View this email online! Hospice Notes, 2/26/2016 View Previous Issues!

TABLE OF CONTENTS:

HOSPICE REMINDER! ARE YOU READY TO CALCULATE AND REPORT YOUR AGGREGATE CAP?
PEPPER TARGET AREAS FOR HOSPICES — 2016
HOSPICE SIA BILLING FOLLOWS EXISTING VISIT REPORTING RULES
CMS RELEASES HOME HEALTH-BASED HOSPICE COST REPORT CHANGES FOR FURTHER INDUSTRY REVIEW
UPDATED INFORMATION: RECOUPMENT — MEDICARE OVERPAYMENTS MANUAL
CMS ISSUES FINAL RULE FOR SELF REPORTING OVERPAYMENTS
CMS RELEASES REPORT ON OVERSIGHT OF ACCREDITING ORGANIZATIONS
SENATE FINANCE COMMITTEE HEARING: SENATORS WYDEN AND WARNER EMPHASIZE CARE PLANNING ACT AND END OF LIFE ISSUES WITH HHS SECRETARY BURWELL
EMPLOYERS MUST POST INJURY AND ILLNESS SUMMARIES
HOSPICE ROUTINE HOME CARE (RHC) LEVEL OF CARE PAYMENT REFORM AND SERVICE INTENSITY ADD-ON (SIA) VISIT PAYMENT Q&As...
HQRP UPDATE...
HOSPICE REMINDERS...
IN CASE YOU MISSED IT, RECENT HOSPICE HEADLINES in NAHC Report...

IMPORTANT NOTICE TO PROVIDERS — QIES DOWNTIME!!

All 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. 

In addition, the following submission systems will not be available for:

  • Hospice Providers and the Hospice Item Set
  • Inpatient Rehabilitation Facilities and the IRF-PAI
  • Long-term Care Hospitals and the LTCH CARE Data Set
  • Skilled Nursing Facilities and the MDS and Payroll-Based Journal, and
  • Home Health Agencies and the OASIS

This downtime will affect ALL QIES users.  It is critical that affected Providers make the necessary contingency plans to accommodate for this downtime and ensure their data is submitted in a timely manner. 

Watch the NAHC Member Listserv and NAHC Report for future updates.

HOSPICE NOTES is a National Association for Home Care & Hospice (NAHC) member benefit; to subscribe, go HERE.  Keep an eye on the NAHC Member Listserv and NAHC Report for updates on key hospice issues!  Subscribe HERE and HERE. Please have your NAHC member ID ready.


HOSPICE REMINDER! ARE YOU READY TO CALCULATE AND REPORT YOUR AGGREGATE CAP?
Submission Deadline is March 31

Beginning with the 2014 Cap year, hospices are required to annually calculate and report their estimated aggregate Cap to their Medicare Administrative Contractor (MAC) no earlier than three months after and no later than five months following the end of the hospice Cap year (the 2015 year closed on October 31, 2015). The latest a hospice may file its self-calculated aggregate Cap calculation for the 2015 Cap year is March 31, 2016. Failure to file the Cap calculation on a timely basis and address any Cap-related liability will result in payment suspension.

Early in 2015 the Centers for Medicare & Medicaid Services (CMS) began a systems change that moved access to the Provider Statistical & Reimbursement Report (PS&R) from the IACS system to the EIDM system. Difficulties with the transition created challenges for some hospice providers related to securing their PS&R data to calculate their estimated aggregate Cap for the 2014 Cap year.  That transition was completed during the summer of 2015, and all hospice providers should ensure that they are registered in the EIDM system and that their account is active so that they may access their PS&R data to calculate their estimated 2015 aggregate Cap. A link to a CMS web page providing guidance on EIDM password reset and account registration is available here. For hospices whose accounts in EIDM are active, you may login here.

