By Tim Rowan. Editor & Publisher, Home Care Technology Report

As we continue to keep readers informed about the impact of CMS’s Pre-Claim Review pilot, we spoke this week with two software vendors, a CMS connection service provider, and two consultants, one a financial advisor and the other an appeals resolution specialist. We believe we are getting a handle on the pros and cons of the new rule but reserve the right to update our analysis as more details come to light, especially after we interview HHAs in the first pilot state, Illinois, when the rule kicks in sometime in August.[The author focuses on the key dilemma to be handled by software vendors–namely, their knowing that significant changes in their software products will need to be undertaken to have it readied for CMS’s pre-claim review pilot program but CMS is not forthcoming about the needed changes. Similarly, providers of CMS connection services notes a lack of communications about providing up-to-date and concise information on, in particular, forms 835 and 837. Additional  lack of information provided by CMS representatives to healthcare at home agencies is indicated, and the article closes with a summary about  the pre-claim review rule pilot program . by Michael McGowan (former OASIS coordinator for CMS Region IX and designer of OperaCare software). He offers his views on chronic recertification of patients home health agencies in the past.]


Software leads off
EMR software vendors are the first to be affected, whether they have a hundred. Software updates must be made across the board even if they only have a few customers in the five states in the pilot. The basic framework of the changes they need to deliver to the customers are in place but CMS will not tell them until June 28 what the final details will be. For example, in their June 14 conference call, CMS representatives were taken aback when a questioner pointed out to them that the 837 field they want to use to hold the pre-claim approval number when submitting the final claim is a field that is already used for another purpose. “We’ll get back to you on June 28 about that,” they sputtered, unable to disguise the embarrassed tone in their voices.

“Here’s what you have to understand about how vendors handle regulatory upgrades,” explained Delta Health Technologies’ Bill Bassett. “There are always going to be changes, whether it’s the Comprehensive Joint Replacement payment bundling that was announced six months before its implementation date or this one, which only gave us a six week warning. You have to read the tea leaves and be prepared for anything. If you are light on your feet, by which I mean you have SaaS or web-based software, you make the change and all your customers have it that day. The vendors who will struggle with getting the details on June 28 and having them ready for Illinois customers by August 1 are the ones with legacy, client/server systems on 20 year-old database technology.”

Connectivity up second
Providers of CMS connection services have to make August 1 changes as well and are anxiously awaiting the rest of the story CMS promised to deliver on June 28. We spoke with Ellie Robison, CEO of MedTranDirect, who told us it will make a big difference whether an unused field can be found on the 837 form to insert the pre-claim approval number or whether the form will have to be redesigned.

“We are ready to update our product that transmits and receives 837 and 835 documents,” she said, “and we would like to be able to transmit the stack of pre-claim documents. There are a few questions that have to be answered before we can do that though.”

She is referring to the way the CMS representatives dodged the answer to a question during their June 14 Open Door forum. When informed that the field on the 837 form they told HHAs to use is already used for another purpose, they muttered, “We’ll let you know about that on June 28,” failing to disguise the embarrassment evident in their tone of voice.

When asked whether plans of care have to be signed by the physician in time for the pre-claim submission or can wait until the final claim, as is the rule now, the answer was again profoundly unclear. “No other rules are changed,” was the best they could do when confronted with the unexpected question. No one we spoke with is sure exactly what that means.

Batting third, HHAs themselves
Nothing made it more clear that CMS is unfamiliar with the day-to-day challenges of operating a home health agency than their cavalier non-answer to the signed plan of care question. Every agency administrator knows the fiasco that occurred when physicians were required to certify homebound status under the Face-to-Face rule. Failure to get it done, signed, and correctly worded caused a phenomenal number of payment denials that could not be avoided or repaired by the agency itself.

The same resentment regarding perceived unnecessary encroachment on their time crops up among physicians when asked to review and sign plan of care documents. Most providers have difficulty getting them signed by the end of a 60-day payment episode so that they can submit a final claim. If MACs interpret the new rule as meaning they can deny a pre-claim review over a missing signature, which is possible if CMS leaves the question unanswered, HHAs will have to bug physicians to sign the document at the beginning of an episode.

“They are not going to like that,” asserted Deanna Loftus, Director of Regulatory Compliance for HEALTHCAREfirst. “We provide outsource billing services and electronic document signing as well as EMR software and we know firsthand that the primary billing delay is the physician signature. Getting it 50 days sooner than they do now will be extremely difficult.”

Cleanup: the consultant’s overview
“What took them so long?” was Michael McGowan’s surprising reaction. “Over the years, I have seen so many fourth, fifth, and sixth consecutive episodes for low-acuity patients, I finally got to the point where I wondered why CMS wasn’t seeing the same thing. This new rule forces agencies to play by the rules. It will be good for the patients, good for the tax payers, and good for the high-performing HHAs.”

