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NAHC Report: Issue# 2455, 6/23/2014
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Forthcoming July First Hospice and Home Health Deadlines Fast Approaching
Additional Organizations Sign Onto Part D Prior Authorization Letter
For Your Information: Open Forum, and Medicare Advantage and Managed Care Cost Analysis Discussion
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Forthcoming July First Hospice and Home Health Deadlines Fast Approaching

July 1, 2014 marks the effective date and deadline date for several Centers for Medicare & Medicaid Services (CMS) polices and initiatives for both home health and hospice providers. Following is a list of those requirements along with a brief description of each.


CMS released a change request (CR) related to hospice, CR 8569 Enforcement of the 5 Day Payment Limit for Respite Care, which, effective July 1, 2014, adds language to Section 30.3 of Chapter 9 of the Medicare Benefit Manual about the use of occurrence code M2 on claims when there is more than one respite period in a billing period and instructs MACs to return to providers any claims submitted with more than 5 consecutive days billed for respite care. CR8569 does not represent a policy change but does make clear that CMS will be enforcing the 5-day limit on respite billing.


Beginning July 1, 2014, Medicare-certified hospices must directly submit a Hospice Item Set (HIS)-Admission and HIS-Discharge record for each patient admission that occurs on or after July 1. Records must be submitted electronically. In recent weeks, the Centers for Medicare & Medicaid Services (CMS) has released numerous materials to assist hospices in their preparations for the coming requirement. Failure to collect and report HIS records for July 1 through Dec. 31, 2014, will result in a 2 percent reduction in hospice payments for fiscal year (FY) FY2016. 

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Additional Organizations Sign Onto Part D Prior Authorization Letter

On June 11, a letter with 27 organizational sign-ons, including AARP, NAHC, and NHPCO, went to CMS’ Administrator Marilyn Tavenner urging that she halt the existing Part D prior authorization processes until a better solution can be found. Since the original letter was sent, 18 additional organizations – including the American Medical Association – have offered their support and signed onto the letter.

Earlier this week, the original June 11 letter was again sent to Ms. Tavenner with the additional signatories. The letter urges that CMS put a, “halt to [CMS’ March 10 Guidance -- Part D Payment for Drugs for Beneficiaries Enrolled in Hospice—Final 2014 Guidance] until a workable alternative is developed that does not place the burden of resolving payment disputes squarely on the shoulders of terminally ill Medicare beneficiaries.” 

The letter to Administrator Tavenner is the latest effort in recent months by NAHC and others to bring attention to the many problems arising out of CMS’ requirement that Part D plans implement a beneficiary-level prior authorization requirement on drugs prescribed for hospice-enrolled beneficiaries.

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Open Forum, and Medicare Advantage and Managed Care Cost Analysis Discussion
Closing General Session at the Financial Management Conference

This year, NAHC and its affiliate Home Care & Hospice Financial Managers’ Association (HHFMA) Financial Management Conference & Exposition is being held July 13 – 15 in Chicago, IL. Once again, the Closing General Session will present its open, no holds-barred forum meeting to conclude the annual conference. The session addresses any and all issues of interest to the conference faculty and attendees. 

A special feature at this year's Closing General Session is a program focused on Medicare Advantage and managed care cost analysis.

The Managed Care Task Force Committee of HHFMA has developed an analytical tool that assists providers with the essential task of costing and pricing Medicare Advantage Plan services to assist all providers with network contract negotiations. The tool is based on the nationwide Managed care Survey conducted by HHFMA.

The seminar will include a discussion of the survey results and the use of the MA plan Costing and Pricing Tool. Be sure to plan you time at the Financial Management Conference to include this crucial program at the closing session of the conference.

Moderator: William A. Dombi, Esq., Vice President for Law, National Association for Home Care & Hospice; Executive Director, Home Care & Hospice Financial Managers Association, Executive Director, National Council on Medicaid Home Care, Washington, DC

Panelists: Pat Laff, CPA, Managing Principal, Laff Associates, Hilton Head Island, SC; Paul Giles, BS, Director of Home Health Finance, Dignity Health Care, Yorba Linda, CA ; Christopher Attaya, MBA, FHFMA, VP, Business Intelligence, Strategic Healthcare Programs, Santa Barbara, CA; Dawn Michelizzi, BS.  Controller, VNA of Greater Philadelphia, Philadelphia, PA

To register to attend this year’s Financial Management Conference & Exposition, please click here.

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