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 is also committed to setting and measuring standards of professional excellence so patients and their families can have confidence in post-acute care providers.

Recent Efforts

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.

This workgroup collaboration is just one of the many resources for home health guidance available to AHCC members. To learn more about AHCC, credentialing, and the many benefits of membership, visit: ahcc.decisionhealth.com.

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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).

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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.”

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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.

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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.

If you have further questions about what AHCC and BMSC are doing about this issue, please be on the lookout for updates. Or reach out via email to Megan Gustafson or Corinne Kuypers-Denlinger.


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.

Archives

Hospital proposed rule: New ICD-10 implementation date is Oct. 1, 2015

Providers can mark Oct. 1, 2015, on their calendars as the date they'll switch to ICD-10, according to a hospital inpatient proposed rule posted April 30.

After Oct. 1, 2015, "we will collect nonelectronic health record-based quality measure data coded only in ICD-10-CM/PCS," the Hospital Inpatient Prospective Payment Systems rule states.

Emails to CMS for comment were unreturned.

"This allows them to essentially put in a new date, sort of ride the coattails of an existing regulation," says Robert Tennant, senior policy adviser for the Medical Group Management Association (MGMA) in Washington, D.C.

Tennant notes that the references in the rule to ICD-10 and 2015 – such as "ICD-10 will officially be implemented on Oct. 1, 2015," on page 1,065 – are more direct than CMS' usual language. "'Will officially' is not 'we propose,'" he says. "That's not common in regulatory language. So I don't know whether that means it's not up for public comment."

The "doc fix" bill signed by President Barack Obama on April 1 had delayed ICD-10 implementation at least a year from its previous Oct. 1, 2014, implementation date.

The Workgroup for Electronic Data Interchange (WEDI) believes the 2015 date is official "based on our initial understanding of the regulation," a release states.

"It is not uncommon for CMS to use other unrelated regulations to address changing compliance dates, as this same approach was taken last time when ICD-10 was delayed," WEDI's release states. "WEDI will continue to work with [the] industry on moving forward with implementation and will operate under the assumption that we need to all work together to meet [an] Oct. 1, 2015, ICD-10 deadline."

Also the proposed rule made no revisions to the ICD-9 diagnosis or procedure codes. In fact, all the index and tabular proposals made during the March ICD-10 Coordination and Maintenance Committee Meeting featured ICD-10 diagnoses — there were no ICD-9 proposals. This further supports that the current code freeze, in advance of the arrival of ICD-10, will remain in effect.

Read the rule at http://ofr.gov/OFRUpload/OFRData/2014-10067_PI.pdf.

The proposed rule is scheduled to be published in the May 15 Federal Register.

– Josh Poltilove (jpoltilove@decisionhealth.com) and Roy Edroso (redroso@decisionhealth.com)

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Congress passes one-year ICD-10 delay; Obama signature near certain

Home health agencies are probably looking at an at-least-one year delay in the transition to the ICD-10 code set with the Senate's passage 64-35 of the "doc fix" bill on March 31.

The Protecting Access to Medicare Act of 2014 resets the deadline for implementing ICD-10 until October 1, 2015 —or even later. Section 212 of the bill says that the Secretary of Health and Human Services "may not, prior to October 1, 2015, adopt ICD-10 code sets as the standard for code sets.

The bill awaits President Barack Obama's signature. Obama has vetoed only two bills in his presidency, and the White House has given no indication that he will veto this one.

The ICD-10 delay was a surprise to many and agencies that weren't prepared for the roll out of the new coding system may be relieved. But for those that have already invested considerable time, effort and money on the transition, this is not welcome news.

The prospect of having to keep home health coders trained in ICD-10 for more than another year or to retrain them down the road is frustrating, says Laura Montalvo, regional director of quality management for Texas and Louisiana for Dallas-based CHRISTUS Home Care.