The former OASIS coordinator for CMS Region IX and now a payment denial consultant and designer of OperaCare, a new software tool designed to produce perfect, audit-proof episode documentation, McGowan offered this bird’s eye view of the environment the Pre-claim approval rule is trying to improve:

“There are more HHAs than the population numbers require. With supply outstripping demand, many HHAs are suffering with census numbers too small to sustain payroll and overhead. There are two ways to keep census numbers up: find new patients or keep the current ones. With every sales rep finding his or herself one of ten or twenty hitting physician offices every day, winning new patients is hard. Recertifying patients, no matter how unjustifiable in terms of medical necessity and homebound status, is much easier.”

This cause-and-effect logic string that McGowan describes is coming to an end, at least in the five pilot states, and is becoming the primary focus of attention for MAC auditors in every state. “These are the states that are the worst offenders,” he told us, “so controlling the problem in 10% of the states will solve much more than 10% of the problem.

“Here is how it will happen. Agencies that have been surviving on recerts will see most of them disapproved in the new pre-claim process. They will perceive this as MAC overreach but that will mostly not be the case. These are episodes that should not be paid. Unable to be paid anymore to care for relatively healthy patients, their census will shrink and they will either figure out a way to improve their sales results or they will close or be acquired. The ethical agencies that have been discharging patients when they should will see few if any of their episodes disapproved for lack of medical necessity through the new pre-approval process. They will be the survivors. They will pick up patients from the agencies that close or from the struggling agencies they acquire. In the end, the smaller number of HHAs will match the population demand and everyone left will have enough census to stay afloat.”

This consultant is not alone in his analysis that there could be an upside to the rule. We recruited an Illinois agency to keep us informed through the August launch. Susan Platt’s opinion of the new rule mirrors Mr. McGowan’s.

“We agencies who are working to do it right, to get the face to face documentation correct and signed, to ensure our clients are truly homebound and have a skilled need, we abhor this rampant fraud and abuse. So we understand the idea behind this new rule. I am sick to death of trying to compete against agencies who see patients forever, sign them up for med set ups, etc. Since this new rule isn’t supposed to create a barrier or delay in starting care, the concept of stopping agencies who sign up inappropriate patients is great.”

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


By Tim Rowan, Editor & Publisher, Home Care Technology Report


Santa Monica, CA – June 23, 2016 –Cedars-Sinai hospital in Los Angeles will announce today that it is launching “Safe Transition Home,” a partnership with HomeHero, a Santa Monica-based, non-medical home care provider. The program is designed to smoothly transition patients from the hospital to their homes with the goal of reducing inpatient readmissions, raising patient satisfaction and improving health outcomes. We spoke with Mike Townsend, co-founder of HomeHero about the new program.

Mike Townsend

“We are essentially expanding our non-medical home care services to include transporting people who have no available family or friends on the day of discharge from a hospital stay,” Townsend told us. “We will dispatch a caregiver, who will go into the hospital room, accompany the patient out the door, help the patient into his or her vehicle, and drive the patient home. Once home, the caregiver will help the person inside and conduct a safety inspection, based on the patient’s condition and needs.” After providing transition services, Townsend expects that his agency will be hired to continue to provide non-medical in-home care.

HomeHero is one of 11 startups participating in the 2016 Techstars Healthcare Accelerator, in partnership with Cedars-Sinai, to develop healthcare innovations. The accelerator is a partnership between Cedars-Sinai and Techstars, a global ecosystem for entrepreneurs to bring new technologies to market. [More details about the planned work between Cedars-Sinai hospital and other innovative partners like HealthHero to assist discharged patients return home and reduce hospital readmissions are provided in this article.]

“We are truly excited to be working with HomeHero, both at the operational level and within the Cedars-Sinai and Techstars Healthcare Accelerator program,” says Bradley T. Rosen, MD, MBA, FHM, Director of Care Transitions and Complex Medical Management at Cedars-Sinai. “They are a mature team with impressive individuals on both the healthcare and tech sides, and they are thinking creatively about how best to tackle fundamental challenges in patient care. I believe the Safe Transition Home program is the first of many initiatives that will effectively improve the quality of care our patients receive.”


The Safe Transition Home program aims to address long-standing transitional care challenges by providing licensed and trained home care professionals as a post-acute extension of Cedars-Sinai’s healthcare continuum. Townsend told us he will be looking for other partner hospitals if the Cedars-Sinai pilot proves successful.


