NY–RAH Facilities Closing in on $10M in Additional Revenue through Year 3

NYRAH facilities earned a total of $9.9 million in additional revenue from the facility payment incentive codes (G9679-G9684) throughout the first three years of Phase Two. During its monthly review of CMS claims data, the NYRAH team noticed that facilities that bill on a regular basis have benefitted the most from the payment incentive codes. Of the 54 participating NY RAH facilities, 12 earned $250,000 or more since November 2016. Each of the 12 has billed at least once in the past three months, with seven of the 12 billing twice in that period. These high-performing facilities have processes and workflows in place to ensure they consistently capture the qualifying conditions (there is no cap on the number of conditions that can be billed for). These processes also enable facilities to continue to improve their ability to recognize, treat, and document for the six qualifying conditions. The success that is possible from a more dedicated focus was demonstrated by one NY RAH facility that only billed for one episode up until a year ago, when it implemented a billing process that has since allowed it to earn more than $60,000 in additional revenue.

Throughout the initiative’s final year, the NY
RAH Data Team will continue its monthly review of CMS claims data and hopes to see improvement in the amount of revenue earned and the number of claims billed. Facilities currently receive a Monthly Billing Report to highlight their billing practices. Moving forward, facilities that have not billed in the last three months will receive an additional email to highlight when they received their last payment for a NYRAH claim. NY RAH encourages all facilities to continually review their billing workflows and processes and urges facilities that do not bill as often to address their process breakdowns. 

If you have questions or would like to discuss improving your facility’s billing workflow, please contact Faiza Haq.

NY–RAH QISs Working to Increase Rate of Advance Directives for Facilities

During the third quarter of 2019, the Group B Quality Improvement Specialists (QISs) reviewed the transfers listed in the Potential Missed Opportunities Dashboard report to identify common themes and potential areas for improvement. Their goal was to create Quality Assurance Performance Improvement (QAPI) Performance Improvement Projects (PIPs) in collaboration with the facilities with which they work. Four of the 25 Group B facilities are working on PIPs related to increasing the number of advance directives completed and the number of advance directive and palliative care conversations conducted. This focus is a continuation of NY RAH’s palliative care clinical intervention that carried over from Phase One. In some instances, the QISs identified process gaps in identifying residents who are appropriate for palliative care. They also noticed opportunities to educate staff about the differences between hospice and palliative care. In addition, residents and families that declined to discuss advance directives upon admission were not provided with opportunities for later conversations to address the need for advance directives. The QISs are actively working with facility staff to implement new processes and increase staff awareness to screen residents who are appropriate for palliative care with the INTERACT palliative care tools.

To further support these efforts, NY
RAH’s Medical and Palliative Care Director, Joseph Sacco, MD, will train staff at facilities. The trainings will be customized based on specific projects and will incorporate the palliative care tools from the Phase One palliative care intervention. NYRAH encourages each participating Group B facility to use the advance directive tracking form in the NYRAH Data Portal to accurately capture the advance directives of the eligible residents and compare their facility against other participating facilities using the quarterly Palliative Care Report to find opportunities for improvement. National Healthcare Decisions Day (NHDD) -- an annual event to empower residents, families, and staff to document their health care decisions and complete health care proxy forms -- is only five months away, on April 16, 2020. NY RAH encourages all facilities to begin thinking about ways to incorporate and promote NHDD at their facility.

If you have questions about the palliative care interventions or advance directives, please contact Joseph Sacco, MD.

NY–RAH Updates Facility Chart Audit Tool

The NYRAH team originally released the Facility Chart Audit Tool in early 2018 to ensure that all claims billed under the facility payment incentive codes are compliant with CMS Nursing Facility Initiative (NFI) criteria. The Excel-based tool helps facilities track potentially billable episodes and determine, based on the information entered, which episodes they can bill. To use the tool, facilities input resident information; dates for the episode, documentation, and billing; and which clinical criteria the resident met to qualify for the condition. The tool uses built-in logic to provide instant feedback based on the data entered.