The National Association for Home Care & Hospice (NAHC) has been in contact with some of the Medicare Administrative Contractors (MACs) and has learned that the MACs do not anticipate a change in the manner in which hospices are required to calculate the aggregate Cap over the process that was used last year. Hospices should bear in mind that their calculation of their estimated aggregate Cap will NOT include the impact of the sequester. When the MACs finalize the 2015 aggregate Cap determinations later this year, their calculations will include the sequester. Those hospices whose estimated Cap calculations put them over the Cap, or whose estimates put them close to their allowable aggregate Cap should plan accordingly for a potential Cap liability linked to the final MAC determination later this year. The hospice aggregate Cap amount for the 2015 Cap year ending October 31, 2015, is $27,382.63.

Each of the MACs will post materials on their websites related to hospice aggregate Cap calculation requirements; hospices should follow their assigned MAC’s instructions -- particularly with respect to submission of the Cap calculation and any associated liability -- to ensure that their information is received timely.

Following are links to MAC-specific information that has been issued, along with any items of particular note:
CGS -- HOME PAGE
Hospice Cap (general information)
Instructions for Completing the Pro-Forma for Provider Self-Determination of Aggregate Cap Limitation

National GOVERNMENT Services (NGS) -- HOME PAGE
Hospice Cap: Self-Reporting Instructions NGS provider: please note that separate submission instructions are available depending on whether you are under the J6 or JK jurisdiction -- please follow the instructions for your jurisdiction.

Palmetto GBA -- HOME PAGE
Self-Determined Hospice Cap for 2015


PEPPER TARGET AREAS FOR HOSPICES

Below is a table showing the expected target areas for the hospice PEPPER being released in spring 2016. This is preliminary information and is subject to change prior to the distribution of the PEPPER, but if there are changes they are expected to be minimal

*Note: Target Areas may be added or modified at the discretion of the Centers for Medicare & Medicaid Services.

TARGET AREA

TARGET AREA DEFINITION

Live Discharges No Longer Terminally Ill
(Live Disch)

Numerator (N): count of beneficiary episodes who were discharged alive by the hospice (patient discharge status code not equal to “40” (expired at home), “41” (expired in a medical facility) or “42” (expired place unknown)), excluding:

  • beneficiary transfers (patient discharge status code “50” or “51”)
  • beneficiary revocations (occurrence code “42”)
  • beneficiaries discharged for cause (condition code “H2”)
  • beneficiaries who moved out of the service area (condition code “52”)

Denominator (D): count of all beneficiary episodes discharged (by death or alive) by the hospice during the report period (obtained by considering all claims billed for a beneficiary by that hospice)

Live Discharges – Revocations
(Live Disch Rev)
*new as of the Q4FY15 release

N: count of beneficiary episodes who were discharged alive by the hospice (patient discharge status code not equal to “40” (expired at home), “41” (expired in a medical facility) or “42” (expired place unknown)), with occurrence code “42”

D: count of all beneficiary episodes discharged (by death or alive) by the hospice during the report period (obtained by considering all claims billed for a beneficiary by that hospice)

Live Discharges with LOS 61-179 Days
(Live Disch LOS 61-179)
*new as of the Q4FY15 release

N: count of beneficiary episodes who were discharged alive by the hospice (patient discharge status code not equal to “40” (expired at home), “41” (expired in a medical facility) or “42” (expired place unknown)), with a length of stay (LOS) of 61-179 days

D: count of all beneficiary episodes discharged alive by the hospice during the report period (obtained by considering all claims billed for a beneficiary by that hospice)

Long Length of Stay
(Long LOS)

N: count of beneficiary episodes discharged (by death or alive) by the hospice during the report period whose combined days of service at the hospice is greater than 180 days (obtained by considering all claims billed for a beneficiary by that hospice)

D: count of all beneficiary episodes discharged (by death or alive) by the hospice during the report period

Continuous Home Care Provided in an Assisted Living Facility
(CHC in ALF)

N: count of beneficiary episodes discharged (by death or alive) by the hospice during the report period where at least eight hours of Continuous Home Care (revenue code = “0652”) were provided while the beneficiary resided in an Assisted Living Facility (HCPCS code = “Q5002”)
 
