Administrative Burden Win: UnitedHealthcare Walks Back Plan of Care Change

UHC has dropped a signoff requirement that sparked concerns from APTA.

Date: Wednesday, July 26, 2023

After steering toward a change that threatened to significantly increase the administrative burden faced by PTs, commercial insurer UnitedHealthcare has reversed course on the most problematic elements of its expanded policies. While not specifically citing reasons for the change, the payer won't be requiring additional signoffs for PT services after all.

The most troubling provision of the planned change — essentially an expansion of existing requirements — involved additional signoffs around plans of care. While a plan of care for PT services has always been required by UHC, under the policy expansion, a referring provider or appropriate specialist would have been required to sign and date the plan — a significant administrative hoop for PTs, and a requirement that could potentially delay timely care. APTA expressed its concerns to the insurer.

In the end, UHC backed off on the plan of care signoff requirement, which it adopted in April. Under the change set to take effect Aug. 1, the initial authorization for therapy must also include a plan that identifies functional impairment, short- and long-term therapeutic goals related to the patient's specific functional skills, and anticipated timelines. However, no additional signoffs are needed.

While the most burdensome requirement is now off the books, UHC did hold on to another, less burdensome provision — that PTs must document start and stop times for each follow-up treatment session. The finalized amended policies were shared in a July 10 addendum published by UHC.

"We are pleased that UnitedHealthcare made this decision," said Wanda Evans, PT, DPT, MHS, APTA senior health policy and payment specialist who led the communications efforts with UHC. "These kinds of wins for physical therapy underscore the importance of helping commercial payers understand the real-world effects of potential policy changes on patients and providers."

 

Bipartisan House Lawmakers Introduce Preserving Access to Home Health Act to Protect Patients from Harmful Home Health Program Cuts

PQHH-NAHC Press Statement
 
New report underscores need for policies to ensure timely patient transition to home health following hospitalization 
 
Washington, D.C. – The Partnership for Quality Home Healthcare (PQHH) and the National Association for Home Care & Hospice (NAHC) today commended Representatives Terri Sewell (AL-7) and Adrian Smith (NE-3) for introducing the Preserving Access to Home Health Act of 2023 in the U.S. House of Representatives. If enacted, the bill would safeguard access to essential, home-based, clinically advanced healthcare services by preventing the Centers for Medicare & Medicaid Services (CMS) from implementing cuts as high as $20 billion over the next decade.
 
“The Medicare home health community strongly supports this legislation and thanks Representatives Sewell and Smith for their leadership on a Medicare issue that truly threatens access to care for the more than 3 million beneficiaries who rely on this care,” said William A. Dombi, President of the National Association for Home Care & Hospice. “The home health community calls on Congress to ensure the stability that patients and providers urgently need. Since Medicare has again proposed deep cuts to home health in 2024, Congress must act to protect the care their constituents prefer and want.”
 
Specifically, the bill is designed to address cuts made to home health by CMS during the implementation of Medicare’s Patient Driven Groupings Model (PDGM) by making the following policy changes:

  1. Repealing permanent and temporary Medicare payment adjustments. The bill would repeal the requirement that CMS make determinations related to the impact of behavior changes on estimated aggregate expenditures. The legislation would eliminate CMS’s authority to adjust home health payments based on such determinations under PDGM. This change would take effect, and be implemented, as if it were included in the Bipartisan Budget Act of 2018, which included home health provisions that led to PDGM implementation.
  2. Instructing MedPAC to analyze the Medicare Home Health Program. The bill instructs MedPAC to review and report on aggregate trends under Medicare Advantage, Medicaid, and other payers and consider the impact of all payers on access to care for Medicare home health beneficiaries. To verify MedPAC’s calculations, the Commission would be required to make its calculations public. This provision would also add requirements for Medicare home health cost reports to include data on visit utilization and total payments by program.

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Changes to Form 1-9 and New Options for Employers to Remotely Examine Employees’ Documents

SESCO Management Consultants

USCIS and DHS Announce a Revised Form I-9 and a New Option for Employers to Remotely Examine Employees’ Documents

The U.S. Citizenship and Immigration Services (“USCIS”) has announced that a revised version of Form I-9, Employment Eligibility Verification will be available starting August 1, 2023. The current version can be used through October 31, 2023; however, as of November 1, 2023, only the revised version may be used.

Additionally, the U.S. Department of Homeland Security (“DHS”) has announced that employers who are enrolled in E-Verify will have the option to remotely examine employees’ identity and employment authorization documents. The revised Form I-9 will have a checkbox designated for E-Verify-enrolled employers to indicate when the employer has remotely examined an employee’s documents. This new flexibility option also goes into effect on August 1, 2023.

To take advantage of the new option for remotely verifying employees’ identity and employment authorization documents, the employer must:

  • Be enrolled in E-Verify;
  • Examine and retain copies of all documents;
  • Conduct a live video interaction with the employee; and
  • Create an E-Verify case if the employee is a new hire.

DHS is considering expanding these flexibilities to even more employers, but for now, employers who are not enrolled in E-Verify must comply with DHS’s previous deadline of August 30, 2023, to perform all required physical examination of identity and employment authorization documents for employees hired on or after March 20, 2020, if the employee’s documents were examined only virtually or remotely as was permitted under prior COVID-19 temporary flexibilities.

