Value of Case Management: (CMS Tools- Across the Continuum) Connecticut Chapter: ACMA
Transcription
Value of Case Management: (CMS Tools- Across the Continuum) Connecticut Chapter: ACMA
Value of Case Management: (CMS Tools- Across the Continuum) Connecticut Chapter: ACMA October 26, 2013 Faculty Jackie Birmingham, RN, BSN, MS, CMAC VP, Emerita, Curaspan Health Group 1 Agenda • Introduction – • CMS Tools – Conditions of Participation • COPs: Utilization Review & Discharge Planning • FY2014 IPPS : time-based (24-48) hour admission & transition • What hasn’t changed and what has changed • A peak at Hospital Value Based Purchasing – 2014-2015 • Summary of key takeaways • Q&A 2 Introduction • Terms for ‘across the continuum’ • Transition of Care, Case Management, Care Coordination • Discharge Planning and Utilization Review • Case Management is not an isolated function process: • It is an essential broad-based concept involving clinical process of care • It involves transition in-out-through multiple of levels of care • Core Values • Patient safety and improve outcomes • Efficiency (appropriateness) • Financial Stability • Compliance 3 The big shift - Incentives Shifting Incentives • incentives from ‘quantity’ to ‘quality • to more ‘patient involvement’ • to preventive care • to coverage of ‘comprehensive’ health care services for all • Still following the payment/practice/payment cycle 4 An evolution perspective • 1965: 50 years – SSA (Part A, Part B, SNF Benefit) • 1972: 40 years - Utilization Review Standards • Admission, continued stay, professional services • 1983: 30 years Prospective Payment (PPS- DRGs) • Bundled payment, Outpatient observation • 1988: 25 years: Discharge Planning Standards • Identify, assess, plan, implement , discharge, • 2010: 3 years: The Affordable Care Act • 2013/4: Time-based presumption of admission 5 Practice - Payment - Cycle Practice Payment Audit Outcomes 6 E.g.: Practice-Payment-Cycle “Observation Services” • 1983: New Payment method - PPS/DRG: • Admit – get paid DRG • Audits of appropriateness of admission • Please – we can’t admit or discharge • What can we do? • How about keeping patient as outpatient? • ‘Observe’ for 24 hours? • Sounds good • Let’s do it! • But – who knew? 7 Admission decision challenge • OIG-OEI Report: July 2013 • “On Average, Medicare Paid Nearly Three Times More for a Short Inpatient Stay Than an Observation Stay and Beneficiaries Paid Almost Two Times More.” • Assigning admission level of care (outpatient or inpatient) • direct impact on what the patient pays and how it impacts the patients use of post-acute extended care services (SNF). • Hospitals inconsistent practices made it necessary for CMS to do something • level the playing field for paying for services. • My opinion – the time-based rule has merit 8 Medicare payment for short stays • In total, Medicare paid $5.9 billion for short inpatient stays, • an average of $5,142 per stay. • In contrast, it paid $2.6 billion for observation stays, an average of $1,741 per stay. Note: Hospitals used inconsistent admission practices Some hospitals were more likely to use short inpatient stays, Others were more likely to use observation or long outpatient stays. 9 What hasn’t changed…. • The Federal Rules (Social Security Act) • rules & regulations for hospitals • The Conditions of Participation • Utilization Review • Discharge Planning • The Interpretive Guidelines (IG) (revised) • What Surveyors look for is ‘rearranged’ • More focus on ‘transition’ • Pilot Process: • Advisory – Blue Boxes 10 Utilization Review • Existing Standards: • Admission review • Continued stay review • Professional Services • Does the patient meet medical necessity for admission? • If yes, which level? • If no, what are the options? 11 3 Reasons to watch admissions 1. EMTALA (Emergency Medical Treatment and Active Labor Act) – still in force – still causing problems (Anti-dumping law) • Determining if the ED patient meets admission criteria is necessary. • Hospitals still being monitored for EMTALA violations 2. DSH (Disproportionate Share Hospital) DSH status. • DSH Hospitals will be getting less money assuming that more patients will have some type of coverage. • What information can you collect at admission that will support the status of an unfunded treatment plan for individuals. 3. The time-based rule changes for hospitals, • ‘presumption ‘ of inpatient admission to Medicare Part A services after 48 hours 12 5 Reasons to watch the clock SNF- CB 3 Midnight Rule Part A after 48 hours Readmission Rates Midnight not the time to Discharge 13 UR: Time-Based Admission review • Review of medical necessity • Predict: severity, intensity and how long the patient is expected to be inpatient! • New ‘approach’ for Inpatient Status • Predict the need for admission • Clinical criteria, services only available as inpatient • Inpatient only list • The 1-2- ‘midnights’: “Presumption” 14 The 2-midnight presumption • The 2-midnight presumption directs medical reviewers to select claims for review • under a presumption that the occurrence of 2 midnights after formal inpatient hospital admission signifies an appropriate inpatient status for a medically necessary claim. • CMS will instruct the Medicare Administrative Contractors (MACs) and Recovery Auditors • that they are not to review claims spanning more than two midnights after admission for a determination of whether the inpatient hospital admission and patient status was appropriate. 