D: count of all beneficiary episodes ending in the report period that indicate the beneficiary resided in an assisted living facility (HCPCS code = “Q5002”) for any portion of the episode

Routine Home Care Provided in an Assisted Living Facility
(RHC in ALF)

N: count of Routine Home Care days (revenue code = “0651”) provided on claims ending in the report period that indicate the beneficiary resided in an assisted living facility (HCPCS code = “Q5002”)

D: count of all Routine Home Care days (revenue code = “0651”) provided by the hospice on claims ending in the report period

Routine Home Care Provided in a Nursing Facility
(RHC in NF)

N: count of Routine Home Care days (revenue code = “0651”) provided on claims ending in the report period that indicate the beneficiary resided in a nursing facility (HCPCS code = “Q5003”)

D: count of all Routine Home Care days (revenue code = “0651”) provided by the hospice on claims ending in the report period

Routine Home Care Provided in a Skilled Nursing Facility
(RHC in SNF)

N: count of Routine Home Care days (revenue code = “0651”) provided on claims ending in the report period that indicate the beneficiary resided in a skilled nursing facility (HCPCS code = “Q5004”)

D: count of all Routine Home Care days (revenue code = “0651”) provided by the hospice on claims ending in the report period

Claims with Single Diagnosis Coded
(Single Diag)
*new as of the Q4FY15 release

N: count of claims ending in the report period that have only one diagnosis coded

D: count of all claims ending in the report period with one or more diagnoses coded

No General Inpatient Care or Continuous Home Care
(No GIP or CHC)
*new as of the Q4FY15 release

N: count of beneficiary episodes ending in the report period that had no amount of general inpatient care (revenue code = “0656”) or continuous home care (revenue code = “0652”)

D: count of all beneficiary episodes ending in the report period

 


HOSPICE SIA BILLING FOLLOWS EXISTING VISIT REPORTING RULES

In recent weeks National Association for Home Care & Hospice (NAHC) members have requested clarification related to new Centers for Medicare & Medicaid Services (CMS) Medicare Claims Processing Manual language (see section 30.2.2) indicating, “The SIA [Service Intensity Add-on] payment is provided for visits of a minimum of 15 minutes [emphasis added] and a maximum of 4 hours per day…” The desire for clarification was prompted by concern that under already existing hospice visit reporting rules visits of less than 15 minutes are reported as a single visit since visits of any length are rounded to the nearest 15-minute increment (“When recording any visit… providers should sum the time for each visit … rounding to the nearest 15 minute increment”), while the manual language on the SIA references visits of a minimum of 15 minutes. The general visit reporting guidance contained in The Medicare Claims Processing Manual contains no reference to a minimum number of minutes that qualify for reporting as a single visit unit for hospice services.

In response, NAHC sought guidance from CMS to ensure that -- despite the SIA manual language -- hospice providers are expected to report visits that ultimately qualify for the SIA in the same manner that they report all other visits. CMS has confirmed that reference to a “minimum of 15 minutes” was intended to describe the lower limit of the range of units (1 to 16) eligible for the SIA, and that visit reporting requirements have not changed. CMS also referenced Medicare Claims Processing instructions for home health agencies directing that “visits of any length are to be reported, rounding the time to the nearest 15-minute increment” as applicable relative to reporting of SIA visits.

NAHC cautions all hospice providers that any visits reported on claims must meet the definition of “visit” as specified in section 30.3 of the Medicare Claims Processing Manual: “To constitute a visit, the discipline…must have provided care to the beneficiary. Services provided by a social worker to the beneficiary’s family also constitute a visit. For example, phone calls, documentation in the medical/clinical record, interdisciplinary group meetings, obtaining physician orders, rounds in a facility or any other activity that is not related to the provision of items or services to a beneficiary, do not count towards a visit to be placed on the claim. In addition, the visit must be reasonable and necessary for the palliation and management of the terminal illness and related conditions as described in the patient’s plan of care.” NAHC also reminds hospices that post-mortem time should be recorded in 15-minute increments with the “PM” modifier and is NOT eligible for the SIA.