In its announcement, USCIS also highlights the following new features of the Form I-9:

  • Sections 1 and 2 are consolidated into a single page.
  • The I-9 is available as a fillable form on tablets and mobile devices.
  • The “Preparer/Translator Certification” section is now a standalone supplement of the form, permitting employers to provide employees a copy of that single page as needed.
  • Section 3 for reverifications and rehires is now a standalone supplement of the form that employers can print whenever a rehire or reverification is required.
  • “Acceptable Documents” include receipt notices for certain filings that automatically extend employment authorization, along with related guidance and links to information.
  • The form instructions are reduced from 15 pages to 8 pages.
  • A checkbox has been added for employers enrolled in E-Verify to use in performing remote examination of employees’ identity and employment authorization documents (as previously noted above).

If you are not a retainer client, contact us to learn about our services by calling 423-764-4127 or click here.

 

Study Highlights Physical Therapy’s Clinical, Financial Benefits Among Medicare Beneficiaries

Home Health Care News | By Patrick Filbin
 
Increased physical therapy (PT) utilization is associated with significant reductions in hospitalizations and emergency room visits, more evidence shows.
 
Meanwhile, home health providers are still grappling with how to manage physical therapy under the Patient-Driven Groupings Model (PDGM).
 
A new study from the Alliance for Physical Therapy Quality and Innovation (APTQI) showed that an increase in PT among Medicare patients could reduce health care spending by $10 billion.
 
PT users were 50% less likely to visit the emergency room or be hospitalized for a follow-up injury in the six months following their initial fall, according to the study.
 
An important distinction, however, is that the data tracked users who had already experienced a fall.
 
“A lot of people are going to end up in home health because after you fall, you may be homebound for a bit,” Nikesh Patel, executive director of APTQI, told Home Health Care News. “I think what this shows is that whatever setting those PT sessions are happening post-fall, you’re going to have a significant decrease in the likelihood of falls in the next six, 12 and 18 months.”
 
The results confirm what physical therapists have known for a long time, Patel said: that PT is a safe and effective method for helping seniors build the strength and other necessary skills to avoid future falls and reduce costly expenditures.
 
The U.S. Centers for Medicare & Medicaid Services (CMS) implemented PDGM on Jan. 1, 2020. Prior to PDGM, home health agencies were paid per therapy visit under the home health benefit in Medicare Part A. Now, payment is tied to patient characteristics.
 
At the beginning of 2020, many believed there would be an inevitable disruption to home health therapy utilization.
 
Today, it’s still unclear exactly how PDGM has impacted therapy utilization. Following the implementation of the new payment model, providers were naturally less likely to offer therapy services because they were not as incentivized to do so.
 
The study’s findings are another example of how PT can offer savings to the entire health care sector.
 
“For me, the most telling statistic was that for every 100 Medicare beneficiaries, we average in the U.S. about 21 hospital stays,” Patel said. “Of those hospital stays, 40% of those are fall-related. If you have a decrease of four to six hospitalizations and inpatient stays for a year, the costs are staggering.”
 
According to the study’s authors, increased PT use by 100 beneficiaries prone to falls could result in an offsetting reduction in total health care spending of as much as $61,400 to $91,900 per member.
 
When considering the 13.5 million Medicare beneficiaries who are not enrolled in physical therapy, that could create $10 billion in savings.

 

Study: Older Dementia Patients Go to ER Twice as Often as Other Seniors

Washington Post | By Erin Blakemore
 
Older people with dementia seek care in the emergency room twice as often as their peers, a new analysis suggests — leading to what researchers call “potentially avoidable and harmful visits” for some patients.
 
The study, published July 24 in JAMA Neurology, examined data from the 2016-2019 National Hospital Ambulatory Medical Care Survey, which collects demographic and other information about a nationally representative sample of ER visits. About 1.4 million of the annual 20.4 million ER visits among adults over 65 involved patients with Alzheimer’s disease and related dementias, researchers found.
 
Patients with dementia presenting at the ER were more likely to be age 85 or older and female. The most common reasons for seeking care were accidents (7.9 percent), behavioral disturbances (7.4 percent) and general weakness (5.3 percent).
 
Once they got to the ER, patients with dementia were likelier to receive diagnostic tests such as CT scans and urinalysis — perhaps because of communication issues or behavioral concerns. They also were twice as likely to receive antipsychotic medication, which is cause for concern, the researchers write, because of the risks of taking such drugs and the potential for them to continue being used long-term. (Antipsychotics are associated with higher mortality risk and life-threatening falls in older adults.) They were less likely to be prescribed opioids than their counterparts.
 
The statistics reflect challenges in the daily lives of people with dementia, who may behave erratically and often cannot communicate about their symptoms. Despite these challenges, the study says the ER is often not the best place to care for adults with dementia due to long wait times, unfamiliar staff and a potentially disorienting environment.
 
The researchers call for better caregiver supports and the development of more geriatric-friendly emergency rooms, although they acknowledge that in some situations emergency care is needed.
 
“While dementia is thought of as a cognitive or memory disorder, it is the behavioral aspects of the disease such as anxiety, agitation and sleep disturbances that can cause the most stress for caregivers and patients alike,” study co-author Lauren B. Gerlach, a geriatric psychiatrist at Michigan Medicine and an assistant professor in psychiatry at the University of Michigan, said in a news release.
 
“Emergency departments are often not the right place to manage these behaviors,” she added. “We really need to do better to support caregivers so there are options other than seeking emergency care.”

 
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