For large agencies, the delay poses a huge drain on manpower and resources because each delay requires a change in the training plan, which touches everyone: clinical document improvement staff, intake, billing, field clinicians, along with changes in action plans and milestones, she explains. "We'll have to redo the budget and the education plan for this and momentum will suffer. And it leads to uncertainty over other issues: Will this delay OASIS-C1? What about the Grouper? It really leaves us hanging."

CMS took these factors into account when estimating in 2012 that a one-year delay could cost from $1 billion to $6.6 billion or 10% to 30% of what providers, payers, vendors and academic programs have spent on or budgeted for upgrades.

Editor's note: For continued coverage of the delay and the impact on home health agencies check out our website Homehealthline.com.

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WEDI/CMS Welcome Home Health and Hospice to the ICD-10 Implementation Success Initiative

Reston, VA – February 14, 2014

The Workgroup for Electronic Data Interchange (WEDI), a leading authority on the use of Health IT to improve healthcare information exchange, and the Centers for Medicare and Medicaid Services (CMS) welcome the home health and hospice industry to the ICD-10 Implementation Success Initiative. Launched in December, the goal of this initiative is to ensure a successful ICD-10 transition for all health care industry stakeholders including providers, payers, clearinghouses and vendors.

“The consortium developed by the new ICD-10 Implementation Success Initiative will help ensure the successful implementation of ICD-10 by serving as a hub to field questions regarding ICD-10 and to develop a coordinated education effort regarding ICD-10 implementation,” explained Devin Jopp, WEDI president and CEO. “By collaborating with CMS and other industry partners, we can work effectively together to unite resources to help provide the most comprehensive support and resources industry wide.”

The Home Health & Hospice Stakeholder subgroup is being co-chaired by Corinne Kuypers-Denlinger, Vice President, Post-Acute Care Product Group with DecisionHealth, a leader in the delivery of information services and education and training to the health care industry, and Mary K. Carr, Associate Director for Regulatory Affairs, with the National Association of Home care and Hospice (NAHC). Other industry leaders participating in the initiative include representatives of organizations that work closely with home health and hospice such as AD Maxim, BKD, The Corridor Group, SHP, Simione Healthcare Consultants, and Hall, Render, Killian, Heath & Lyman, as well as representatives from home health and hospice agencies.

The new ICD-10 Implementation Success Initiative is comprised of several different elements, including a searchable database of ICD-10 issues, which is open to the public for submission. WEDI, CMS and their partners will help to triage issues and provide valuable information and resources to help healthcare organizations understand how the new codes and coding standards will impact diagnosis and inpatient procedures. A series of educational webinars and articles will also be created to highlight prominent ICD-10 conversion issues and trends. The ICD-10 searchable database can be found here.

We will be using a WEDI listserv to organize and communicate among the members of this subgroup. To join the listserv please follow the directions below.

  1. If you do not already have a free WEDI user profile please take a few moments to create one:http://www.wedi.org/forms/applications/NewUserPublic/edit?mode=quick
  2. Go to http://www.wedi.org/users_only/mailinglist/MailingListFormPublic/subscriptions and select “individual messages” for the WEDI-HomeHealthandHospiceStakeholders@lists.wedi.org listserv and then scroll down to the bottom of the page and click Save Changes
  3. (optional step) Make sure your server/firewall is not blocking emails from this listserv WEDI-HomeHealthandHospiceStakeholders@lists.wedi.org

Please contact Samantha Holvey, sholvey@wedi.org if you have any questions or need further information about the listserv. For more information on ICD-10 compliance steps, please visit WEDI ICD-10 Information.

The Home Health & Hospice Stakeholder subgroup joins other industry partners participating in the ICD-10 Implementation Success Initiative including AAPC, American Health Information Management Association (AHIMA), America’s Health Insurance Plans (AHIP), American Osteopathic Association (AOA), Blue Cross Blue Shield Association (BCBSA), Cooperative Exchange, Healthcare Billing Management Association (HBMA), Medical Group Management Association (MGMA), National Association of Community Health Centers (NACHC), National Association of Rural Health Clinics (NARHC), and Professional Association of Health Care Office Management (PAHCOM).

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