The Centers for Medicare & Medicaid Services (CMS) held its most recent Home Health, Hospice, and Durable Medical Equipment (DME) Open Door Forum (ODF) on July 9, 2014. CMS officials discussed the 2015 proposed rule for the home health prospective payment system (HHPPS), hospice reporting of DME items and the hospice CAHPS survey. Access to the recorded Forum is available through CMS’ Encore system by dialing 1-855-859-2056 and using conference ID code 44430036 beginning at 5 p.m. Eastern on July 9; the recording expires after 2 business days.
The proposed rule for the HHPPS rate update for 2015 went on display June 2, 2014 and includes both payment and non-payment related changes.
CMS proposes the following changes and clarifications to the Face to Face requirement:
- Eliminate the narrative requirement
- Only consider medical records from the patient’s certifying physician or discharging facility in determining initial eligibility for the Medicare home health benefit.
- Claims for physician certification/re-certification for home health services be considered a non-covered service if the HHA claim was non-covered because the patient was ineligible for the home health benefit.
- The proposed rule also clarifies that a new F2F encounter document must be completed when ever a start of care OASIS assessment is required, even if there has not been more than 60 days between episodes.
The proposed rate updates for Calendar year 2015 (CY) include the continuing phase in of the rebasing adjustments set out in the 2014 HHPPS rule. In addition, the 2.6 % market basket rate update will be decreased by .4% to equal 2.2% market basket update. The .4 % decrease reflects the required productivity adjustment.
CMS proposes to recalibrated the case mix weights for 2015 using 2013 data, and recalculate the home health wage index using the Office of Management and Budget newly delineated core based statistical areas(CBSA). For CY 2015, the wage index will be 50/50 blend of the 2014 and the 2015 wage index.
The proposed rule outlines a plan that sets a threshold for the quality reporting program. Agencies will be required to submit 70 % of OASIS quality assessments beginning July1, 2015 –June 30, 2106 in order to receive the full annual payment update for 2017. CMS will increase the threshold by 10 % for the each year until a 90% percent threshold is reach. A value based purchasing model is proposed to potentially begin in 2016. The plan would include a payment increase or reduction of 5-8 % and apply to all HHAs in each of 5-8 states selected to participate. Lastly, the proposed rule includes changes to the Conditions of Participation for speech language pathologist qualifications.
Although the CMS officials did not comment on the provision addressing coverage of insulin injections, CMS is proposing to require that agencies list a diagnosis on the claim that supports why the patient is unable to self inject for those patients receiving home health services for the sole purpose of insulin injections. A list of acceptable diagnoses has been proposed for which CMS is seeking comments.
There were several question posed regarding the face-to-face documentation requirement.
One was whether, with the proposal to eliminate the physician narrative requirement and have the documentation supporting the need for home health and the homebound status be in the hospital notes/physician notes, would CMS require the home health agency to have this documentation right away or would it be alright for the home health agency to request it upon receipt of an ADR. CMS claimed they could not provide further clarification while the comment period for n the proposed rule was open, but encouraged providers to use the comment period as an opportunity to submit comments related to the provisions in the proposed rule.
Another face to face-related question was, if the proposed elimination of the physician narrative requirement were to come to fruition, how would this impact medical review? What instructions would be given to the MACs? CMS did not have answer but did indicate this issue has been brought up and they are looking into it.
Summary of Hospice Topics
Hospice Reporting of DME Items
Since April 1, 2014 hospices have been required to report certain drugs and equipment on the hospice claim. Some of the claims are being returned to provider (RTP’d) in error. These erroneous returns have reason code W7061 or W7072 and are occurring on claims including infusion pump data. CMS is in the process of providing instruction to the Medicare administrative contractors (MACs) that will authorize MACs to override the edits so the claims will be processed. The overrides will be applied automatically so there will be no corrective action required of hospices. This instruction should be issued shortly per CMS. Hospices should check their MAC’s websites for implementation dates as these may vary by MAC. During the question and answer portion of the call, CMS indicated that hospices are free to make their own determination about whether to submit claims in the interim without the infusion pump data and then submit an adjusted claim when the corrective override is in place or hold the claims until the override is in place.
The hospice CAHPS website will launch later this week and will have an address ofwww.hospicecahpssurvey.org CMS suggest hospices visit the site on Friday or Monday. There providers will find a copy of the final hospice CAHPS survey instrument as well as the vendor minimum business requirements. Potential vendors will be able to download participation forms which can be filled out beginning next week. CMS has scheduled hospice CAHPS vendor training for early October. Questions about hospice CAHPS can be submitted to email@example.com
A caller representing eleven hospice facilities shared concerns about hospice termination (revocation/discharge) and hospice election information not being current and accurate in the CWF and the issues this causes for hospices, especially related to the determination of which benefit period the patient is in and the face to face encounter requirement. The same caller stressed the horrific time patients are having in getting their medications when they’ve revoked or been discharged from hospice but the Medicare system does not contain this information. The caller shared that even though the hospices are providing the discharge/revocation paperwork to the Part D sponsors the sponsors are not accepting the documentation and are still requiring the patient to go through the Part D prior authorization process. CMs responded that the Medicare Part D folks have received a number of reports of these types of issues and encouraged the caller to submit concerns via the ODF mailbox so the questions could be submitted to the proper department. The address suggested by CMS staff on the call for submitting questions and concerns is:Homehealth_hospice_dmeodffirstname.lastname@example.org.
PLEASE NOTE: Questions and comments about the Part D prior authorization process may also be submitted directly to PARTDPOLICY@cms.hhs.gov; please include “Hospice” in the subject line to ensure prompt referral of the email to the correct subject matter expert.
Several callers asked questions about the Hospice CAHPS. CMS responded that the protocols and guidelines for the hospice CAHPS survey will not be available when the website goes live this week but are expected to be available by September, as is the list of approved vendors. The final survey instrument has 47 questions which include demographic questions for both patients and the person answering the questionnaire. Some questions apply only for certain settings so it is anticipated that most responders will be answering fewer than 47 questions.
There was a question regarding the additional drug and equipment reporting requirements (Change Request 8358). Specifically, there appears to be a problem with revenue code 0291 and the corresponding HCPCS code. Providers are being told by MACs to remove the HCPCS code and then resubmit the claim but this fix is not working. There may be a problem with the J code that is used on this claim line. On some of these types of claims providers are receiving the claim with reason code 33206. CMS is checking into this but did indicate that the HCPCS code is required on the claim.
PLEASE NOTE: It is NAHC/HAA’s understanding that all the MACs are experiencing issues with claims that include certain HCPCS codes; as these issues arise the MACs are working to address their internal systems issues that are keeping claims from processing properly. Please see previous NAHC Report coverage of these issues here.
In response to a question about the possibility of the physician narrative requirement being eliminated for the hospice face to face encounter documentation requirements, CMS indicated that if this were to occur a proposal is necessary and no such proposal has been made at this time.
The next scheduled Home Health, Hospice and Durable Medical Equipment Open Door Forum is scheduled for August 20, 2014.