1) NHPCO’s Overview of FY2019 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements Proposed Rule
“ The NHPCO’s NewsBriefs Online provided the following overview of the rule:
Posted on April 27, 2018, NHPCO analyzed the proposed rule (PDF) and published a Regulatory Alert on April 30, 2018. Some highlights of the proposed rule include:
- “Hospice rates will increase by 1.8% for FY2019. The cap amount has also increased by the same percentage to $29,205.44.
- Physician assistants will be able to serve as a hospice patient’s attending physician, effective January 1, 2019.
- CMS has reduced regulatory burden for hospice providers by allowing drugs and durable medical equipment to be reported in the aggregate on the claim form, rather than the extremely burdensome per drug or per equipment reporting that currently exists.
- There will be no new hospice quality measures in FY2019.
- Data points from the hospice public information, currently available in the Provider Use File and posted by CMS, will be added to an “information” section in Hospice Compare.
CMS published a data trend analysis of hospice claims and cost report. Concerns continue to be raised about the number of patients who did not receive a skilled visit in the last seven days of life, the number of drugs paid for by Part D after the patient has elected hospice and the lack of completeness in the hospice cost report. All members are encouraged to review the detailed analysis in the NHPCO Regulatory Alert.”
Link to PDF of 2019 Proposed Rule Regulatory Alert
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2) NAHC chimes in on Proposed Rule FY2019 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements Proposed Rule
NAHC Report has also written and posted an article regarding the Proposed FY2019 Hospice Payment and Quality Reporting Proposed Rule Read it here.
Here’s a link to the May 3 NAHC webinar with NAHC President Bill Dombi and Theresa Forster discussing the proposed rule and other topics. Listen here.
Now that you’re informed, speak up! Comments are due by June 26, 2018
3) CMS Announces the Next Home Health, Hospice & DME Open Door Forum Scheduled for 5-15-2018
The next open door forum is scheduled for Tuesday, May 15, 2018 at 2:00-3:00pm Eastern Time. Call at least fifteen minutes prior to the forum start time. This call will be conference call only. To participate by phone, dial 1-800-837-1935. Reference Conference ID 33245710.
Although the agenda is subject to change, the following is on the docket:
- Opening Remarks
- Announcements & Updates
- FY 2019 Hospice Payment Update
- Proposed regulations text changes recognizing physician assistants (PAs) as designated hospice attending physicians
- Hospice QRP announcements
- HH QRP Website Recent Updates
- Announcement of June 27 MLN call on Star Ratings
- Updates on Hospice CAHPS
- Updates on Home Health CAHPS
- Hospice Claims Processing Update
- Home Health Claims Processing Update
3. Open Q&A
An encore audio recording of this call will be available beginning two hours after the conference call has ended. To access, dial 1-855-859-2056 and enter Conference ID 33245710. Note that the recording expires after two business days.
To access the ODF schedule and to register for the ODF emailing list, visit http://www.cms.gov/OpenDoorForums/.
4) Hospice Quality Updates
There is both an audio recording and a transcript available of the March 27 Hospice Quality Reporting Program webinar. During the webinar, CMS discusses two new series of learning modules: “Navigating the HQRP websites” and “HIS Coding”). Also included are updates on Hospice CAHPS. Full article from May 4 NAHC Report.
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5) Changes to Hospice Cost and Data Report
The National Hospice and Palliative Care Organization released on April 13 a regulatory alert regarding the Changes to Hospice Cost and Data Report released by CMS. CMS’s Transmittal 3 makes changes to Hospice Cost & Data Report for the reporting period ending December 31, 2017. Read CMS’s full Transmittal 3 release here.
The NHPCO emphasized the following:
- Any December 31, 2017 cost report created prior to June 1, 2018 using the existing forms (prior to the changes imposed by Transmittal 3) will be accepted.
- Any cost report created on or after June 1, 2018 will be required to be submitted using the forms incorporating the changes imposed by Transmittal 3.