CMS RELEASES HOME HEALTH-BASED HOSPICE COST REPORT CHANGES FOR FURTHER INDUSTRY REVIEW

In recent years the Centers for Medicare & Medicaid Services (CMS) has been expanding hospice cost reporting requirements to gather greater detail on costs by level of care. The National Association for Home Care & Hospice (NAHC) has been monitoring activity in this area and submitting recommendations to CMS through the review and comment process. The revised hospice cost report for freestanding hospice providers became effective for cost reporting years beginning on/after October 1, 2014.  Revisions to all provider-based hospice cost reports are at different points in the public review process but it is expected that all provider-based hospices will be subject to the expanded reporting requirements effective for cost reporting years beginning on or after October 1, 2015.  All hospice providers should be preparing their organizations for the expanded reporting requirements at this time.

The latest version of proposed cost reporting changes for home health-based hospices was released by CMS for public comment on February 10 with a 30-day comment period.  The notice requesting public input is available here, and the supporting documents for the notice are available here.  Of particular note in the supporting documents is a summary of the 60-DAY COMMENTS/RESPONSES FOR CMS-1728-94 as it includes CMS’ views on recommendations from home health and hospice stakeholders relative to the initial revisions proposed in September 2015.  As part of the comments, CMS confirms previous communication with NAHC and others related to use of square footage vs. dollar value as the statistical basis for capital-related movable equipment costs.  Additionally, CMS communicates that it does not intend to delay the effective date for changes to the provider-based hospice cost reporting requirements beyond the currently planned application for cost reporting years beginning on or after October 1, 2015.

NAHC will be analyzing the latest version of proposed changes to the home health-based hospice cost reporting requirements with the intent to comment as appropriate on the revised 1728-94 or more general issues related to the hospice cost report changes.


UPDATED INFORMATION: RECOUPMENT — MEDICARE OVERPAYMENTS MANUAL

CMS posted Change Request 9458, Revision to Chapter 3 Section 200: Limitation on Recoupment - Medicare Overpayments Manual. This update to the Manual and instruction to the contractors concerns the content of the letters providers will receive from the Contractor upon a redetermination/reconsideration. The update includes detail on the rebuttal process that is a good reference for providers.


CMS ISSUES FINAL RULE FOR SELF REPORTING OVERPAYMENTS

The Centers for Medicare & Medicaid Services (CMS) has issued a final rule for provider and supplier self reporting overpayment requirements.

The rule clarifies requirements for the reporting and returning of self-identified overpayments. Health care providers and suppliers have been and will continue to be subject to potential False Claims Act (FCA) liability, Civil Monetary Penalties Law (CMPL) liability, and exclusion from federal health care programs for failure to report and return an overpayment.

 The major provisions of this final rule include clarifications around: the meaning of overpayment identification; the required look back period for overpayment identification; and the methods available for reporting and returning identified overpayments to CMS.

An overpayment must be reported and returned by the later of: (i) the date which is 60 days after the date on which the overpayment was identified; or (ii) the date any corresponding cost report is due, if applicable. This final rule states that a person has identified an overpayment when the person has or should have, through the exercise of reasonable diligence, determined that the person has received an overpayment and quantified the amount of the overpayment.

In the rule, CMS finalized a look back period of 6 years, rather than the proposed 10 years, for reporting and returning overpayments.

Providers and suppliers must use an applicable claims adjustment, credit balance, self-reported refund, or another appropriate process to satisfy the obligation to report and return overpayments. In addition, if a health care provider or supplier has reported a self-identified overpayment to either the CMS or the Office of the Inspector General (OIG) using the Self-Referral Disclosure Protocol, the provider or supplier is considered to be in compliance with the provisions of this rule as long as they are actively engaged in the respective protocol.

