CMS Holds Latest Home Health, Hospice, & DME Open Door Forum
May 6, 2016 11:41 AM
The Centers for Medicare & Medicaid Services (CMS) held a Home Health, Hospice, and Durable Medical Equipment (DME) Open Door Forum (ODF) on May 4, 2016. Relative to home health and hospice, the CMS panel shared information on the following:
FY2017 Hospice Notice of Proposed Rule Making (NPRM)
Medicaid home health face-to-face (F2F) final rule
Home health value based purchasing
Home Health CAHPS
Home health star ratings
Please note: CMS will have a recording of the ODF available until 5 p.m. EASTERN on Friday, May 6, that may be accessed by calling: 1-855-859-2056 and using conference ID: 39979021.
FY2017 Hospice NPRM
CMS summarized the proposed changes to the hospice payment rates, the update to the wage index upon which the rates are based, and the aggregate cap amount as well as the proposed changes to the hospice quality reporting program (HQRP) (see NAHC Report April 22, 2016 for a detailed summary). CMS confirmed the anticipated dates for public reporting of hospice quality data via a Hospice Compare website (mid-calendar year 2017) and hospice demographic data will be available in advance in late spring/early summer 2016.
For the CAHPS hospice survey, CMS reminded providers that the next survey data submission deadline is May 11. Vendors will be submitting data for the last quarter of 2015. CMS urged hospices to contact their vendor to ensure the vendor is on track to meet the May 11 deadline. CMS also reminded providers there are updates to the CAHPS Hospice Survey Quality Assurance Guidelines as well as other announcements, all available at www.hospicecahpssurvey.org.
Medicaid HH F2F Final Rule
The Medicaid HH F2F final rule, CMS 2348-F, implementing a Medicaid F2F encounter compliant with the ACA and codifying various Medicaid policies in regulation was reviewed. CMS stressed that the final rule clarifies that Medicaid home health services can be provided in any setting and may not be subject to a homebound requirement and that CMS tried to align the F2F regulation with Medicare as much as possible. The effective date is July 1, 2016, but CMS recognizes there may be some budgetary or other constraints that are state-specific and states may need to go to their legislature for changes. To accommodate such needs, states must be in compliance with the regulation within one year if the state’s legislature met this year but if the legislature was not in session this year the state has two years from the effective date to be compliant.
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CMS reminded home health agencies in the nine states that are part of the value-based purchasing (VBP) pilot that they need to establish primary contact at the home health agency and CMS does not have this information for every agency in all of the nine states. Once approved as the primary point of contact (PPOC) for the VBP application, the PPOC will have access to the VBP secure portal. Multiple individuals within an agency may have access to the portal. CMS urged home health agencies to be thinking about roles in their organization that they want to have privileges and start the approval process for these staff. If only one staff member has access to the portal, all functions within the portal will need to be done by the PPOC.
Please note: When going through the approval process, home health agencies should only select roles in the CMS drop down box that begin with “HHA” as these are the only allowed roles to have access. Choosing a role from the drop down box that does not begin with “HHA” will cause the request to be denied.
There will be a live tour of the portal on May 12, 2016 for those approved for portal access. Registration is required.
The 2015 benchmarks and achievement thresholds have been set and the information is available in HVBP Connect. Individual HHA data is included in the quarterly performance reports which will be available in July. Updated FAQs also have posted on the site.
CMS reviewed the HH CAHPS and reiterated that if a HHA is not yet participating, it is never too late to join. The next submission of the list of patients is due May 21 – May 25 but there is allowance for later submission, but only under certain circumstances. Any questions should be directed to firstname.lastname@example.org call 1-866-354-0985.
Home Health Star Ratings
CMS revised data in April and would like to note that if an agency’s HH CAHPS data is on Home Health Compare but the star ratings are not shown, it is because the agency did not have 40 or more surveys during the period.
IMPACT Act – Home Health
CMS welcomes stakeholder community input and partnering. Those interested can view the IMPACT Act webpage and choose the upcoming stakeholder engagement opportunities. There are events each month.
There will be a Special ODF May 12, 2016 from 2-3 PM Eastern to allow patient/family and other interested parties to participate.
CMS is also participating in the Long Term and Post-Acute Care Health IT Summit held June 26-28 in Virginia. CMS will offer information on the IMPACT act during this Summit.
HH VBP- A participant followed the instructions for requesting access and was stopped at identity verification because she did not have a credit history due to not having any lines of credit. She called the helpdesk and they could not help her (nor could Experian) so this person also sent an email to the helpdesk and has not received a response.
CMS suggested calling the helpdesk for such issues as there is a system established for these types of instances where an individual can provide other acceptable documents for approval (they will deal directly on this issue with the individual participant).
Another participant indicated that she heard at a recent conference that agencies in some states in the HH VBP pilot had received their agency-specific reports and asked if this was accurate. CMS responded that no agencies have yet received these reports.
Another participant asked why it is CMS’ policy to normally ask for the Social Security Number (SSN) of those applying for access to the portals. CMS indicated that it is and the SSN is not stored in the database anywhere.
Hospice RHC rates– A participant noted that one of the Medicare Administrative Contractors (MACs) posted an update on hospice RHC rates not paying correctly, this was to be fixed with the July 1 update and this is now postponed until January 2017. Why is it taking so long to fix a system that should have been ready to go by January 1, 2016? Can you share how FISS maintainer works and why it takes so long to get a fix?
CMS responded by acknowledging that this process is taking longer than desired and that while not aware of the specific issue posted by the MAC, CMS is aware that there are a few issues affecting the high and low RHC rates. One fix is supposed to take effect in July and they are not sure when all the issues will be fixed.
Hospice CoPs 418.78paragraph 2 – an attendee requested guidance on services under the Medicaid personal care benefit and whether the hospice may apply the standard related to training the family for addressing items included in the plan of care. The attendee indicated that her hospice routinely teaches family members to change dressings and administer medications so does this mean the hospice can do the same with personal care attendants?
CMS responded that they did not have anyone on call who could answer this and instructed the participant to submit the question to the ODF mailbox at HomeHealth_Hospice_DMEODF-L@cms.hhs.gov
Hospice Quality Reporting Program– A participant asked if with the release of Hospice Compare will CAHPS hospice survey data be reported with first release.
CMS indicated that CAHPS hospice survey data will not be reported until there are at least four quarters of data that can be publicly reported, and reiterated that sometime in 2017, probably summer, the Hospice Compare site will have be available and populated with hospice data.