Revenue Cycle management Services

Medicaid Disenrollment Means Providers Should Rethink Revenue Cycle Management Services

Medicaid unwinding has been a critical topic around revenue cycle management services for months now, and this is because providers will be directly impacted. Most providers should expect to see serious upheaval in their revenue cycle management services as patients are kicked off Medicaid rolls.

Medicaid Unwinding Explained
During the height of the COVID-19 pandemic, enrollment in Medicaid increased, largely thanks to the continuous enrollment provision that prevented people from having their coverage removed. For providers, this meant an unprecedented stability in the Medicaid enrollment in their care communities. But since the end of the public health emergency (PHE) this has changed. The Kaiser Family Foundation (KFF) estimates that anywhere between 8 million to 24 million people will lose their coverage as the continuous enrollment provision unwinds [1]. 

Providers such as hospitals, health systems, home health agencies, and physician practices will need to pay attention, possibly even considering working with a revenue cycle management company. But first, it will be important to understand the possible outcomes during the unwinding. 

How States Will Be Impacted
Not every state will see the same issues, so providers should be working to understand their individual risk. 

For example, Utah is expected to have the highest proportion of members who are taken off the rolls, with a possible percentage difference of 32.5%. After that is Indiana at 28.1%, Minnesota at 27.2%, and North Dakota at 26.5% [2]. States with the lowest impact include:

  • Nebraska
  • Connecticut
  • Kansas
  • Alabama
  • Alaska
  • New Mexico 

Providers in each of these states are already working on plans to adjust. Indiana University Health, for example, is offering personal assistance to members to help them keep their benefits or find a path to new coverage. They’re doing this through financial counselors at their hospitals and cancer centers as well as through community outreach events. 

Florida’s Memorial Healthcare System is in a state that could see around 1 million people disenrolled during the unwinding. The health system is working on auto-enrolling based on information gathered by the state but is also aware that work and preparation will need to happen for people who aren’t able to auto-enroll and who might need support looking for alternative coverage. 

The Uninsured Challenge
During the three-year period of continuous enrollment (February 2020 to March 2023) Medicaid enrollment increased by around 20 million people. This was the reason the uninsured rate fell to its lowest level at the beginning of 2022. Unfortunately, according to the recent KFF survey, only about one-third of states had the ability to project coverage losses around disenrollment, meaning providers will face multiple challenges in establishing revenue cycle management services that align with their needs as uninsured populations rebound [3]. 

Providers should expect that, while renewals resume for Medicaid enrollees, they will see substantial uncertainty around how many people will lose Medicaid coverage, how many will find their way to other coverage, and how many will become uninsured. That said, most providers can be sure that they will see an increase in their uninsured rates, on top of increases in enrollment in CHIP and private health insurance. 

But exact predictions will be difficult. Consider that, since Medicaid enrollment was automatically sustained through the height of the pandemic, some people who are currently listed as enrollees through administrative data could have started working and might now have insurance coverage under an employer. At the same time, the federal surveys that measure uninsured rates (through self-reporting) show smaller increases in enrollment than administrative data. 

Hospitals Could See Mixed Results
Hospitals will need to pay close attention to their revenue cycle outcomes. Hospitals now are dealing with changes from the end of the PHE including shifts in bad debt and charity care as well as other factors tied to the end of the continuous coverage requirement. 

Kaufman Hall reports that the April increases in bad debt and charity care could be directly tied to Medicaid disenrollment. They also report that hospital volumes have dropped, including both inpatient and outpatient. These decreases combined with increases in charity care and bad debt could be a signal that widespread disenrollment is at hand. Erik Swanson, senior vice president of data and analytics believes there is a link. “With states conducting their Medicaid eligibility redetermination, it’s predicted that hundreds of thousands of people will ultimately become uninsured. The data indicate that we may already be seeing the effects of disenrollment materialize with patients less likely to seek out the care they need and a continued rise in bad debt and charity care.” [4]

Hospitals will be navigating these changes while paying more for supplies and labor, stressing the importance of looking for a revenue cycle management company who can help them ride out these trends in the best way possible. 

Nursing Homes Are Waiting to See Outcomes
Even as hundreds of thousands have already been removed from Medicaid rolls, the impact hasn’t been severe for Medicaid-dependent nursing home residents according to McKnight’s Long-Term Care News. Their survey of a dozen sector associations about the end of the COVID-19 PHE and Medicaid unwinding found reports of no significant impact. As a result, members are following their standard processes to continue serving their Medicaid-eligible residents. That said, in Oklahoma, where 70% of disenrollments have been a result of procedural issues (vs. proven ineligibility), neither the Oklahoma Health Care Association or LeadingAge Oklahoma could comment on the situation in nursing homes [5].

How to Approach Revenue Cycle Management Services
This is a time of ongoing uncertainty for providers. Cash flows will undoubtedly be impacted even as expenses are increasing. Providers should be taking a step back to examine their approach to revenue cycle management services, assessing whether they have the ability to monitor and respond to this type of unprecedented change. Most will also need to consider partnering with a revenue cycle management company to navigate the coming changes. To learn more about a revenue cycle management company that can help you in this process, start here.