- If a hospice elects the electronic signature option, the new forms reflecting the changes imposed by Transmittal 3 are required to be used.
The NHPCO highlighted the most significant changes as:
- The ability to report DME costs directly to inpatient respite care services and general inpatient costs which previously could not be reported and identified on Worksheets A-3 and A-4,
- Drugs Charged to Patients are now reportable as Direct Patient Care Service Costs (a new cost center, line 42.50) and are reported into the four (4) levels of care,
- Numerous Level 1 edits have been added to ensure reporting costs into the following cost centers:
- Line 1 – Capital Related Costs – Building & Fixture
- Line 2 – Capital Related Costs – Movable Equipment
- Line 3 – Employee Benefits Department
- Line 4 – Administrative and General
- Line 13 – Volunteer Services Coordination
- Line 28 – Registered Nurses
- Line 33 – Medical Social Services
- Line 37 – Hospice Aide and Homemaker Services
- Line 38 – Durable Medical Equipment
- Line 14 and 42.50 (combined) – Pharmacy and Drugs Charged to Patients, and
- NOTE: A cost report cannot be submitted electronically if it contains a Level 1 edit.
- The ability to submit an electronic signature with the cost report submission.
Link to NHPCO’s Hospice Cost Report PDF
6) NAHC Seeks Feedback on its Strategic Plan
As the NACH Bulletin for May 11 states, “Please weigh in on NAHC’s Strategic Plan! We’re nearing the later stages of our strategic planning process and are now looking for feedback from the community. Work on the plan has been underway for four months and will be presented to the NAHC Board of Directors for finalization in June. We’re seeking input from all with in the industry before that finalization. The actual plan can be found here and the form for comment submission here.”
7) CMS Reminder of the May 15 Hospice Item Set (HIS) Freeze Date Deadline
Remember that corrections, modifications, and inactivations need to be submitted by the deadline. Otherwise, the mistakes will appear without corrections in the data that gets processed quarterly. Via the CMS: “The freeze date for the Hospice Item Set (HIS) data that will be included in quality measure calculations for the August 2018 Hospice Compare refresh is May 15, 2018. The August refresh will include HIS data from Q4 2016 to Q3 2017 (10/1/16-9/30/17). All HIS records, including modifications/corrections and inactivations need to be submitted and accepted by the Quality Improvement and Evaluation System (QIES) Assessment Submission and Processing (ASAP) system by 11:59:59 p.m. E.D.T. 5/15/18 to be reflected in the Hospice Provider Preview Report that will be available on June 1, 2018.”
An increase in the number of corrections, modifications, and inactivations after the release of the Provider Preview Report has been detected by CMS. CMS states: “As a friendly reminder, it is the provider’s responsibility to ensure that records are complete and accurate prior to submission to the QIES ASAP system. CMS encourages providers to review quality measure data often using their CASPER QM Reports and not to wait until the freeze date or when the Provider Preview Reports are released to submit any necessary HIS corrections.”
For further information:
CASPER QM Reports Fact Sheet
HQRP Requirements and Best Practices
Public Reporting: Key Dates for Providers
8) Moral Injury Conference Call Recording Available
The Carolinas Center has made available their May 11, 2018 conference call with Joshua Briscoe, MD, a fellow in hospice and palliative medicine at Duke University. Here’s the recording link.
9) Medicare Cost Report E-Filing (MCReF)
Attention cost report staff responsible for submitting annual Medicare Cost Reports (MCRs) to Medicare Administrative Contractors (MACs) for services provided to Medicare beneficiaries: there is a new electronic filing system for transmitting cost reports. Medicare Part A providers must use MCReF starting July 2, 2018 if you elect to electronically submit your cost report.
