CMS Open Door Forum Examines Claims Processing, Quality Reporting Issues
March 11, 2016 10:53 AM
Following is a summary of key issues addressed on the March 9 Home Health, Hospice and Durable Medical Equipment Open Door Forum. Recording of the call is available for listening until 11:59 p.m. on Friday, March 11, by calling: 1-855-859-2056 and using Conference ID: 38504851.
Claims Processing Updates
Home Health: CMS released CR 9474 which addresses the new condition codes for reporting on home health claims that no skilled service was delivered during the billing period. MACs are instructed to evaluate claims where skilled nursing visits are provided less than once every 60 days. Code 54 – “No skilled HH visits in billing period. Policy exception documented at the HHA” – should be used on these claims. Claims submitted without the code will be RTP’d (returned to provider). The provider will then have the option to
Add any accidentally omitted skilled services to the claim
Submit the claim as non-covered, if appropriate
Append the new condition code
CMS also reminded home health agency providers that the PC Pricer software is being modernized and has not yet been released. An expected release date was not provided.
Hospice: CMS staff noted that the Medicare Administrative Contractors (MACs) are reporting that some hospices are receiving Service Intensity Add-on (SIA) payments for RN and Social Worker visits provided in the last seven days of life when the patient is on levels of care other than routine home care (RHC). The SIA payment is being applied to visits that are not eligible for the SIA. CMS implemented the systems fix for this issue on February 22. CMS is currently developing the instructions for the MACs to adjust the overpayments that resulted on claims because of this issue. The MACs will be instructed to reprocess the claims in error within 30 days of issuance of the instructions.
HHCAHPS and Hospice CAHPS Announcements
Quality Announcements Home Health: CMS reminded home health agencies that if they are not yet participating in HHCAHPS there is still time to sign up to participate in the next round of reporting. Agencies should register now or as soon as possible as April begins the new reporting period that impact the next annual update period. From now through May agencies can sign up. Surveys begin on May 21, 2016. The best way to get started is to register on the HHCAHPS webpage by clicking on the HHA tab.
If there are home health agencies not participating right now because have served less than 60 HHCAHPS eligible patients, they must file a participation exemption form by March 31, 2016.
CMS reminded HHAs that if they are participating in HHCAHPS but have experienced problems with monthly submission of files, the HHA should notify its vendor as soon as possible. The vendor can file a discrepancy notification report to the HHCAHPS team so CMS knows the reasons for the missed months. This information is used to determine if the agencies qualify for the 2% non-participation reduction. HHAs are reminded to always check the monthly HHCAHPS data submission reports as the home health agency holds ultimate responsibility for ensuring the submission of monthly data.
On January 28, 2016 the Home Health Compare website star ratings were released. These ratings are for those home health agencies with at least 40 surveys completed for the 12 months reported on Home Health Compare. If and agency has less than 40 completed surveys the star rating data is reported for the HHA, but there is not a star rating posted for the provider. All HHAs can also see their star rating in their preview reports.
Also added to Home Health Compare is information on the star ratings descriptions and methodology.
Hospice: CMS has posted the Hospice CAHPS Participation Exemption for Size application on its website HERE; hospices have until August 10, 2016, to apply for the size exemption which would be applicable to Hospice CAHPS collection requirements for 2016. To be eligible for the exemption, a hospice must have served fewer than 50 survey-eligible decedents/caregivers in CY 2015. The participation exemption for size is applicable for one year only so any hospice that previously was determined exempt from Hospice CAHPS collection must reapply in order to be considered for exemption for 2016. Reporting during 2016 will impact the FY2018 payment update.
Staff also noted that the Hospice CAHPS FAQs have been updated; they are available HERE; reporting dates have been updated and the next data submission deadline is May 10, 2016. NO LATE SUBMISSIONS are permitted on Hospice CAHPS surveys.
The CMS Hospice CAHPS team also noted that they are preparing for public reporting of Hospice CAHPS data some time during calendar year 2017, but likely no sooner than some time during the summer months.
Following are key ways of securing additional hospice quality reporting information:
QIES Down Time Reminder -- Home Health and Hospice Impact!
CMS reminded providers that the QIES systems will be down from Wednesday, March 16 after 8:00 p.m. (EST) through Monday, March 21, 2016 at 11:59 p.m. (EST). This downtime will affect all QIES connectivity and systems. This means the national database, CASPER reports, and QW will NOT be available during this time. Of particular note is that Hospice HIS and Home Health OASIS submission systems will NOT be available during this time frame. Please alert all appropriate staff and plan accordingly to ensure timely submission of your information.
