CMS Open Door Forum Provides Home Health, Hospice Updates
July 18, 2016 08:50 AM
The Centers for Medicare & Medicare Services (CMS) conducted a Home Health, Hospice and Durable Medical Equipment (DME) Open Door Forum on July 13. A summary of home health and hospice issues are provided below.
HOME HEALTH ISSUES
2017 HHPPS Rate Update Proposed Rule. CMS provided the following overview of 2017 home health rate update proposed rule:
The proposed rule implements the final year of the four year phase-in of the rebasing adjustments to the national, standardized 60 day episode payment rates, the national per-visit rates, and the non-routine medical supplies (NRS) conversion factor. In addition, this proposed rule would reduce the national, standardized 60-day episode payment rates by 0.97 percent in CY 2017 to account for nominal case-mix growth between CY 2012 and CY 2014. The CY 2017 proposed rule would result in a 1.0 percent decrease (-$180 million) in payments to HHAs. CMS is also proposing changes to the methodology used to calculate outlier payments from a cost per visit to a cost per unit model. As required by the Consolidated Appropriations Act of 2016, CMS proposes changes in payment for disposable Negative Pressure Wound Therapy (NPWT) for patients under a home health plan of care. The Act requires CMS to pay for the NPWT separately and equal to payment made under the hospital outpatient prospective payment system. CMS also proposes an update to the Home Health Quality Reporting Program (HHQRP). Lastly, in addition to providing an update on the progress towards developing public reporting of performance under the Home Health Value Based Purchasing model (HHVBP), CMS proposes several changes and improvements related to the model.
HHVBP. CMS proposes the following changes and improvements to the model:
Removes the following four the quality measures, beginning for the 2016 reporting year
Care Management: Types and Sources of Assistance Prior Functioning ADL/IADL
Influenza Vaccine Data Collection Period: Does this episode of care include any dates on or between October 1 and March 31
Reason Pneumococcal Vaccine Not Received
Requires annul reporting and submission of the influenza vaccine measure rather than quarterly.
Increases the time frame to submit new measure from 7 calendar days to 15 calendar days
Calculates performance benchmark and achievement threshold based on the state level rather than cohorts
Defines a small-volume cohort for performance comparison and calculation of payment adjustments as having a least eight HHAs
Adds an appeals process to the total points score and payment adjustment to include a request for recalculation and reconsideration.
Outlines the process for public reporting of performance related to HHVBP
CMS officials announced that agencies should expect to receive their first interim performance report this month. Agencies may access the report through the HHVBP secure portal. CMS will be hosting a webinar on the performance reports on July 28 at 2pm. Agencies can obtain information and register for the webinar by going to the HHVBP connect site.
HHQRP. The presenters provided an overview of several proposed changes to the HHQRP.
CMS proposes to eliminate 28 measures, and add the following four new measures as required by the IMPACT Act.
Drug Regimen review conducted with follow-up – OASIS
Discharge to community
Potentially preventable 30 day post discharge readmission
Also in the proposed rule, CMS listed eight new measures under consideration for home health agencies.
The policy for public reporting of measures adds a review period and correction process prior to measures posting on Home Health Compare.
IMPACT Act. The presenters also addressed stakeholder engagement opportunities related to the IMPACT Act and encouraged participants to view the CMS IMPACT Act web site. One such opportunity occurring in July is the field testing of standardized data elements among post acute care (PAC) providers to test the validity of the standardized data elements and the feasibility of collecting the items in all four PAC settings. CMS also announced that it plans to conduct webinars related to the IMPACT Act activities every 8 weeks.
Hospice Payment Reform/Claims Processing Update. Claims processing staff provided an update on issues that have emerged since the two-tiered payment system for Routine Home Care (RHC) and the Service-Intensity Add-on (SIA) were instituted on January 1, 2016. These claims processing issues may be reported in your Medicare Administrative Contractor’s (MAC’s) Claims Issues Log. Four problems have surfaced; they are described below along with the scheduled plans to address them:
First, CMS received reports that the Common Working File (CWF) did not always identify prior hospice days that should have counted toward the episode day count. This occurred when a revocation posted prior to the final claim coming in. As a result, hospices were receiving the high RHC rate for some days for which they should have been receiving the lower payment rate. A revision to the system was implemented on May 9 and hospices should no longer be experiencing this problem.
A second issue has been occurring in the Fiscal Intermediary Shared System (FISS) system where FISS is not always using the correct date to start the episode of care day count if a previous period of hospice care was recorded. At times FISS used the start of a previous benefit period to begin the count rather than using the current benefit period (when a 60-day period had intervened). The result is that too many days are being included in the current episode of care so providers are being underpaid. A correction to this error is scheduled for July 25, after which the MACs will adjust the claims.