Via MLN Matters: “Change Request (CR) 10611 informs MACs and providers of the new MCR e-filing (MCReF) system available for electronic transmission of cost reports. Medicare Part A providers file an annual MCR with the Centers for Medicare & Medicaid Services (CMS). The reports are filed with a MAC assigned to each provider. The MCR is used to determine the providers’ Medicare reimbursable costs. MACs may suspend payments to providers that fail to file their MCR on the due date. Make sure your cost report staffs are aware of the new MCReF System”
“To streamline the MCR filing process, the 2018 Inpatient Prospective Payment System (IPPS) Final Rule allows for an electronic signature on the MCR Worksheet S (Certification Page) for cost reports ending on or after December 31, 2017. Additionally, beginning May 1, 2018, CMS will make the MCReF system available to Part A providers for electronic transmission (d-Filing) of an MCR package directly to a MAC. A CMS Enterprise Identity Management (EIDM) account is required to use MCReF, which is the same account providers use to order copies of their Provider Statistical and Reimbursement Reports (PS&R).” Read the full MLN Matters article.
Cost report staff is encouraged to review the official instruction, CR10611, regarding this change. Also attached to the CR is a detailed MCReF System Overview. Link to CMS’s official instruction and overview.
10) Medicare Secondary Payer (MSP) Status/Location R B75XX
Via CGS: “The MSP status/location R B75XX is an MSP pre-payment location (e.g., R B7516). The claim will remain in this status/location for at least 75 days unless additional MSP information becomes available.”
To see: under what circumstances providers may request claims be moved out of R B75XX status/location, what reminders CGS has about provider responsibilities when it comes to Medicare Beneficiaries’ MSP records, and what further resources CGS provides regarding MSP status/location R B75XX, read more at CGS here.
11) Change in Ownership Reminder
The May 10th MLN Connects included an important reminder regarding providers needing to report changes in ownership. A 2016 Office of the Inspector General report highlighted that providers may not be informing CMS of changes in ownership. This issue of MLN Connects reminds providers that they “must update their enrollment information to reflect changes in ownership within 30 days. Owners are individuals or corporations with a 5 percent or more ownership or controlling interest. Failure to comply could result in revocation of your Medicare billing privileges.” Read the full MLN Connects reminder and the further resources they have assembled on the issue.
12) Updates made to the Home Health and Hospice Claims Processing and Issues Log
Be sure you refer to the linked issues log page often to stay current on processing issues. Please refer to this log before contacting the Provider Contact Center. Link to updated issues log from CGS.
13) Upcoming May 2018 Home Health and Hospice Provider Contact Center (PCC) Training
In order to train Customer Service Representatives (CSRs) to provide current and correct answers to the provider community’s questions despite the constant changes in Medicare, CMS allows PCCs the opportunity take some time to offer training to CSRs. The upcoming closure date and times for CSR training and staff development will be on Thursday, May 24, 2018 from 8:00-10:00 am Central Time.
A reminder from CGS: “The Interactive Voice Response (IVR) (877.220.6289) is available for assistance in obtaining patient eligibility information, claim and deductible information, and general information. For information about the IVR, access the IVR User Guide on the CGS website. In addition, CGS’ Internet portal, myCGS, is available to access eligibility information through the Internet. For additional information, go to the Home Health and Hospice website and click the ‘myCGS’ button on the left side of the webpage.
For your reference, access the Home Health & Hospice 2018 Holiday/Training Closure Schedule for a complete list of PCC closures.”
14) Medicaid Information Bulletin May 2018: Article 18-39 Rescinded
The Utah Department of Health sent out a bulletin that The April 2018 MIB article, 18-39 Emergency Services Program for Non-Citizens is rescinded.
15) CMS Issues Guidance on New Medicare Advantage Plan Benefits
CMS issued two memos with instructions regarding changes for the 2019 contract year. The May 4 NAHC report explains: “One memo relates to the expanded interpretation for health related benefits that plans will be permitted to offer their enrollees, such as home based support services. The second memo addresses CMS’ expectations for the MA plans regarding the reinterpretation of the ‘uniformity’ requirements and how this flexibility will be applied to benefit offerings. The MA plans will be permitted to provide more targeted benefits to certain enrollees beginning in 2019.”