The program also helps Cedars-Sinai address comprehensive regulatory changes set in place by the Affordable Care Act and CMS, such as steep fines for 30-day hospital readmissions and bundled payment systems emphasizing value-based care. HomeHero’s caregivers, referred to by the company as “Heroes,” provide assistance with activities of daily living such as personal care, housekeeping and medication management. Safe Transition Home covers additional services such as transportation to and from follow-up appointments with the patient’s physicians.


Caregivers also become the eyes and ears of the hospital in the home with the aid of a mobile app. The “Heroes” conduct guided safety checks in the home, record patient health information, monitor social determinants and deliver critical real-time data back to families and hospital case managers.


“The first six weeks of our time at Cedars-Sinai has been spent learning about the deep inner-workings of hospitals and identifying the biggest areas of need,” said Kyle Hill, Townsend’s partner and co-founder and CEO of HomeHero. “We felt Safe Transition Home was the best program to build first due to its low cost and risk, broad impact across multiple units and speed to implement.”

The program is funded through a combination of private clients and Cedars-Sinai.


About HomeHero

HomeHero is a non-medical home care provider based in Santa Monica, California, offering post-acute services such as personal care and companionship, transitional care, postoperative recovery, medication management, transportation and assistance with activities of daily living through hundreds of licensed and trained caregivers. Launched in May 2013 by Kyle Hill and Mike Townsend, originally as a service for their own families, HomeHero has grown to be one of the largest home care providers in California. Recently, the company made the decision to transition all of its field staff from 1099 to W-2 employees. The company has raised $23 million in venture funding from Graham Holdings, Social+Capital Partnership, Science Inc, The Launch Fund, Tencent Holdings, Techstars and Cedars-Sinai Medical Center.


About Cedars-Sinai

Cedars-Sinai, the largest nonprofit academic medical center in the western United States, is known internationally for providing the highest-quality, most advanced patient care. Over its 113-year history, Cedars-Sinai has evolved to meet the needs of one of the most diverse regions in the nation, setting standards in quality and innovative patient care, research, teaching and community service. Cedars-Sinai has a long history of transforming healthcare — at the bedside, in the clinic and in the community. Innovations from Cedars-Sinai include the invention of the Swan-Ganz catheter to measure blood pressure inside the heart, the start-up of a company that developed one of the world’s top evidence-based clinical decision-support systems for physicians, and the first experimental use of stem cells to cure heart disease.

About Techstars

Techstars is a global ecosystem that empowers entrepreneurs to bring new technologies to market wherever they choose to build their business. With 18 mentorship-driven accelerator programs worldwide, Techstars exists to support the world’s most promising entrepreneurs throughout their lifelong journey. Techstars provides access to over 3,000 founders, mentor investors, and corporate partners, allowing entrepreneurs to accelerate the pace of innovation and do more faster. Techstars makes entrepreneurship more accessible by providing access to capital, guidance, marketing, business development, customer acquisition, and recruitment.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


Tim Rowan, Editor & Publisher of Home Care Technology Report 

Curaport, to whom we introduced you last month, has partnered with Ankota CEO Ken Accardi to deliver a timely education session to Home Care providers. “How Homecare Wins in the Bundled Payment Era” is scheduled for Thursday, June 23, at 1:00 p.m. EDT. Register here. [Details are provided in this article about the webinar’s focuses on new payment options for healthcare at home service billings.]

Ken will help you:

 Understand the new payment changes for post-acute care
  • Introduce new optimized care delivery models
  • Discuss business models that enable you to win referrals and control costs
 With so many payment, reimbursement, and regulatory changes barging into the Homecare industry, Ankota & Curaport will help quiet the noise and help you know what you really need to be planning for regarding Bundled Payments.
 Curaport’s mission is to deliver relevant and impactful education and information to a market segment whose disparate parts are growing together – and to do so in a manner that can be understood and applied. According to co-founder Tripp Matthews, “We want to Curate the content that exists, and bring the experts and tools to you.”

Ken Accardi is a technology executive with a broad experience base. He has served as CEO, CTO, CIO, VP of Business Solutions, Director of R&D, and VP of Process/Quality. Ken’s passion is to drive entrepreneurial growth via new product introductions with a strong preference for healthcare IT.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


 By Tim Rowan, Editor & Publisher, Home Care Technology Report

The Alliance for Home Health Quality and Innovation (the Alliance) today released a new data analysis from Dobson | DaVanzo & Associates that found the use of home health after a hospital stay is associated with cost effective care and lower readmission rates for Medicare patients who have undergone major joint replacement surgery. The analysis examined the distribution of discharges for patients from the hospital to various post-acute care (PAC) settings, the average Medicare payment per episode by first PAC setting, and the average readmission rate for related conditions within the Centers for Medicare & Medicaid Services’ (CMS) Comprehensive Care for Joint Replacement (CJR) model.[Details about the scope of this study–numbers of patients by MSA regions and readmissions of these patients–are provided in this article. A quote from Teresa Lee, Executive Director of the Alliance, summarizes the value of this study:  “This new data analysis establishes home health care, when clinically appropriate for patients, as a valuable, cost effective partner for hospitals and other conveners to collaborate with in delivering quality care while also achieving cost savings for patients, providers, and taxpayers.” A link to the this study is provided.]


