CMS ODF Addresses Home Health, Hospice Rules, Hospice Claims Processing
August 14, 2015 09:57 AM
The Centers for Medicare & Medicaid Services (CMS) held its Home Health, Hospice & DME Open Door Forum on August 12, 2015. A recording of the session will be available from 5 p.m. EASTERN on Wednesday, Aug. 12 through 5 p.m. EASTERN on Friday, Aug. 14. Following is a summary of issues addressed on the call.
MARK YOUR CALENDARS! The next Home Health, Hospice & DME Open Door Forum is scheduled for September 23, 2015.
Representatives of CMS outlined changes that were included in the final hospice payment rule for FY2016 which was issued on Friday, July 31. Staff highlighted:
The final phase-out of the budget neutrality adjustment actor (BNAF) to the hospice wage index;
Alignment of the accounting year for the hospice aggregate and inpatient CAPS with the federal fiscal year;
Modification of the update factor for the aggregate cap to reflect the annual percentage rate update to hospice (rather than the CPI-U);
Imposition of a two-tiered rate of payment for Routine Home Care (eff. Jan. 1, 2016);
Implementation of a Service Intensity Add-on for skilled visits in the last 7 days of life (eff. Jan. 1 2016;
Use of a single RHC rate from Oct. 1 - Dec. 31, 2015;
Clarification that hospices are required to include all diagnoses gathered during the comprehensive assessment on hospice claims (including mental health disorders and other conditions affecting the plan of care) and regardless of whether the diagnoses are related or unrelated to the terminal diagnoses and related conditions.
Questions about the final FY2016 hospice payment rule may be submitted to CMS at: firstname.lastname@example.org.
The calendar year 2016 proposed home health payment rule was placed on display on July 6, 2015, and the comment period closes on Sept. 4, 2015. CMS encourages comments in either hard copy or electronic submission.
Quality Reporting Updates
HOSPICE: As part of the FY2016 hospice final rule, CMS finalized several new policies related to the Hospice Quality Reporting Program (HQRP). Of particular note by CMS staff were the numerous comments received regarding the new measure concepts, including a patient-reported pain outcome measure, hospice staff responsiveness to patient and family needs, skilled visits in the last days of life, and communication by the hospice team.
Staff noted several programmatic changes that were included in the final rule, including:
The new policy related to retention of previously-adopted measures;
Reporting requirements for new hospice facilities;
Enforcement of data submission timelines for all Hospice Item Set (HIS) records effective Jan. 1, 2016, and
The imposition of timely data submission compliance thresholds as outlined below with submission of HIS admission/discharge records within 30 days of the event date considered timely:
70 percent timely submissions for FY2018 annual percentage update determination (APU),
80 percent for FY2019 APU determination, and
90 percent for the FY2020 APU determination.
The overall goal is to have all hospices achieve 90 percent or higher compliance over time.
Staff also commented on use of CASPER files as an additional mechanism (beyond the U.S. Postal Service) to communicate with hospices regarding compliance with annual reporting requirements. CMS indicated that hospices that meet reporting requirements will be published on HQRP website.
CMS also indicated that public reporting of hospice quality measures and other data via a COMPARE website is on track for CY2017. CMS is also prepared to post Medicare Provider Utilization and Payment data for hospices in CY2016. There is an existing Medicare Provider Utilization and Payment Data Public Use File (PUF) currently. This includes information on services and procedures provided to Medicare beneficiaries by physicians and other healthcare professionals (Part B).
Questions about hospice quality reporting requirements may be submitted to: email@example.com.
Home Health: As part of the home health proposed payment rule for CY2016, CMS is proposing one new quality measure for CY2016 -- skin integrity/the percent of patients with pressure ulcers that are new or worsened -- to meet requirements under the IMPACT Act. CMS also proposed to raise the pay for reporting threshold:
Beginning CY2016 payment determination CMS is requiring 70 percent timely OASIS submissions for the July 1, 2015 - June 30, 2016 time period
July 1, 2016 - June 30, 2017 HHAs must meet an 80 percent timeliness requirement for OASIS submissions
July 1, 2017 through June 30, 2018, (and thereafter) HHAs must meet the 90 percent timeliness submission threshold for OASIS submissions.
CMS indicated that four potential future measures are under consideration at this time and CMS is seeking comments on these measures. The four potential future measures are:
All condition risk-adjusted potentially preventable hospital readmission rates
Resource use including total estimated Medicare spending per beneficiary
Discharge to community
CMS also proposed seven additionl measures for the home health quality reporting program as part of the proposed rule. Comments are due to CMS by September 4, 2015.