Home health and hospice providers raised concerns with the proposed rule regarding the rule's effect on the hospice annual cap, the home health outlier revenue cap, and requests for anticipated payments (RAPs). Hospices and home health agencies have no way of knowing whether they have received a cap overpayment, or the amount, until they are notified by the MAC. CMS clarified in the rule that hospice and home health cap determinations are made at the end of the year and it is possible that the provider may not be aware of the cap status until their MAC calculates the final cap amount. Therefore, the provider is not responsible to report and refund the overpayment until they have received the cap determination from their MAC. There can be no applicable reconciliation until the final cap amount is determined.

CMS also clarified that overpayments as a result of PIP payments would be reported and returned at the time the initial cost report is due. There is no applicable reconciliation until the PIP payments are dealt with in the cost report process. However, if a provider is aware that their PIP payment may not be accurate, they should continue with normal business practices and inform its MAC of the issue.

The National Association for Home Care & Hospice will continue to evaluate the final rule and provide any additional analysis specific to home health and hospice providers.


CMS RELEASES REPORT ON OVERSIGHT OF ACCREDITING ORGANIZATIONS

In late January the CMS Survey and Certification Group sent a memo to state survey agencies that summarized the FY 2015 Report to Congress (RTC):

Review of Medicare’s Program Oversight of Accrediting Organizations (AOs) and the Clinical Laboratory Improvement Amendments of 1988 (CLIA) Validation Program. According to the Report, 62 percent of hospices are not deemed through an accrediting organization while 38 percent have chosen deemed status with one of the AOs. Of the hospices choosing deemed status, the majority utilize CHAP as their AO. The majority of surveys conducted by AOs are for a hospice’s initial Medicare certification. ACHC awarded full accreditation to 77 percent of the hospice organizations it surveyed, CHAP 85 percent and The Joint Commission 83 percent.

One of the types of surveys CMS conducts is a validation survey. The purpose of 60-day validation surveys is to assess the AO’s ability to ensure compliance with Medicare conditions, and this is determined by having the state survey agency conduct a survey of the hospice after the AO has completed its survey. Only one percent of hospices received a validation survey (16 hospices), and there was a 6% disparity rate meaning the AO missed some deficiencies. Home health agencies saw a 15% disparity rate. IDG, Care Planning, Coordination of Services, Medical Director, Organizational Environment and Volunteers were all cited for condition-level deficiencies by the SAs, but only the Medical Director condition-level deficiency was missed by the AO.


SENATE FINANCE COMMITTEE HEARING: SENATORS WYDEN AND WARNER EMPHASIZE CARE PLANNING ACT AND END OF LIFE ISSUES WITH HHS SECRETARY BURWELL

On Thursday, February 11, the U.S. Senate Finance Committee held a hearing on the President’s budget proposal for the Department of Health and Human Services (HHS), and received testimony from HHS Secretary Sylvia Mathews Burwell. During the hearing, Ranking Minority Member Ron Wyden (D-OR) and Senator Mark Warner (D-VA) emphasized the importance of the Care Planning Act (S. 1549) and end of life issues.

Last year, on June 10, 2015, Senator Warner along with Senator Johnny Isakson (R-GA) introduced a revised version of the Care Planning Act (see previous NAHC Report article here). First introduced in August 2013, the legislation was designed to give individuals with serious illness the tools with which to make more informed choices about their care and the power to have those choices honored. Senator Warner discussed the need for the legislation at the hearing, adding that he and Senator Isakson have continued to receive broad bipartisan support. The cosponsors of the bill are equally represented by Republicans and Democrats, with three from each party. In addition to Senators Warner and Isakson, the cosponsors include Senators Tammy Baldwin (D-WI), Shelley Moore Capito (R-WV), Susan M. Collins (R-ME), and Amy Klobuchar (D-MN).

“There’s not a member of the Senate that I have talked to that doesn’t have a personal story,” Senator Warner said. He spoke of his own experience with his mother who had Alzheimer’s for 11 years. Even as a “relatively well-informed citizen,” he said, his family did not have the conversations early on about care planning.