Launched in April of this year in 67 metropolitan statistical areas (MSAs), CMS’s goal for the CJR model is to provide Medicare beneficiaries undergoing major joint replacement with coordinated, high quality, cost-effective care. This bundled payment model begins upon admission to the hospital and ends 90 days post-discharge, making the care received after the initial hospital stay and preventing readmissions critical components to reducing health care costs and improving care quality.

The MSA-level data analyzes the distribution of post-acute care services for MS-DRG 470 patients (major joint replacement without major complication or comorbidity) and revealed that on average, when home health was the first PAC setting after hospital discharge, episodes have significantly lower Medicare episode payments and readmission rates when compared to patients discharged to facility-based settings.

When looking at the various MSA regions, home health care accounts for 41 percent of discharges, but within regions, the use of home health spans a wide range. For example, in New York City, just 16 percent of patients are discharged to home health compared to 48 percent in Boulder, Colorado.

The data also points to significant cost savings for the Medicare program when patients enter home health care following a hospital stay. Across all settings and MSAs, the average Medicare episode payment for MS-DRG 470 CJR episodes is $24,900, but when home health is the first PAC setting, the average payment drops to about $19,900.

Readmission rates for all settings and MSAs for MS-DRG 470 patients average eight percent. However, patients receiving home health care immediately after an acute stay see a readmission rate of just five percent, compared to 12-15 percent for patients receiving rehabilitation in facility-based settings. Patient severity, aside from MS-DRG and presence of a fracture, was not controlled for in the analysis, but previous research conducted by Dobson | DaVanzo & Associates and other researchers suggests the presence of some overlap in clinical characteristics of patients that are admitted to different settings of care.

“In the post-acute care space, bundled payment initiatives, such as CJR, will be an essential part of achieving a health care system that rewards value-based approaches over the quantity of services provided,” said Teresa Lee, Executive Director of the Alliance. “This new data analysis establishes home health care, when clinically appropriate for patients, as a valuable, cost effective partner for hospitals and other conveners to collaborate with in delivering quality care while also achieving cost savings for patients, providers, and taxpayers.

“The Alliance stands ready to work with CMS and lawmakers as they reform the health care delivery system to elicit better patient outcomes and lower spending rates by providing valuable data on the role of post-acute care in bundled payment models.”

This analysis was completed using both the five percent and 100 percent samples of Medicare beneficiaries contained within the 2011-2014 Standard Analytic Files (SAF) Limited Data Set (LDS).

Click here to read the complete analysis.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


By Tim Rowan, Editor & Publisher,  Home Care Technology Report

In a June 14 Open Door Forum, CMS representatives answered questions about the new Home Health documentation rule they will soon begin to test in five states. The “Pre-Claim Review” rule, as it is now called by the department that manages payments to Medicare home health providers, is being couched as an opportunity for those providers to “better manage their cash flow.”

“Now, you will know in advance whether your documentation is correct and your claim will be paid when submitted,” the CMS spokesperson read from a prepared script.[Additional details are provided  about documentation required from healthcare at home agencies by CMS under the “Pre-Claim Review” rule,  the expected advantages for healthcare at home providers using the “Pre-Claim Review” rule, and questions and answers about CMS’s “Pre-Claim Review” rule–with details on claim submissions for pre-approval and on funds available for agencies’ hiring additional staff.]


Here is how CMS anticipates the new system will help providers when it begins in Illinois on August 1, Florida on October 1, Texas on December 1, and Michigan and Massachusetts on January 1, 2017. (All dates are designated as “no earlier than.”) Most of the following information was delivered in a brief summary and clarified during the Q&A section of the June 14 conference call.