Home Health CAHPS (HHCAHPS): CMS staff noted that the only Official HHCAHPS website for any info about HHCAHPS survey information, and for HHAs to check their HHCAHPS preview reports for data posted on Home Health Compare, and for HHCAHPS Survey Vendors to submit data is the following website: https://homehealthcahps.org. HHAs and others should NOT rely on other websites (such as vendor websites) for official information. The website has public and private portions -- for the private side, HHAs must have a password established. To establish a password and to authorize vendors, HHAs should go to the tab marked: FOR HHAs ONLY. If you are a new HHA, please call RTI at 866-354-0985 or email them at: firstname.lastname@example.org for help in getting started in the system.
For technical assistance, including questions about HHA Preview Reports, contact the HHCAHPS Coordination Team: email@example.com.
For CMS Assistance about Home Health Care CAHPS (HHCAHPS) APU questions, contact HHAPUreconsiderations@cms.hhs.gov.
CMS has also established a monthly newsletter for HHCAHPS that is issued at the end of each month; for access to the newsletters, go to the GENERAL INFORMATION tab on the home page.
HHAs will be able to obtain their next preview report in early September 2015 (either the Friday before or just after Labor Day). The September preview reports will include the first time dry run of the home health star ratings. While star ratings will not be available publicly until January 2016, the “dry run” will allow HHAs to see what the reports will look like, and to provide feedback to CMS on the look and the feel of the report, as well as how the data and star ratings are presented. Please provide feedback on these reports to the RTI team at: firstname.lastname@example.org or to the CMS team at: email@example.com.
Hospice CAHPS: For the Hospice CAHPS web site, please go to: www.hospicecahpssurvey.org; for technical assistance, contact the CAHPS Hospice Survey Project Team by email at hospicecahpssurvey@HCQIS.org or by phone at 1-844-472-4621; and to communicate with CMS staff about implementation issues, please email: firstname.lastname@example.org
Hospice CAHPS Deadlines: Wednesday, August 12 was the deadline for submission of exemption requests from hospice CAHPS based on size. August 12, 2015 was also the deadline for survey vendors to submit first quarter 2015 data to the Hospice CAHPS warehouse. Late submissions will not be accepted.
Hospice CAHPS Vendor Training: CMS has set Wednesday, September 30 as the date for the 2015 Hospice CAHPS Survey Vendor Training. Additional information will be available closer to the date; hospice providers are permitted to participate in this training.
HOSPICE CLAIMS PROCESSING UPDATE
CMS has issued Change Request 9255/MedlearnMatters 9925 to instruct the Medicare Administrative Contractors (MAC) on action that should be taken relative to hospice claims that are being returned to provider because they contain certain anti-emetic and anti-cancer drugs that the Common Working File will not allow to be submitted on hospice claims. Please see additional information about this in NAHC Report at: http://www.nahc.org/NAHCReport/nr150811_2/ .
CMS also has plans to release Change Request 9201 on Friday, August 14, which will contain changes related to the final hospice payment rule. CR9201 will NOT contain the new HCPCS codes that will be associated with RN and LPN visits that will allow the system to distinguish between these nursing visits for purposes of the Service Intensity Add-on; those codes will likely not be available until some time in October.
COORDINATED CARE FOR JOINT REPLACEMENT PROPOSED RULE
CMS proposed a bundled payment model for lower extremity joint replacement procedures within 75 randomly selected geographic areas. Model participants are IPPS hospitals -- CMS proposes to implement the model through rulemaking. CMS is currently in the comment period for this proposal with comments due on Sept. 8.
Under the proposed model, an episode of care includes a hospitalization assigned MSDRG 469 or 470. The bundle includes hospitalization and 90 days post-discharge with most Part A and Part B services included with few exceptions. This is a retrospective model which means providers would continue to bill Medicare FFS as normal throughout model with a retrospective reconciliation process at the conclusion of the performance year. The first performance model year is proposed to begin January 1, 2016. The proposal is a two-sided risk model with financial responsibility phasing in starting in year two of the model. CMS would set target prices for episodes of care and participating hospitals would be given the target price before performance period, Financial risk primarily affects the hospitals but may also include “partners”, potential financial arrangements between hospitals and risk partners are included in the rule.
Three quality measures that would be tied to the payment structure for the model include –
Patient reported outcome measures
Some questioners asked if and advocated for hospices and home health agencies to be afforded the same flexibility as physicians when it comes to ICD-10 implementation. No one from this division was on the call, so CMS representatives could not respond. Another questioner indicated that the DMEPOS suppliers are required to ensure their medical record supports the ICD-10 code which will be nearly impossible to ensure when physicians are not required to do so.
It was noted that PECOS files are not up to date in CMS databases which means DME claims are getting denied because PECOS list is not up to date. CMS did not have an answer for this dilemma.
Related to hospices having to include all diagnoses on claims CMS indicated that there should be no determination of relatedness or unrelatedness of the codes on the claims, so it should not have impact on hospice payment responsibility.