IMPACT Act – Home Health
The IMPACT Act requires implementation of clinical assessment domains using standardized uniform data elements within assessment instruments currently used by home health agencies and other post-acute providers. The intent of the Act is to enable interoperability and access to longitudinal information to facilitate coordination of care, improvement in outcomes and overall quality comparisons. CMS encouraged the provider stakeholder community to partner on this initiative. Citing one way to do this is to view the CMS IMPACT Act webpage and view the stakeholder engagement opportunities. Engagement opportunities include:
A national provider call, IMPACT Act Data Element Library Call, on April 14 at 2:00-3:00 PM EST. Register here.
A Special Open Door Forum on May 12, 2016 at 2:00 – 3:00 PM EST. This Special Open Door Forum will allow patients, families and advocacy groups and other interested parties to provide valuable feedback to CMS on standardizing assessment instruments across post acute settings to improve quality of care and quality of life. Registration will be available on the Special Open Door Forum webpage.
On June 26 there will be a complimentary pre summit session at the 2016 Long Term and Post Acute Care (LTPAC) IT Summit at the Hyatt Regency in Reston VA. Registration will be available in the Spotlights & Announcement section of the CMS IMPACT Act webpage.
Quality of Patient Care Star Ratings TEP – Home Health
A Technical Expert Panel (TEP) is being developed by CMS contractor Abt Associates. The TEP will evaluate the methodology for the rating system among other activities. The TEP will be convened in May for reviewing first year of data on the performance of star ratings and gathering feedback on potential refinements. The TEP nomination period is from February 4, 2016 to March 18, 2016. To nominate a colleague or yourself go to the CMS TEP webpage.
Interim QAO Reports
The next round of QAO interim reports will be available in CASPER the second full week of April for the January 1 – December 31, 2015 assessments that were submitted by January 31, 2016. This data is for informational purposes only. The QAO reports are available quarterly.
CMS encouraged all HHAs included in the HHVBP Model to take the following steps:
Establish your agency's HHVBP Point of Contact: HHAs in the nine selected states should provide the HHVBP Help Desk, HHVBPquestions@cms.hhs.gov, with the name and email address of a primary point of contact for each CMS Certification Number (CCN). Please also include the agency name, agency address and agency phone number.
Obtain a User Account on the CMS Secure Portal: This is an important first step towards registration for the HHVBP Model portal where HHAs will receive performance reports and enter data for new measures.
HHVBP Connect: Get yourself and your team connected. Send names, email addresses for everyone you’d like to have access to HHVBPquestions@cms.hhs.gov Please include your agency’s CCN. Information is on HHVBP Connect such as recorded webinars, discussion groups, and other valuable resources are located on this site.
Upcoming FY 2017 Annual Hospice Payment Update Compliance Determination
CMS plans to begin evaluating hospice HIS submissions and Hospice participation some time within the next month to determine compliance for the FY2017 payment year.
Please note: Hospices must fulfill both Hospice CAHPS and HIS submission requirements in order to avoid the 2% penalty.
Also note: Hospices must check final validation reports on HIS submissions to ensure that your records have been accepted into the system and do not contain errors. These reports are available in the CASPER system. If no final validation report is received, your submissions have not been received. ANY errors on the HIS identified in the validation reports MUST be corrected and resubmitted to ensure full compliance. Please print and retain your final validation reports as evidence of final processing.
Q & A
Following are some of the questions posed by attendees, along with CMS’ responses.
Question: A hospice indicated that they are experiencing two new issues with the proper processing of hospice payments under the new payment model. When the final seven days of life cross from one month to another they are not receiving their SIA payments for the first month. They also are receiving the incorrect RHC payment rate on patients that have transferred to their hospice.
Response: CMS is aware that SIA payments are not processing properly when the final seven days of life cross from one month to another. They are developing software to address the problem but the change will not be implemented until July. When the fix is implemented, the MACs will reprocess claims to ensure appropriate payment. CMS was not familiar with the RHC payment issue related to transfer payments but will pursue this issue when confirmed by the MACs.
Question: A hospice asked about whether a SIA payment is in order when the hospice has been called to the home because a patient has died and the Social Worker arrives first but the patient isn’t pronounced until the RN arrives some time later.
Answer: CMS indicated that SIA payments are appropriate only in cases where direct services are provided to the patient and in such cases the SIA is not applicable to the Social Worker visit.