  • HHAs may begin patient services the same way they do today, typically within 24-48 hours of referral or hospital discharge.
  • HHAs may submit a Request for Anticipated Payment as they do now, as soon as the usual documentation and signatures are in place.
  • Any time before the final claim is submitted, the HHA may submit documentation to its Medicare Administrative Contractor for pre-approval of that future claim. If any deficiencies are found in the Face-to-Face document, OASIS, plan or care, certification of homebound status or medical necessity for skilled services, deficiencies that would cause the final claim to be denied, the HHA is informed, ideally within 8 to 10 days.
  • Corrections to disapproved documentation can be resubmitted an unlimited number of times, up until the final claim is submitted, until the HHA receives approval from the MAC.
  • Pre-approval documents can be submitted by U.S. Mail, fax, or electronically via the CMS esMD system. MACs will notify HHAs if they have established their own electronic submission system. Replies will be sent via the same method through which they were received (mail, fax, electronic, etc.).
  • When the MAC finally approves the documentation, the HHA is notified that its claim will be paid when submitted. A pre-approved claim cannot be denied by the MAC. “It is immune from further review,” in the language of the Open Door Forum hosts.
  • HOWEVER, other contractors, including ZPIC, CERT, and RAC auditors, “are free to do whatever they want,” the CMS spokesperson stated. Even pre-approved PPS episodes can be subjected to further scrutiny by any or all of these other auditors.
  • If a patient condition requires adding or increasing services during an episode of care, including unanticipated therapy services, no further pre-approval is required. “We are not assessing the plan of care,” it was explained, “only the correctness of the documentation that asserts the patient qualifies for the Medicare home health benefit. After that, we assume the episode will continue under physician supervision and that services will be added as necessary.”
  • In the event that the HHA does not submit documentation for pre-approval and the claim is later determined to be proper and payable, it will be paid at 75% of the claim value. “This 25% penalty is in there to encourage HHAs to participate in the pre-approval process,” the forum host stated.
  • MACs are being given supplemental funds to hire the additional staff to process the expected influx of hundreds of thousands of admission documents.
  • HHAs are not being given supplemental funds to hire the additional staff to gather and submit admission documents at the beginning of each episode. “We see that all the pre-approval documents we are requiring are documents that you are gathering and getting signed anyway. There will be little extra work to submit them one additional time.” The implication was clearly that, while there may be additional staff hours required if admission documents must be submitted multiple times until a MAC finds them acceptable, that is essentially your fault and you should get better at submitting correct documentation the first time.

There were questions that were not answered during the call, or were answered in a way that did not satisfy the questioner.

Q: If an HHA receives a disapproval that says the need for skilled services is not verified, won’t they be motivated to discontinue services before their unpayable visits mount up to unacceptable losses?

A: “We expect that Home Health Agencies are oriented toward patient care and would not abandon a patient simply because they are not going to be paid for the services provided.”

Q: Does the plan of care have to be signed before the pre-claim review documents can be submitted?

A: Normal requirements apply. (We interpret this to mean the plan of care has to be signed before the final claim is submitted but the CMS spokespeople would not confirm that this is how your MACs will interpret it.) 

Q: Looking at recent MAC and ZPIC historical evidence, we know that quick hiring and training of new staff leads to problems. Training is often superficial, knowledge of home health regulations on the part of the trainees is inadequate, new auditors with insufficient understanding of Medicare Home Health regulations often improperly deny payments and demand ADRs. In the past, this problem has resulted in 80% to 90% overturn of denials by the ALJ, when that department was available. How are we to be assured that this history will not be repeated when MACs rapidly staff up and superficially train newcomers once again to meet this massive increase in documents arriving as soon as six weeks from now?

A: “We met with the MACs and told them to be ready.”

Q: You know who the bad actors are. We reluctantly accept that you were unable to figure out a way to target the criminals and leave the rest of us alone, but is there a way for a high-performing agency to be excused from the pre-approval requirement, for example if they receive no disapprovals for a year?

A: “This is a three-year trial. All HHAs in these five states will be on the program for the full three years regardless of their performance.”

Editor’s comment: While it is a relief that it has been clarified that in-home patient care services will not have to be delayed until pre-approval is received, indicating less fear of putting patients in danger than once thought, this regulation continues to disappoint on two levels. CMS has found extra money in the budget to defray the added costs the regulation imposes on MACs but refuses to acknowledge that HHA costs will rise as well. The hope that “cash flow will be more predictable” is little condolence. This reinforces the long-suspected CMS attitude that MACs are the police, the “good guys,” while all home health agencies, not just the tiny percentage of fraudulent players, will cheat if not constantly watched.

Secondly, to the extent this regulation is a punishment, as it has been described by the Partnership for Quality Home Healthcare (last week’s issue, Partnership Expresses Disappointment with Medicare Home Health “Pre-Claim Review” Demonstration), it will be a most ineffective one. It imposes equal burdens on criminals and legitimate providers. What is worse, as Bill Dombi has been making clear during his round of visits to state association meetings this spring, the bad guys will find a way around it. The rule ensures that documentation indicates homebound status and medical necessity, but it does not guarantee that there is an actual patient behind the documentation, a living human being receiving home health services.