Two additional issues related to claim processing under the new hospice payment system are scheduled to be addressed in January 2017 (a Change Request addressing these will be issued during the first week in August). The first issue relates to circumstances under which systems are not applying all days from multiple prior benefit periods in the day count for the episode. The second issue relates to payments for the end-of-life SIA payments for certain claims. While changes to correct both of these problems have been completed by the MACs, the changes did not fully address the problems, so additional changes must be made.
Hospice CAHPS.The Hospice CAHPS survey website is: http://www.hospicecahpssurvey.org/; technical questions related to the survey may be directed to the CAHPS Hospice Survey Project Team at hospicecahpssurvey@HCQIS.org or by calling 1-844-472-4621.
Notices for non-compliance with CAHPS survey requirements affecting the FY2017 payment year have been mailed to hospice providers; if a hospice has received a notice of non-compliance and wants to request a reconsideration, please follow the instructions contained in the letter. The deadline for filing the recondition request is Friday, July 29. The following recommendations were stated:
First, as part of your reconsideration request, DO provide evidence that your hospice is compliant. If you need guidance on such information please contact the Technical Assistance team.
Second, DO include the correct CCN or provider number on your request; otherwise there will be problems with processing of your reconsideration request.
Finally, DO NOT include protected health information (PHI) or personal information about patients with your reconsideration request. These are a violation of HIPAA and CMS is required to report agencies that perform such violations.
CAHPS Exemption for Size.The CAHPS Hospice Exemption for Sizeform for 2018 APU is now available on the CAHPS Survey Website and will remain available until August 10, 2016, which is the deadline for submission. You MUST submit a request to have CMS consider giving you an exemption for size. Be sure to use the correct CCN with your exemption request and submit your form as soon as possible.
A list of CAHPS Hospice vendors is available on the CAHPS Hospice website. Please stay in touch with your vendor and make certain that they are submitting your data in a timely fashion. Successful submission includes acceptance of your records by the data warehouse.
Deadlines for submission/acceptance of CAHPS data are the second Wednesday of February, May, August, and November. CMS recommends that your monitor your vendor for performance as you would any investment -- the quality of vendor performance varies. CMS cannot accept late CAHPS data submissions, and it is the hospice that will be penalized. A hospice may gain access to the data warehouse so that it can monitor activities of its vendor on behalf of the hospice, and CMS recommends that hospices take advantage of this opportunity.
Hospice Quality Reporting Program. Between June 15 and 29 CMS sent notices related to non-compliance with the quality reporting requirements for the FY 2017 APU. Hospices receiving such notices have the opportunity to submit a request for reconsideration. Please view the following web site for more information on requesting reconsideration: https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Hospice-Quality-Reporting/Reconsideration-Requests.html.
A New Hospice Data Directory is now available on www.data.medicare.gov ; this directory includes information on all hospices certified by Medicare and high level demographic data for each agency. Establishment of the data directory is CMS’ first step toward public reporting for hospice providers. CMS is currently actively developing a Hospice Compare website, which should be ready by mid-2017. CMS’ plans are for Hospice Item Set (HIS) measures to be posted on the Compare site, and eventually will post CAHPS and other data there. Hospice providers should check to ensure that data related to their agency is correct and report any errors to the regional office coordinator.
HIS Data Submission Specifications (v2.00.0) are NOW available in draft form in the DOWNLOADS section at the bottom of the HIS Technical Information page. These specifications go into effect April 1, 2017.
A New Hospice Timeliness Compliance Threshold Report will be available beginning July 17, 2016 in the CASPER Reporting Application. This report will allow hospice providers to determine how well they are meeting the new timeliness requirement that 70% of CY2016 submissions are accepted by the deadline.
Following is a summary of questions and answers related to hospice issues that were posed during the Open Door Forum:
Hospice Claims Processing Issues. One caller requested a written claims processing update related to hospice payment reform processing issues. CMS staff indicated that most of the MACs should have updates included under their Claims Issues Logs. A Change Request related to some corrections will be available during the first week of August; additionally, staff offered to include an article on outstanding payment reform issues and their status in a forthcoming edition of CMS’ Thursday E-news.
Hospice CAHPS. When will group share calculation of how hospice CAHPS measures will be scored? CMS staff indicated that the final decision on this issue has not yet been made.
Hospice and HH CAHHPS.A participant asked is CMS would be willing to make available the number of clients (providers) per state are covered by each vendor as that may be an indicator of vendor usefulness to providers? A CMS CAHPS representative said that CMS will look into that, but suggested that the number of providers used per state will not be a determinant of the quality of work that the vendor does. CMS’ Office of General Counsel is currently looking at what information CMS can make available related to vendors.