CMS Provides Education on Revised Hospice Item Set Manual
June 19, 2015 10:22 AM
On June 17, 2015, CMS held a training call for the revised Hospice Item Set (HIS) Manual. The revised manual, version 1.02, is effective June 28, 2015, and it includes HIS definition clarifications as well as some revised guidance. CMS has indicated a recording of the call will be available. In the interim, providers can find out more detail by reading the NAHC summary below and viewing the presentation slides. A change table outlining the revisions is also available for providers in the downloads section of the CMS HIS webpage.
A hospice should still complete and submit HIS records even if late. The provider will receive a warning ‘error’ but the records are still accepted.
The definitions for admission and discharge are helpful in determining when an HIS needs to be submitted.
Admission: A patient is considered “admitted” to a hospice if:
There is a signed election statement (or other agreement for care for non-Medicare patients) and
The patient did not expire prior to the effective date of the election or agreement for care and
The hospice made a visit in the setting where hospices services are to be initiated.
All three criteria must be met in order for the patient to be considered “admitted” for the purposes of HIS reporting.
Discharge: A patient is considered discharged when the patient is no longer receiving services from the hospice or there is an interruption in care/services. Patient discharge is the “trigger event” for completing the HIS-Discharge.
When a patient transfers from one hospice provider to another hospice provider, and those providers have different CCNs, each provider is responsible for submission of an HIS-Admission and an HIS-Discharge. If the providers have the same CCN, i.e. hospices with multiple locations and the patient’s care is being transferred from one of multiple locations to another, only the admitting hospice location is responsible for submission of the HIS-Admission and HIS-Discharge.
As long as there is no interruption in care, there is no need for another HIS. For example, a change in payor source – the hospice continues to provide care without any interruption in service but discharges the patient from one payor source and admits under another payor source in their administrative records. This often occurs when a F2F encounter is not completed timely. Some software systems require a complete discharge, an ‘administrative discharge’ if you will, when there is a change in payor source and no interruption in service. In these instances, an HIS-Discharge does not need to be completed when the patient is ‘discharged’ from the first payor source and a new HIS-Admission does not need to be completed when the patient is ‘admitted’ with a new payor source.
If the initial assessment is initiated, but the entire initial assessment was not completed before the patient is discharged, providers should enter the date the assessment was initiated. If no initial assessment was initiated, providers should enter a dash for A0205. Providers should remember that the patient must meet all three criteria for admission outlined above in order for the HIS to be submitted, and the inability to complete the initial assessment does not eliminate the need to complete and submit an HIS-Admission and HIS-Discharge.
New guidance for F3000, spiritual/existential concerns, allows a hospice to include dates that precede the patient’s admission date. This was allowed for CPR preferences, hospitalization preferences and other life sustaining treatment only.
For item J2030, Screening for Shortness of Breath, new guidance is that providers should consider whether shortness of breath (SOB) is an active problem at the time of screening. The clinician may determine that SOB is an active problem, even if SOB does not occur during the assessment visit. If the patient is receiving treatment for SOB, that indicates SOB is an active problem. This is different than determining severity of pain in J0900C, which is determined at the time of the visit.
Many hospices continue to have questions surrounding comfort kits. There are several HIS items that ask if a treatment was initiated and the date treatment was initiated. If the treatment is in the form of a comfort kit or any type of pre-printed admission orders, treatment is “initiated” when the hospice has received the order and there is documentation that the patient/caregiver was instructed to begin use of the medication or treatment for the relevant symptoms. Both conditions must be present. Proactive education is not considered “initiation.” For non-medication interventions, providers can use the date on which the hospice first discussed the intervention with the patient/caregiver.
Hospices were hoping for some clarification regarding the HIS items related to bowel regimen. In this call and the HIS Manual revisions, it was clarified that the bowel regimen order need not explicitly state it is for the management of opioid induced constipation and the date the bowel regimen is initiated can precede the date an opioid is initiated.
Due to technical difficulties, participants were not able to ask questions on the call but questions can be submitted to HospiceQualityQuestions@cms.hhs.gov.