Open Door Forum: Heavy Focus on Proposed Hospice Changes
May 10, 2013 09:08 AM
On May 8, the Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice, and DMEPOS Open Door Forum, during which the following issues in hospice and home health care were discussed:
Hospice Quality Reporting Program
The deadlines for 2013 submission of quality measures collected during the fourth quarter of 2012 - the hospice Structural Measure and NQF0209 Pain Measure - have now passed. Providers that failed to meet either the Structural Measure or Pain Measure deadlines - January 31 and April 1, 2013, respectively - may be subject to a 2 percent reduction off their FY2014 market basket increase.
Hospices should have continued to collect data related to the Pain Measure for 2014 submission. There will be a single deadline - April 1, 2014 - for reporting of the Structural and Pain Measures collected during 2013. Failure to report CY2013 data by deadline will affect the FY2015 payment cycle resulting in 2 percent reduction in market basket. Relative to the Structural Measure, hospices will no longer be required to submit the checklist of measures they use as part of their QAPI programs effective with the April 2014 reporting. Hospices will only be required to answer the questions related to their QAPI measures.
Training on HQRP will be available this summer.
CMS has proposals for the CY2014 - affecting FY2016 payment - and subsequent year collections under consideration as part of the recent proposed rule related to the FY2014 Hospice Wage Index. CMS is proposing elimination of the pain measure and, in its place, will collect quality data through a Hospice Information Set (HIS). NAHC is conducting an analysis of the HIS measures and reporting proposal that will be published in a forthcoming issue of NAHC Report.
Elements included in the HIS are now posted online here.
Providers should read the materials to familiarize themselves with the proposed changes. Questions about hospice quality reporting requirements may be emailed to: firstname.lastname@example.org.
For payment policy information, please see the NAHC Report summary published April 30.
The proposed payment rule was placed on display April 30, 2013, and will publish in the Federal Register on May 10. There is a 60-day comment period that closes on June 28. The rule includes proposals related to the following major changes:
Hospice Quality Reporting – reports proposed changes to HQRP and intent to require a family experience of care survey
Payment – proposes that payment rate changes be published through an annual notice or rule (rather than through an administrative instruction)
Payment Reform – announces availability of a technical report and literature review related to work on hospice payment reform
Inclusion of Multiple Diagnoses on Hospice Claims – a further clarification that existing policy requires hospices to provide multiple diagnoses on claims, as well as clarifies CMS’ expectation related to use of certain diagnosis codes in hospice.
Providers are urged to read and become familiar with the provisions and clarifications provided in the proposed rule.
During the Q & A, a participant asked when CMS would begin returning to provider (RTP) hospice claims that use debility or adult failure to thrive (AFTT) as the primary diagnosis; CMS staff indicated that an instruction to the Medicare Contractors will be coming out soon, but they do not have an implementation date at this time.
When asked if the pending instruction would impose a requirement that hospices include multiple diagnoses on claims, CMS indicated it would not, but CMS does expect to see more diagnoses provided by hospice than just a principal diagnosis.
A participant asked how application of the policy disallowing use of debility or AFTT will impact any local coverage determinations (LCDs); CMS staff indicated that a national instruction would supersede any local policy.
When asked if, once a claim is RTPed because it has a single diagnosis that is either debility or AFTT, but there is not a more prevalent or additional diagnoses that can be added, what would happen; CMS indicated that hospices should not use AFTT when there is another diagnosis and should establish causation. CMS staff indicated they do not expect that there would be instances where AFTT is the only diagnosis, but that this should be left to the clinicians at the hospice to determine.
Wage index files for FY2014 are available online here in the Spotlight section.
The payment reform technical report and literature review are available here in the Research and Analyses
Hospice Cost Report
CMS has developed a revised hospice cost report that has been published online in order that comments can be made on the increased paperwork burden; comments are due by June 28.
Here is a link to the location of the cost report materials.
Home Health Issues
Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS)
Most recently HHCAHPS data that is posted on the Home Health Compare web site includes data through September 2012.
A description of the patient-mix adjustment for the HHCAPHS and a table with patient mix-risk factors can be found on the HHCAHPS website.
Replication of the data is not possible due to data cleaning and 4-quarter averaging. For each future public reporting period, Tables One and Two will be updated and posted on the Home Health Care CAHPS Web site here.
Agencies are reminded that they must authorize data survey vendors. In addition, agencies should check to see if data is being submitted on regular basis. If data for a month is missed, notify the vendor and document in HHCAHPS discrepancy notification report as filed by vendor so CMS is aware of reason month(s) was missed.
Medicare-certified home health agencies (HHAs) that served 59 or fewer unduplicated patients from April 1, 2012 through March 31, 2013 who met HHCAHPS survey-eligibility criteria are eligible for an exemption from participating in the HHCAHPS Survey for the calendar year 2015. An exemption form for has been posted and must be complete by 1/16/2014 for 2015.
Outcome and Assessment Information Set (OASIS)
CMS OASIS web based training has been updated with several new OASIS training modules. The modules can be accessed here. Click on “I am a Provider” link then click “Web based training” then click “Outcome and Information”.
Set training (OASIS), click on “Launch Course”. The new modules cover the OASIS Overviewand Conventions, ADL and IADL parts One and Two,Care Management Therapy Needs, and Emergent Care domains. A History and Diagnosis Module is under development.
The OASIS-C instrument with a 12/31/2014 expiration date is available on the CMS web site here.
There are no changes to the data set other than the expiration date.
Claims Processing Update
The quarterly update to the list of HCPCS codes for consolidated billing of home health services include two new therapy codes for negative pressure wound therapy (G0456 and G0457) are available here.
The codes are therapy codes and have no effect on the supply list. A new Master Consolidated billing list has been posted to the CMS web site here.
Change Request 8136 - which requires home health agencies (HHAs) report new Q codes indicating the location where services were provided - was reissued on April 2 to add clarifying language for the use of the new Q codes and to remove the requirement for agencies to add a modifier to report orders received from additional physicians.
CMS is to post Change Request 8244 that will provide instructions to discontinue the use of type of bill (TOB) 33x for home health claims, effective October 1. TOB 33x was eliminated by the National Uniform Billing Committee to simplify the code set. Agencies will not see claims changed from 32x to 33x on the remittance advice. If TOB 33x is submitted, it will be retuned to the provider.