As CMS continues to push the total number of HHAs from 12,000 to 6,000, we can only hope that the criminals will be the ones eliminated. Current efforts do not seem to be leading in that direction.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


By Tim Rowan,  Editor & Publisher of Home Care Technology Report

We have long promoted the strategy of combining technologies rather than expecting a home healthcare or hospice EMR to fulfill a provider agency’s every automation need. In recent weeks, we have found three supplemental systems that appear to us will save more than they cost. At least one of these three will be worth a closer look to every reader. [Rowan provides details on 3 companies that might be worth a closer look. These are: 1) Medalogix and its Touch predictive technology used to assess healthcare at home patients’  many risks, such as risk of rehospitalization, risk of falling, and risk of requiring another 60 days of in-home care; 2) MedTranDirect and its NOETracker software system that tracks timely, much needed and precise NOE details about hospice patients; 3) CaptureProof and its Smart Medical Camera app– use to provide improved physician and patient videovisits.]


Dan Hogan

Medalogix has been accumulating patient data for seven years now. Their newly released product, Touch, uses that growing volume of information in a new way. By comparing every patient against a benchmark of every past patient, Touch can accurately predict an individual’s risk. Risk of rehospitalization, risk of falling, risk of requiring another 60 days of in-home care. More often than not, CEO Dan Hogan told us, the nurse’s professional judgment and gut instinct is confirmed by the system’s analytics.

“Our products have always been designed to help make home health agencies more attractive to hospitals and ACOs seeking partnerships,” Hogan said, “by improving their outcomes and reducing readmissions.”

While we had him on the phone to talk about Touch, we asked Hogan about the first competitor to enter his data analytics category ( see “Kinnser Tackling Hospital Admissions with New Data Analytics Tool” (5/11/2016). “I’m happy to see Kinnser entering the data science arena,” he told us. “It confirms that we are on the right track if someone else is doing it.”

Ellie RobisonHospice providers have been suffering under the new “Notice of Election” rule. Now there is finally a cure. MedTranDirect, which providers payer connection services and HIPAA-compatible 835/837 transmissions, has a software system just coming out of beta, NOETracker, that solves a problem create by CMS. We will explore the problem and they way MedTranDirect goes after it next week in detail but here is the brief version.

Hospices must submit an NOE for every new patient within five days of admission. Daily payments are denied until an error-free NOE is received by CMS, through a mid-20th Century era, green-screen, direct data entry system which does not validate entries. In this archaic system, patient names, physician names and NPIs must be typed in as many as five times. Opportunity for error is extremely high, as evidenced by the 50% rejection rate. However, hospices may not know they have submitted a NOE with a typo for ten to twenty days, the time CMS takes to review and respond.

Hospice are reporting annual losses of six figures and up.

NOETracker sits between the hospice and the green screen. Data fields are typed once. The system checks for errors and populates all the repetitive fields in the CMS system automatically. Beta testers report zero payment denials over the first two month of use and an 80% reduction in time spent managing NOEs. We will bring you our complete interview with MedTranDirect CEO Ellie Robison and one of the company’s beta testers later this month.

One of the perennial problems with virtual video visits is that the patient and the physician are not often available at the same time. Still, healthcare at home nurses know the value of including images to help physicians and WOC nurse specialists better understand each patient’s condition. Enter a startup company founded by a woman with an undergraduate degree in physiology and a graduate degree from the Paris Photography Institute.

Meghan ConroyMeghan Conroy, CEO of CaptureProof, has developed an asynchronous communication system that goes far beyond transmitting pictures from a cell phone to an office. Her Smart Medical Camera™ app is different from those you may have used. Text instructions are displayed on the screen with photos. Indicators on the photo alert the person evaluating a wound or other target when there are areas of overexposure or shadows that may interfere with clinical evaluation.

Most importantly, the system offers an overlay system. The initial photo, usually taken by a nurse, remains available in the app as a shadowy outline. The patient downloads the app for use on his or her own device so updated wound photos can be sent often, daily if necessary. The outline helps the patient line up each photo with the size and angle of the original, enabling accurate remote evaluations.

See the CBS News interview with Meghan Conroy here.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


[Statement issued by  the Partnership for Quality Home Healthcare]
 Washington, DC – June 8, 2016 – The Partnership for Quality Home Healthcare – a coalition of home health providers dedicated to improving the integrity, quality, and efficiency of home healthcare for our nation’s seniors – today expressed disappointment with the revised home health prior authorization demonstration, released today by the Centers for Medicare & Medicaid Services (CMS). Now called a “Pre-Claim Review” demonstration affecting seniors in five states over three years, the demonstration will impose still further documentation requirements on already burdened high quality home health agencies that could result in poor care transitions and still further confusion for seniors seeking care at home. [Details are provided about the expected detrimental results of applying the Pre-claim Review to healthcare at home seniors.]

