A recent survey of home care software vendors with products aimed at Medicare billing reveals that the task of upgrading for CMS’s new PPS rules is a large one but that all expect to offer releases to their customers by mid-November at the latest. Though most would have preferred a little more time than the less than three months from the date the final rule was published on August 29 through the November 3 date when the first start-of-care’s could stretch into 2008, they all promised they would be ready in plenty of time for their customers.
Asked when they planned to release new versions, the majority said November 1. The earliest prediction was October 1 and the latest December 19. One indicated they planned monthly releases from September on but that they offer a hosted application, meaning their customers do not have to become involved in that frequent upgrade schedule. About half said they will be prepared for an emergency tweak to their application at the end of December, should Congress of CMS issue last-minute changes. How much work has this regulatory update been for your software vendor?
- None rated it a “small” task, requiring fewer than 100 programming hours
- A little more than a third described it as “medium,” requiring between 100 and 300 hours
- Half described the talk as “large,” pulling their programmers from other jobs for 300-500 hours
- A small number, fewer than 15%, called it “XL,” requiring more than 500 programming hours
At first, none of the vendors said they planned to take on additional temporary programming staff to get the job done in time. When the final rule appeared, however, closely followed by the updated “pseudocode” – which programmers use to create your grouper – some indicated they may change their mind. One added that additional staff might be needed during the testing phase.
Regarding additional programming staff and the pseudocode, one vendor exclaimed, “It resorts to ‘Julian’ dating!
Where am I going to hire programmers old enough to remember how to do Julian dating?” CMS’s Wil Gehne explained in his presentation at last week’s NAHC meeting that Julian dating enabled federal programmers to avoid increasing some field sizes. By far, the largest part of the task was creating the new multiple therapy threshold system to replace one single threshold, then building the formulae behind them. Following that, vendors said, updating OASIS questions and formats was the second most demanding job. After those two major programming chores, vendors said they decreased in demand volume from adding case-mix calculations to creating equations for later contiguous episodes to building new RAP formulae and finally, the easiest, and happiest chore, eliminating SCIC.
Many home care providers are concerned about how to handle episodes that begin during 2007 but end in death or discharge after the first of the year.
All vendors said they would handle that situation by automatically detecting the date and adjusting pay rate appropriately. Some remain unclear how to calculate the payment formula for supplies used during year-straddling episodes but CMS has already indicated there may soon be a grace period announced for that situation. Where this section got tricky was when CMS decided the five-day OASIS window would apply for early 2008 episodes, meaning that the new version of OASIS must be used starting December 27.
This may be one area where each agency should look for communications from its vendor for guidance.
In order for agencies to adapt their clinical and financial policies so that they both comply with and thrive under the new payment rules, different types of reports may be needed. Half of the vendors surveyed said they planned to anticipate what you need and prepare new reports for use in 2008. Another full half said their systems already give control over reported fields to the user and that, therefore, they do not plan significant changes. About one-quarter added that they would be ready to build custom reports on request. Some said they would do two or more of these things, explaining the higher than 100% total for this question. Perhaps one of the most significant questions was whether vendors had to delay other software development tasks in order to devote resources to PPS changes. A full three-quarters said ‘yes’ they did put off other projects. If you have been waiting for one of those other projects, perhaps a little patience and understanding will be required for a time.