RAH sent out an update to the tool earlier this year to reflect the clinical criteria changes that became effective January 1, 2019. In the next few weeks a newer version of the tool -- containing updates based on facility feedback -- will be sent to all facilities. The revised tool will include a reference column that auto-populates the last potential day of billing based on the maximum benefit period for the condition and the day the acute change of condition (ACOC) was first noticed, along with a summary sheet that provides aggregate data on all episodes entered into the tool. NY RAH will release two versions of the revised tool, one with the aforementioned changes and a second version that will also include a resident eligibility field for facilities to double-check that claims are submitted only for eligible residents (long-stay, Medicare A & B FFS, no Medicare Advantage, no hospice). NYRAH encourages all facilities to use the tool to track facility episodes and to ensure that all criteria are met prior to billing.

If you have questions or would like to discuss the NY
RAH Facility Chart Audit Tool, please contact Faiza Haq.

NY–RAH Continues to Promote Practitioner Engagement

Under the NFI, practitioners can benefit from a new code, G9685, for initial visits when assessing residents experiencing ACOCs. To ensure all practitioners are aware of their billing practices, NYRAH will email all eligible practitioners in the next few weeks with their current number of paid G9685 claims within Phase Two. Practitioners can use the resources available in the email to begin or increase their use of G9685. 

G9685 reimburses at the same rate as the highest-level inpatient hospital admission code (99223) and can be used in place of the typical SNF follow-up codes (99307-99310) -- all of which reimburse at a lower rate. NY
RAH’s Clinical Project Specialists have worked closely with medical directors and eligible practitioners to encourage use of this code and to improve practitioner processes. In October, NYRAH released a new case study on the practitioner patient incentive that highlighted the work of Beth Murray, NP, at Smithtown Center for Rehabilitation & Nursing Care. Ms. Murray created a successful G9685 workflow, maximized use of the code, and built an interdisciplinary team approach at the facility. NYRAH sent the case study to all eligible practitioners and hopes they find it helpful in improving their own workflows related to G9685 billing. NY RAH also connected Ms. Murray to a practitioner at another participating facility who faced challenges using the enhanced code. After the connection, the practitioner was able to use NYRAH resources and Ms. Murray’s experience to create a workflow, and has since submitted her own G9685 claims. 

For practitioners who believe their claim count number listed in the email is incorrect, please contact NY
RAH immediately, and we will investigate. For questions about the practitioner payment incentive or to speak to a NY–RAH Clinical Project Specialist, please contact Faiza Haq.

In Case You Missed It

GNYHA, DOH Release Training Video on Cleaning C. auris
Candida auris (C. auris) is a hospital-acquired, multidrug-resistant bloodstream infection that has spread throughout health care institutions in New York State. A nursing facility resident could be infected and not necessarily show symptoms. To reduce the spread of infection, Greater New York Hospital Association (GNYHA) and the New York State Department of Health (DOH) created a training video to show environmental services staff how to clean the room of a resident who tests positive for C. auris. The video demonstrates the process for both daily and terminal cleanings. NY RAH encourages facilities to share the video with environmental services staff as part of your facility’s Infection Prevention and Control Program; infection control in-services and staff trainings are specifically required under Phase Three of the CMS Long-Term Care Facility Requirements of Participation, effective November 28, 2019.

These videos can be accessed via the following links (no log-in required):

MBI Transition Period Ends December 31
CMS recently released a reminder to providers that beginning January 1, 2020, all Medicare transactions must be submitted using the Medicare Beneficiary Identifier (MBI) instead of the Health Insurance Carrier Number (HICN). CMS will reject any claim submitted with a HICN on or after January 1, 2020, with few exceptions.

CMS transitioned to MBIs last year to comply with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA required CMS to remove social security numbers from all Medicare cards by April 2019. CMS established a transition period for providers to submit claims using either the beneficiary’s HICN or MBI. This transition period concludes on December 31.

      NY-RAH is supported by Funding Opportunity Number 1E1CMS331492-01-01 from the US
Department of Health and Human Services, Centers for Medicare & Medicaid Services. The
contents provided are solely the responsibility of the authors and do not necessarily represent
the official views of HHS or any of its agencies.