Home health leaders have previously warned that prior authorization policies will drive up costs to the Medicare program as patients would likely be sent to more expensive in-patient facilities, or potentially experience a hospital readmission while waiting alone at home for their prescribed post-acute care to begin. The Pre-Claim Review Demonstration takes a step forward to address this outcome by allowing seniors to start home health services while the agency submits applicable documentation, but it still creates new challenges for home health agencies in providing seamless, integrative high quality skilled health care, and thus could negatively impact the patient experience overall.

“We appreciate the steps CMS has taken to protect beneficiary access to care in the revised demonstration, however, much more needs to be done. We remain concerned that the demonstration does not go far enough to protect patients from potential harms inherent with pre-claim review, including confusion, delays and service interruptions in care for a vulnerable patient population” said Colin Roskey, Executive Vice President of the Partnership. “We are also concerned that CMS has not followed notice-and-comment standards for obtaining and responding to input from those immediately affected by the demonstration.”

Bipartisan lawmakers have also expressed concerns that home health prior authorization could cause dangerous delays in care for vulnerable home health patients. In a letter to CMS last month, 116 bipartisan House lawmakers wrote, “This demonstration project imposes costs on patients, providers and taxpayers. Delaying patient care while waiting for CMS to approve home health services may put patient health in jeopardy and cause patients to stay in the hospital longer than necessary.”

The mandatory pre-claim review demonstration paints all agencies in the affected states with a single brush. The Partnership instead recommends CMS pursue more targeted reforms that will strengthen program integrity without compromising the healthcare needs of patients. The Partnership has offered several proposals to address fraud, including targeting aberrant billing and utilization, ensuring sufficient qualifications and background checks, and identifying the isolated geographic areas which CMS data confirm are the ‘hot spots’ of fraud.

“We and our colleagues throughout the home healthcare community would welcome the opportunity to collaborate with CMS on the development and implementation of appropriate and targeted program integrity measures that fall within CMS’s authority and that would effectively identify and eradicate fraud and abuse,” the Partnership wrote in its comment letter to CMS.

Data compiled by Avalere Health reveal that Medicare home health beneficiaries are older, sicker, poorer and are more likely to be female, a minority, and disabled than all other beneficiaries in the Medicare program combined. Nationwide, 3.5 million homebound Medicare beneficiaries depend on the Medicare home health benefit to receive clinically advanced, cost effective and patient preferred care.

This statement was released on 6/8/16 by the Partnership for Quality Home Healthcare. For more information about the Partnership, visit or on Facebook at


By Tim Rowan. Editor and Publisher of Home Care Technology Report

On April 8, fourteen representatives of healthcare at home software companies gathered with provider executives at the VNAA Annual Meeting in Miami to explore the challenges of creating data interoperability between acute and post-acute caregivers. What came out of the two-plus hour discussion must be described as, at best, a solid understanding of how difficult a hill this is going to be to climb. This will not be the only attempt, however, to search for answers. Home Care Technology Report editor Tim Rowan and VNAA CEO Tracey Moorhead have agreed to work together to keep the conversation alive until the best path forward appears. [The range of multi-faceted problems were outlines by 14 panelists from the industry’s leading solutions vendors, and, as Rowan notes, though definitive solutions could not be expected during a preliminary discussion between 14 people, a moderator, and an audience of providers,   a range of first steps to be undertaken by national associations such as the VNAA is indicated for working toward establishing data interoperability between acute and post-acute caregivers.]


The fourteen panelists from the industry’s leading solutions vendors first outlined the multi-faceted problem:

  • Willingness to cooperate on the part of hospital EMR software vendors cannot be assumed, especially the one vendor that chose not to join the Commonwell Health Alliance, a membership organization where competition is supposed to take a back seat to patient care when the creation of data sharing standards is concerned.
  • Customers of these EMR vendors have not been demanding data interoperability features to be added to their applications. Much work remains to be done to teach providers how urgent this technology will be to their very survival.
  • HL7 can no longer be considered an adequate solution to the problem of HIPAA-compliant data transparency.
  • Healthcare at Home providers and their vendors should not be hoping that complete patient records will be shared in the near future but should be satisfied with minimal data sets, such as the one established for the Continuity of Care Document.
  • The entire Healthcare at Home industry must continue the uphill battle to be included in high-level discussions rather than disregarded as an afterthought, merely informed when others finally establish standards.

While definitive solutions could not be expected during a preliminary discussion between 14 people, a moderator, and an audience of providers, some good ideas came to the forefront before the afternoon ended.

