is a disconnect between the Coding Clinic guidance and the Grouper Logic and has said that steps are being taken to manage the issue. So far, we’ve heard that claims will be adjusted between October 1 and December 31, 2015, and that the Grouper will be updated on its normal schedule, which would be January 1, 2016.

However, we are still waiting for confirmation from CMS that that is how this problem will be addressed. Rest assured AHCC and BMSC are working on your behalf. A letter detailing our concerns has been drafted and sent to CMS. Click here to review the memo.

ICD-10 Implementation Success Initiative

As a participant in WEDI/CMS ICD-10 Implementation Success Initiative, AHCC is working collaboratively with other public and private organizations in the health care industry to ensure that the entire industry transitions smoothly from the ICD-9 code set to ICD-10 with minimal impact on productivity and cash flow.

AHCC responds in letter to CMS’ proposed drop of the face-to-face (F2F) narrative requirement

Advocate for the national membership organization for home health coding and compliance professionals, AHCC’s board president, Diana Kornetti, addresses the question – What does the F2F narrative requirement change mean for you and your agency? – and how the PPS Proposed Rule change will affect the home health community.

Kornetti’s comments on the PPS Proposed Rule in a detailed and insightful memo were presented to the CMS on behalf of AHCC members. Click here to review the memo.