Medicare Annual Wellness Visits

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Medicare Annual Wellness Visits

Postby lori » Fri Oct 20, 2017 5:09 pm

Hi. My questions are related to the HRA portion of the Annual Wellness Visit. My first question is: does the HRA need to be separate and/or easily distinguishable from the rest of the AWV documentation?

My next question is regarding the specific requirements for the HRA. The general info published by CMS (such as the "ABCs of the Annual Wellness Visit") only lists 6 mostly vague topics that they require to be addressed in the HRA. However, the reference links on this same document include a link to Chapter 15 of the Medicare Benefit Policy Manual, where a lengthier and much more detailed list of required bullets for the HRA is published, expanding upon each of those 6 topics. These more detailed bullets also appear in the Federal Register and in a CMS FAQ publication.

To illustrate further what I mean, the general info from CMS lists "demographic data" as a required element of the HRA but does not define it further. However, Chapter 15 reads "demographic data, including but not limited to age, gender, race, and ethnicity." The general CMS info lists "psychosocial risks" with no further definition, but Chapter 15 states "psychosocial risks, including but not limited to depression/life satisfaction, stress, anger, loneliness/social isolation, pain, and fatigue." Does this mean if a provider does not document every single one of those detailed bullets (such as race, ethnicity, stress, anger, etc.), then they cannot report the AWV?

Some consultants are saying CMS no longer requires that detailed list of bulleted items for the HRA that appears in Chapter 15. Some state CMS only requires those 6 topics be addressed in some manner but that CMS allows the provider to determine what HRA questions within those 6 topics are relevant to the specific patient based on their current health status. So far I have been unable to locate any clear guidance that says the specific bullets in Chapter 15 are no longer required. Could you please advise on this? Thank you!
lori
 
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Re: Medicare Annual Wellness Visits

Postby admin » Wed Nov 01, 2017 1:57 pm

HRA's are still required, they do not have to have every element captured, but at least one or two of each element. I am attaching a copy of what CMS uses to define the HRA (https://www.cdc.gov/policy/hst/HRA/FrameworkForHRA.pdf) to assist you in picking which what elements to use in the assessment.

Your question has been answered by Omega Renne, CPC, CPCO, CPMA, CEMC, CIMC
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Re: Medicare Annual Wellness Visits

Postby lori » Fri Nov 10, 2017 7:33 pm

Thank you for that info. We know CMS does make reference to the CDC publication you attached as an example of HRAs, but do you know why CMS still states in Chapter 15 of the Medicare Benefit Policy Manual that all of those specific detailed bullets are required? CMS seems to be contradicting themselves on this issue with their published references. We consider Chapter 15 to be authoritative and we don't typically regard the CDC to be authoritative in the area of CMS/Medicare requirements. Do you have any authoritative CMS reference that states the HRA only has to address one or two elements within each area? Also, does the HRA need to be separate or easily distinguishable from the rest of the AWV? Thank you!
lori
 
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