Analyze these changes to understand how to navigate your business in the coming months
by Tom Ryan
January 9, 2014

It’s 2014, and a lot of changes will take place this year that will directly impact the home care industry and how business is conducted. But before we look toward the future, it’s worthwhile to spend some time reviewing a little of what happened in 2013. The power mobility prior authorization demonstration project really took off this past year. A major project for AAHomecare, the Association collaborated with CMS to address a number of concerns and make adjustments to the project that minimized its negative impacts on providers and patients. Of course, the 800-pound gorilla has been, and continues to be, the national “competitive” bidding program. Round 2 contracts began July 1, 2013, and since then it has become increasingly clear that the program’s absurdly low reimbursement rates will continue to force significant consolidation within the home care industry at the expense of small providers and their patients. Large providers aren’t immune to its effects either. In a recent AAHomecare survey, only two out of 14 national companies saw any positive benefits from the program. People for Quality Care’s patient complaint hotline has documented more than 2,700 calls—
indisputably proving that CMS’s complaint numbers are grossly underreported. January 1 brought with it the Round 1 Rebid contracts. When the reimbursement rates were announced, the additional reductions shocked even the cynical among us. While it remains to be seen how much damage will be done by the bidding program to the home care safety net, we have every reason to hope that Congress will finally act. On the regulatory front, 2014 will be a busy year with at least three major initiatives taking effect. We’ve been preparing for them for quite a long time, so there are no surprises now that they’re finally here. Our job as HME providers is to make certain that we understand all of the nuances in these new regulations and do our best to comply with them so that—to the extent possible—we avoid disruptions to our businesses from denials, audits and recoupments. The end-stage renal disease (ESRD) prospective payment system final rule took effect Jan. 1, affecting routinely purchased HME items that were reclassified to capped rental items in all areas of the country where those items were not included in a Round 2 or Round 1 recompete bidding area. For reclassified items provided in bidding areas, the effective dates have been pushed to either 2016 or 2017, depending on the bidding areas involved. In the final rule, 78 Healthcare Common Procedure Coding System (HCPCS) codes were reclassified. The Medicare Provider Enrollment, Chain and Ownership system (PECOS) has been rolled out in phases, with denials for non-enrolled power mobility device ordering/referring providers scheduled to take effect April 1. Implementation will begin April 7. MLN Matters No. MM8239, published by CMS in 
November 2013, includes a list of HCPCS codes that will be subject to denials, as well as a list of approved physician and non-physician specialty codes. HME providers are required to check PECOS. When a filed claim is denied because 
of an ineligible ordering/referring 
provider, it will include claim adjustment code 183 and remittance advice remarks code N574. Once again, the Face-to-Face Encounter Rule has been scheduled for implementation. After a number of delays, due to continued concerns that some HME providers may need additional time to establish operational protocols necessary to comply with the requirements, CMS hopes to have everything in place sometime in 2014. However, the Agency expects that providers will have used the delays to prepare their staffs, and AAHomecare urges providers to be fully compliant as soon as possible in case enforcement turns out to be retroactive. It was a busy 2013 for AAHomecare, its members and others in the industry who make the effort to get involved solving problems that affect everyone. It appears that 2014 will be no different. The growing audit crisis, ICD-10 implementation, the power mobility repair mess and legislation to end the bidding program will take center stage. The year ahead will be a challenging one, but we can adapt to the changes and use them to strengthen ourselves as we move on from yesterday and ready ourselves to face tomorrow.