  • National associations such as the VNAA have a responsibility to include interoperability in their educational offerings.
  • Healthcare at Home executives need to take responsibility to negotiate partnerships with hospitals and ACOs, not leave it up to their sales and marketing staff.
  • Early steps can be taken to transmit simple patient data sets from home health to hospice to long term care and rehab hospitals while waiting for the large hospital software companies to decide on standards. Among those might be Direct Secure Messaging, a protocol available to all software developers that could be used to exchange patient data without the need for interoperability standards.

As mentioned above, this conversation will continue. The VNAA is taking it seriously and so do we. The door is open to every concerned healthcare at home industry participant to join us.

©2016 by Rowan Consulting Associates, Inc., Colorado Springs, CO. All rights reserved. This article originally appeared in Tim Rowan’s Home Care Technology Report. One copy may be printed for personal use; further reproduction by permission only.


AxisCare Selected by Companion Connection Senior Care 
Private Duty EMR built by veteran agency owners

AxisCare, Inc., provider of software supporting administrative, marketing, caregiver management, billing and reporting for private duty, Medicaid and long-term care providers, announced this week that it has partnered with Companion Connection Senior Care to offer its AxisCare Home Care Management Software to CCSC members. The software provides tools built by healthcare at home industry veterans.

CCSC is not a franchise home care company but a membership organization that provides entrepreneurs training and equipment needed to start a non-medical home care company. Based in New Jersey, it was founded in 2000 by David Goodman and Frank Esposito to help people find the success they did with their agency, Expert Home Care.

AxisCare’s home care management software provides CCSC members a wide-variety of tools, including CRM, scheduling, payroll, integrated Medicaid and LTC insurance electronic billing, GPS mobile app, telephony, and reporting. It can be integrated with third party software, such as QuickBooks, if desired.

“Based on experience, we’ve tested the success of different business concepts and marketing techniques prior to passing the knowledge on to our members,” said Goodman. “Selecting AxisCare as a preferred vendor marries our knowledge and expertise with practical real world solutions that can make a positive day-to-day impact on behalf of our members.”


Libman Education Makes CCS Mock Exam Available

Libman Education has announced the re-release of its popular CCS Mock Exam.


“The CCS credential is a great achievement, as it demonstrates mastery of acute care hospital coding,” said Mary Beth York, CCS, CCS-P, CIC, a nationally recognized CCS expert who provides the personal mentoring session. “But passing the CCS exam is not easy; even experienced coders have difficulty passing. There is no substitute for hard study. However, proper guidance can make one’s studies more focused and productive. It is this kind of guidance that the coaching session offers.”

York, who has mentored hundreds to CCS success, added, “While many mock CCS exams are available, finding one that is really helpful is difficult. In Libman Education’s intensive CCS Exam Prep course, hundreds of students have used our CCS Mock Exam to successfully prepare for CCS.”

Those who take the CCS Mock Exam get a feel for the actual exam, and receive a detailed report with test results to know where to focus their studies. In the optional private mentoring session, Mary Beth York identifies a student’s strengths and weaknesses, suggests proven test-taking techniques and strategies, and provides a tailored plan based on one’s results to maximize their limited CCS prep time.

For those who need more preparation after taking the CCS Mock, Libman Education offers an online CCS Exam Review course, and an instructor-led intensive CCS Exam Prep course by Mary Beth York.

About Libman Education
Libman Education Inc. is a provider of training for the healthcare workforce. Libman Education offers self-paced online courses designed and developed by leading industry experts in Health Information Management (HIM) and Medical Record Coding. Courseware is designed for individuals as well as health care providers and institutions, public and private workforce development training programs, and professional and volunteer associations interested in preparing their employees and members for the challenges facing the HIM workforce.



By Tim Rowan, Editor & Publisher, Home Care Technology Report

2016 Aging2.0 Survey of Senior Care Innovation & Technology Use

We are pleased to pass along an invitation from Aging2.0, which has announced the 2016 “Senior Care Innovation & Technology Use Survey” to advance a greater understanding of how senior care providers from across the care continuum are approaching innovation and implementing technology to support care. [Details are provided  on available discounts to respondents for attending Aging2.0 OPTIMIZE is set for October 12-14, 2016 in San Francisco.]

Respondents have the option to remain anonymous. However, they will give a 25% discount to their upcoming conference to participating senior care provider organizations if you provide your company name when you complete the survey.

Aging2.0 OPTIMIZE is set for October 12-14, 2016 in San Francisco.

Results will be shared with participating Associations, Aging2.0 Alliance members, and directly upon request. They ask that you complete the survey by close of business on Friday, June 10. Click on the image below to get started.

Aging 2.0 Survey