“This is an issue where the American people are candidly ahead of their elected officials,” Senator Warner said. “We still remain the only industrial nation in the world that hasn’t had this kind of adult conversation about care planning; about trying to make sure that issues around end of life are dealt with respectfully. But also recognize this is not about limiting choices but it’s about expanding choices.” Senator Warner added that he was pleased that the Centers for Medicare & Medicaid Services (CMS) activated new codes to allow payment for advanced care planning discussions (see previous NAHC Report article here). “I was pleased to see that CMS introduced a payment form for physicians to have those kinds of conversations about advanced directives and POLSTs and the other legal entities that come out of those conversations. Those conversations should include family members, loved ones, and religious advisors.” Senator Warner said he is continuing to work with CMS “to make sure that these types of advanced directives can actually travel across state lines” so that the documentation is “built into your EMR.”

Secretary Burwell responded by saying that the leadership of Senator Warner, Senator Isakson and others has “helped create the space where we could go forward and make the changes that we have made in terms of the paying. We think that’s an incredibly important first step, but we know it is a first step and now the question is, how do you implement this so this is useful to the people and meets the goals and objectives that I know we share.” Senator Wyden voiced his support for Warner’s efforts. “Senator Warner who along with Senator Isakson have really been in the vanguard of laying out some new policies to expand choices for end of life care,” he said. “What Senator Warner is talking about is—the centerpiece of end of life care should be about empowering patients and their families. And it is high time… Medicare Care Choices starts us down the path, but Senator Warner is absolutely right about several of the next steps, and I’m with you.”

NAHC has created a Legislative Action Center campaign that allows individuals the ability to urge their Senators to join Senators Warner and Isakson as cosponsors of the Care Planning Act. Please contact your Senators to cosponsor the Care Planning Act by clicking here.


EMPLOYERS MUST POST INJURY AND ILLNESS SUMMARIES

OSHA reminds employers of their obligation to post a copy of OSHA’s Form 300A, which summarizes job-related injuries and illnesses logged during 2015. The summary must be displayed in a common area where notices to employees are usually posted each year between February 1 and April 30. Visit OSHA's Recordkeeping Rule webpage for more information on recordkeeping requirements.


HOSPICE ROUTINE HOME CARE (RHC) LEVEL OF CARE PAYMENT REFORM AND SERVICE INTENSITY ADD-ON (SIA) VISIT PAYMENT Q&As

Medicare hospice payment reforms went into effect January 1, 2016. To assist providers, NAHC has developed a Q&A document on these reforms – routine home care (RHC) level of care payment reforms and service intensity add-on (SIA) payments. The document can be viewed here.


HQRP UPDATE

The following items were posted on the Hospice Quality Reporting Web Page or the CAHPS Hospice Survey Web Page:

Hospice-specific FAQs Page Updated
The Hospice-specific FAQs page has been updated to include an additional question: What reports are available to my hospice on the CAHPS Hospice Survey Data Warehouse? In addition, clarification to the following question has been added: How will my hospice access the CAHPS Hospice Survey Data Warehouse? To view these updates, please click here.

UPDATED: OMB Paperwork Reduction Act Language
The OMB Paperwork Reduction Act language has been updated for the following CAHPS Hospice Survey translations: Traditional Chinese, Simplified Chinese, Russian, and Portuguese. To view or download the updated OMB Paperwork Reduction Act language, please click here. The OMB Paperwork Reduction Act language can be found after the CAHPS Hospice Survey and cover letters.

UPDATED: English and Spanish Telephone Script
The CAHPS Hospice Survey Telephone Script in English and Spanish has been updated. Details regarding the revisions can be found in the CAHPS Hospice Survey Quality Assurance Guidelines V2.0 Technical Corrections and Clarifications document located on the Quality Assurance Guidelines page. To view or download a copy of the updated CAHPS Hospice Survey instruments, please click here.