References
[1] J. Tolbert and M. Ammula, “10 Things to Know About the Unwinding of the Medicaid Continuous Enrollment Provision,” KFF, 9 June 2023. Available: https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-the-unwinding-of-the-medicaid-continuous-enrollment-provision/.
[2] R. Wilson, “How many people could lose Medicaid coverage, state-by-state,” Becker’s Healthcare, 31 March 2023. Available: https://www.beckerspayer.com/payer/how-many-people-could-lose-medicaid-coverage-state-by-state.html.
[3] A. Burns, E. Williams, B. Corallo and R. Rudowitz, “How Many People Might Lose Medicaid When States Unwind Continuous Enrollment?,” KFF, 26 April 2023. Available: https://www.kff.org/medicaid/issue-brief/how-many-people-might-lose-medicaid-when-states-unwind-continuous-enrollment/.
[4] J. LaPointe, “Hospital Finances Break Even as PHE Ends, Medicaid Unwinds,” RevCycleIntelligence, 31 May 2023. Available: https://revcycleintelligence.com/news/hospital-finances-break-even-as-phe-ends-medicaid-unwinds.
[5] J. R. Towhey, “As Medicaid disenrollments surge, concerns about nursing home residents persist,” McKnight’s Long-Term Care News, 5 June 2023. Available: https://www.mcknights.com/news/as-medicaid-disenrollments-surge-concerns-about-nursing-home-residents-persist/.

Home Health Coding Changes under the Home Health Final Rule

Home Health Coding Changes under the Home Health Final Rule

After much speculation, CMS has released the 2023 Home Health Final Rule (HHFR). It includes updates to the home infusion therapy and home health service payment rates for CY 2023. 

Revenue cycle leaders will want to pay attention to these changes from a coding perspective, because it will impact not just home health coding overall, but specifically OASIS coding

How the Home Health Final Rule Intersects with OASIS Home Health Coding 
Under the rule and with the implementation of OASIS-E, a diagnosis won’t exist to put on a recertification OASIS. Still, the orders to take care of the patient and plan of care will have to be coded [1]. 

Know that under the final rule, CMS is ending the temporary suspension of OASIS data collection for non-Medicare and non-Medicaid (home health agency) HHA patients. This means HHAs will have to submit all-payer OASIS data for the Home Health Quality Reporting Program (QRP), starting with the CY 2027 program year. This will require two quarters of data for that program year. CMS is finalizing a phase-in period that runs from January 1, 2025 to June 30 of the same year. Failure to submit data during that period will not result in a penalty [2]. 

Background on OASIS Coding for Home Health
The launch of OASIS-E was delayed because of the COVID-19 pandemic, being rescheduled for 2023 along with the expansion of the Home Health Value-Based Purchasing (HHVBP) model. This delay gave HHAs a bit more time to prepare for OASIS coding requirements and make sure their OASIS data accurately reflected the status of their home health patients. 

OASIS-E implementation launched along with the HHVBP model on January 1, 2023. This means that HHAs who haven’t started will need to begin a transition plan. While rolling out too early is no longer a concern, it will be critical to design a training plan that supports a continuous approach to education that helps clinicians understand the data elements that make up OASIS home health coding and how each of these elements aligns with their care responsibilities. 

How to Ensure OASIS Coding Accuracy
Coders face increased complications under these OASIS changes. They’re dealing with a wide range of documents from multiple providers in multiple care settings. You need to be working with coders who can perform accurate reviews while navigating the changes in information access that have come about in terms of OASIS coding under OASIS-E. These tips will help you navigate increasing complexity and ride the wave of coding changes while improving the health of your revenue cycle. 

Have a Plan
It is important that you approach OASIS coding strategically. While it is possible to simply start training your coders, you’ll likely miss critical opportunities to not only streamline your coding practices, but also to avoid the pitfalls that come with this kind of change. 

Make sure your approach doesn’t simply continue the status quo. Now is the time to align any high-level initiatives you have in improving revenues, increasing efficiency, and improving staff confidence with your OASIS coding training tactics. 

Choose the Best Metrics for Home Health Coding
Part of your OASIS coding plan should be coming up with the metrics you want to monitor as you implement change. Consider prioritizing KPIs in revenue cycle performance. For example, Net Days in Accounts Receivable can help monitor whether you have clean claim issues caused by coding. You’ll find similar results by watching metrics like Aged A/R as a Percentage of Total Billed A/R to monitor how coding issues might be slowing your revenue cycle and A/R liquidation. Aged A/R as a Percentage of Total A/R is also useful in tracking receivable aging and collectability. If it begins moving upward during your OASIS efforts after holding steady or even decreasing, you know this might be an issue. 

Work with Trained Coders
If you’re working with coders who are either newly trained on OASIS coding or aren’t catching on quickly enough, you’ll have issues in home health coding accuracy. These issues can result in unnecessary readmissions and patients not receiving the care they need. 

You will need connections with coders who have the right qualifications and who are able to maintain them without causing you significant burden. This challenge can be a complicated and expensive one, especially considering how often coding requirements change in the home health environment today. This is why many organizations consider working with outsourced OASIS coders instead of taking on the ongoing responsibilities themselves. 

Find the Right Partners
Even if you are absolutely sure you want to build your OASIS coding team in-house, you should consider the option of working with a third-party partner. 

This is because having a few conversations will help you understand the efficiency you could create. You also might be missing awareness of the potential pitfalls around OASIS coding – something you don’t want to discover through trial and error. 

To help you get this conversation started as early as possible, we’d like to invite you to contact us so we can discuss the potential benefits of finding the right OASIS coding partner today.

References
[1] J. Famakinwa, “How Coding Could Change Under The Home Health Proposed Payment Rule,” Home Health Care News, 23 August 2022. Available: https://homehealthcarenews.com/2022/08/how-coding-could-change-under-the-home-health-proposed-payment-rule/.

[2] “CY 2023 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Requirements — Final Rule (CMS-1766-F),” U.S. Centers for Medicare & Medicaid Services, 21 October 2022. Available: https://www.cms.gov/newsroom/fact-sheets/cy-2023-home-health-prospective-payment-system-rate-update-and-home-infusion-therapy-services-0.

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