15 Default method: Admission order and Certification •Reasonable & Necessary •Inpatient only •Or explain why inpatient needed •Requirement met by either physician notes or by discharge planning instructions •inpatient treatment or medically required inpatient diagnostic study a. Authentication of the Order b. Reason for the inpatient service d. Posthospital care plan c. Estimated time for inpatient • How long [ n hours] needed for inpatient 16 Hospital Inpatient Admission order and Certification (9-5-2013) a. Authentication of the practitioner order: This includes certification that hospital inpatient services are reasonable and necessary and in the case of services not specified as inpatient‐only under 42 CFR 419.22(n), that they are appropriately provided as inpatient services in accordance with the 2‐midnight benchmark under 42 CFR 412.3(e). b. Reason for inpatient services: The reasons for either— (i) Hospitalization of the patient for inpatient medical treatment or medically required inpatient diagnostic study; or (ii) Special or unusual services for cost outlier cases under the inpatient prospective payment system (IPPS); 17 Estimate LOS and plan for discharge c. The estimated time the beneficiary requires or required in the hospital. • • • • Estimate in hours? How? Tests needed (is radiology available)? If using outside reviewers – how long will that take? • Ask for Physician Advisor opinion? 18 “Plans for Posthospital care” d. The plans for posthospital care, if appropriate, and as provided in 42 CFR 424.13. 42 CFR Ch. IV (10–1–11 Edition) • (b) Certification of need for hospitalization when a SNF bed is not available. • (1) A physician may certify or recertify need for continued hospitalization if the physician finds that the patient could receive proper treatment in a SNF but no bed is available in a participating SNF. • (2) If this is the basis for the physician’s certification or recertification, the required statement must so indicate; • and the physician is expected to continue efforts to place the patient in a participating SNF as soon as a bed becomes available. 19 What to document for SNF Level? • Review the MDS (Minimum Data Set) • What terms do they use • RUG-III classification based on the information from the Medical Necessity and Level of Care (MN and LOC) assessment. • What type of therapy? PT, OT, ST • How much? Why? • Need for 24/7 nursing supervision • Why not at home (amount of therapy, comorbidities, ADLs) 20 A word about 3 midnights for SNF • 3 midnight – SNF (Skilled Nursing Facility) Extended Care Benefit • Patient must still have 3 ‘inpatient’ midnights • Observation status – doesn’t count • Admit to inpatient can count starting at the time of ‘inpatient’ stay order • Part A payment not necessary for SNF benefit • Medical necessity for SNF benefit is KEY • Improving Access to Medicare Coverage Act of 2013 (H.R. 1179) – Pending Legislation • Law suit – 9/23/2013 – stays the same – • Observation not inpatient 21 Hospital: 3+ days but no SNF 617,702 beneficiaries had hospital stays lasting more than 3 nights (or more) but did not qualify for SNF extended care coverage 4% (25,245) received SNF services for which they did not qualify • Medicare inappropriately paid $255 million for these services 22 Advice from Surveyors (IGs) • CMS : Center for Clinical Standards and Quality/Survey & Certification Group • May 18, 2013 Ref: S&C: 13-32- HOSPITAL • Surveyors’ Worksheets: update IGs • Advisory Boxes (Blue Boxes): updated interpretive guidelines share practices used to promote better patient outcomes. • Information in advisory boxes is not required for hospital compliance 23 Discharge Planning ‘Advisory Boxes’ • Do discharge planning for ‘outpatients’ (observation) • Develop discharge policies with input from: • Medical staff & facilities that provide after-care • If patient refuses discharge planning – document • The discharge plan does not stop at discharge • • • • Schedule follow-up appointments Filling prescriptions prior to discharge Arrange remote monitoring technologies Follow-up phone calls 24 Discharge Planning ‘Advisory Boxes’ for Surveyors CMS - Center for Clinical Standards and Quality/Survey & Certification Group – Pilot project prior to revisions of IG • Do discharge planning for ‘outpatients’ (observation) • Develop discharge policies with input from: • medical staff • Other facilities that provide care after discharge • If patient refuses discharge planning – document 25 IG: Actions expected by Surveyors • All patients will be screened for discharge needs • How do you screen those outside the criteria • Assessment will be based on the patients preadmission level of care • Staff doing ‘discharge planning’ must be qualified • Patient choice – patient preference – no obligation to develop a discharge plan that cannot be implemented 26 27 Impact of VBP Domains on CM 1. Clinical processes of care: Take care of patient’s medical needs while planning for discharge 2. Patient Experience of Care: score after discharge 3. Outcomes: right next level of care – Hospice 4. Efficiency – (Part A and Part B) How much did Medicare pay for 3 days before admission- the admission - and 30 days after discharge? 28 Key points – value • Know your patients need you to be Case Managers – • Assessment the patient/family • Know levels of care – which one, when, why, expectations • Know your organization needs Case Managers to stay in business! • coders, physicians, CXOs • Know that you are the experts in management ‘across the levels of care’ • Nobody else is • No program or process can succeed without Case Management 29 Thank you. Contact information: Jackie Birmingham, RN, BSN, MS, CMAC [email protected] Or [email protected] Phone: (860)519-4499 30