The May 4 NAHC Report also discusses CMS’s announced intention from its 2019 MA Plan Call Letter to expand the interpretation of what is considered “primary health related” supplemental benefits: “CMS is expanding the definition of ‘primarily health related’ to consider an item or service as primarily health related if it is used to diagnose, compensate for physical impairments, acts to ameliorate the functional/psychological impact of injuries or health conditions, or reduces avoidable emergency and healthcare utilization.” Read full NAHC article.
16) Use New Medicare Cards—Medicare Beneficiary Identifiers (MBIs) Right Away
MLN Connects from May 3 discussed the new Medicare cards. Medicare patients have been instructed by Medicare to show you their new MBI card when they come for care. These new cards have new numbers that are replacing the Social Security Number based Health Insurance Claim Numbers (HICN) on the old cards. Medicare will replace all SSN-based numbers by April 2019. To protect your patients’ identities, use their new MBIs as soon as you get them. Use the MBIs to bill Medicare as soon you receive the patient’s new MBI number. Use the transition period to ensure that your systems accept and transmit MBIs.
To read more about ways your staff can get MBIs, information about transition periods, and links to Medicare resources regarding these cards, read the full MLN Connects article.
17) New Change Requests from CMS (via NHPCO’s NewsBriefs Online)
The May 3 NewsBriefs Online posted two change requests in their Regulatory and Compliance section:
“CR 10602 (PDF) – Update to the Hospital Transfer Policy for Early Discharges to Hospice Care. This CR implements the section of the Bipartisan Budget Act of 2018 to adjust hospital payments when a patient is discharged to hospice early. Discharges to hospice would qualify as a postacute care transfer and will be subject to payment adjustments for the hospital. This provision is also included in the FY2019 Inpatient Hospital proposed rule. The change is scheduled to take effect on October 1, 2018.”
“CR 10753 (PDF) – Enhancements to Processing of Hospice Routine Home Care Payments. CR 10573 creates new fields which will display the number of days paid at the high and low, Routine Home Care rates. The number of prior days will be retained for the life of the claim. In addition a separate field is added on the claim record that will store days from a prior period used in determining the count of days.”
18) NHPCO Announces the #MyHospice Campaign
“The purpose of the campaign is to reinforce the value of the Medicare hospice benefit among policy and healthcare decision makers to foster a policy environment that will support patient access to high quality, comprehensive hospice and palliative care.” Visit the My Hospice website for more information.
19) The NHPCO Makes a New Podcast Available featuring Kelly Vontran, CMS Technical Advisor for Hospice Payment Policy
“Hear a discussion on why hospice payment policy is important, the rule making process, why feedback from providers is critical and how CMS engages with the public to promote hospice.” Listen here.
20) You’re Invited: Honoring Utah Veterans with Gail Halvorsen, The Candy Bomber
This event takes place on Tuesday, May 15, 2018 from 11:30 am to 1:00 pm at American Legion Post 112. Address: 320 E 3900 S Murray, UT 84107. For event details, cost, and RSVP information, visit this website.
21) Zen Hospice Project Offers Two Open Death Conversation Workshops
Both workshops: the Open Death Conversation: An Evening Gathering and the End of Life Contemplations employ conversation and experiential activities to have open-hearted discussions regarding death.
End of Life Contemplations is a guided journey that helps us explore our own relationship with death and dying. Through experiences and conversations, the conversations get progressively deeper and our connections get stronger. Advanced directives and practical issues revolving around end of life care are addressed from both a personal perspective as well as how one can assist others with their needs.
Upcoming dates (all on Saturdays) for End of Life Contemplations are: May 12, May 19, June 2, June 9, July 14, July 21, August 11, and August 18.
Open Death Conversation: An Evening Gathering is an open forum for discussing the many facets of death and dying. The conversation is not directed. Anyone may attend and they are asked to come with an open heart and mind. People from all walks of life participate. It is an informal evening where people can come together and have a meaningful conversation regarding death and dying.
Upcoming dates for Open Death Conversation: An Evening Gathering are: June 13, July 18, and August 8.
22) Want more overviews and news? Follow the links below.
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