January 2016 Technical Corrections and Clarifications to the CAHPS Hospice Survey Quality Assurance Guidelines V2.0 Document has been Updated
Additional items have been added to the CAHPS Hospice Survey Quality Assurance Guidelines V2.0 Technical Corrections and Clarifications document. This document may be accessed by clicking here. A list of the new technical corrections and clarifications included in this document can be found on the Quality Assurance Guidelines page.


HOSPICE REMINDERS

HOSPICE PHYSICIANS/NPS: DO YOU PRESCRIBE PART D-COVERED MEDS?

Over the last several months, NAHC Report has published information regarding a new Centers for Medicare & Medicaid Services (CMS) requirement that all prescribers of prescription medications that will be processed through the Part D program must be enrolled in Medicare in an approved status. The requirement was scheduled to be applicable on June 1, 2015, but this date was delayed until January 1, 2016. In a recent notice, CMS further postponed the requirement, which will now become applicable on June 1, 2016.

However, if you are a hospice physician/NP that prescribes medications that are processed through Part D (these prescriptions would be for conditions that are NOT related to the terminal or related conditions) and you are NOT enrolled in Medicare in an approved status, action should be taken before the end of 2015 to ensure sufficient time for processing of your enrollment so that your patients will not run into Part D processing issues when enforcement of the requirement begins on June 1, 2016. 

Following is information related to this issue that has been posted on the CMS Medicare Part D Prescriber webpage, along with additional resources:

Part D Prescriber Enrollment - About
If you're a physician or other eligible professional who writes prescriptions for Part D drugs, CMS regulations now require you to be enrolled in Medicare in an approved status.

The effective date for this requirement is June 1, 2016. To allow Medicare Administrative Contractors (MACs) that process the applications enough time to enroll all prescribers and to ensure prescriptions are not denied, it is strongly recommended that prescribers of Part D drugs enroll by January 1, 2016.

What happens if I don't enroll?
Federal regulation requires all physicians and other eligible professionals who prescribe Part D drugs to be validly enrolled* in the Medicare program. Part D plans will deny a pharmacy claim at point of sale for drugs prescribed by physicians or other eligible professionals who are neither enrolled in Medicare.* Enforcement of this provision is scheduled to begin on June 1, 2016; therefore, all prescribers should enroll by January 1, 2016, to allow for the processing of applications and to make sure enrollees get their prescriptions.
You can check your enrollment status using our online Enrollment File. Here are the instructions for using the file to check enrollment.

* Physicians and other eligible professionals, except for prescribers for Medicare Advantage organizations, may validly opt out of Medicare.


IN CASE YOU MISSED IT, RECENT HOSPICE HEADLINES in NAHC Report

In this section, Hospice Notes provides links to articles that have been published in NAHC Report, NAHC’s daily electronic newsletter, since Hospice Notes’ most recent publication.

  • NAHC Announces Plan to Recruit and Train Needed Home Care and Hospice Workers: Creates Home Care University and Announces Relationship with Relias Learning, February 12, 2016
  • U.S. House Speaker Paul Ryan Visits NAHC Board of Directors Chair Denise Schrader, MercyRockford Health System, February 10, 2016
  • President’s Budget Proposes More Than $470 Billion in Medicare Savings Over 10 Years, February 10, 2016
  • CDC Uniform Definitions and Recommended Data Elements to Address Elder Abuse Released, February 2, 2016
  • CBO Projections Released for Medicare and Medicaid Spending Over Coming Decade, February 1, 2016
  • NAHC Comments on Senate Finance Committee’s Chronic Care Policy Options: Hospice Comments (Article 2 of 2), January 30, 2016
  • MedPAC Finalizes 2017 Payment Recommendations for Home Health, Hospice, January 15, 2016

For questions about Hospice Notes, please contact its editors or authors
Theresa Forster, Vice President for Hospice Policy & Programs
Katie Wehri, Hospice Operations Expert

Please note that some links used in the production of the Hospice Notes are time-sensitive. These links may expire or require registration or fee-based subscriptions in order to access.

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