The Centers for Medicare & Medicaid Services (CMS) held its most recent Home Health, Hospice, and DME Open Door Forum (ODF) on May 28, 2014. Access to the recorded Forum is available through CMS’ Encore system by dialing 1-855-859-2056 and using conference ID code 71065438 beginning at 5 p.m. Eastern on May 28; the recording expires after 2 business days.
Below is a summary of the Forum.
QIO – Quality Improvement Organizations
Quality Improvement Program Transition Announcement
CMS currently contracts with 50 QIOs, one in each state. The QIOs operate under a Statement of Work (SoW) that includes collaboration with home health agencies on various campaigns including care transitions and other quality projects. QIOs also process appeals for discharge decisions and quality of care concerns. The 11th statement of work begins in August and is based on the CMS Triple Aim quality strategy: make health care better, better health care for populations, improve care by lowering costs.
This 11th statement of work is under a new QIO platform which brings about some changes to the QIO. These changes include extending the QIO contract to 5 years and changing some functions namely separating case review and appeals as well as consolidating QIOs. There will be two types of QIOs (1) the beneficiary and family centered care (BFCC) QIO and (2) the quality innovation network (QIN) QIO. The entire country will continue to be covered by a QIO but the QIO an agency is currently working with may change. KEPRO and Livanta have been awarded the BFCC contract. KEPRO covers 34 states in the middle of the country. Livanta covers mainly the west coast and Atlantic coast. These two QIOs will handle Medicare beneficiary complaints and reviews and appeals of notices of non-coverage.
The changes will be effective August 1, 2014 and may require home health and hospice agencies to revise their notices of non-coverage with changes to QIO name, telephone number, website, and other pertinent information
CMS will award the QIN QIO contract in July. QIN QIOs will work with providers and community on data driven quality initiatives to improve patient safety, reduce harm and to improve clinical care in the local area. This will be effective August 1, 2014 and prior to this time your current QIO will advise you on the two new QIOs and how to contact them. A new website for QIO information will be available in a few weeks.
HOME HEALTH
OASIS C-1 Implementation
CMS representatives discussed changes to the OASIS-C1 that resulted from the legislative delay in implementation of the ICD-10-CM codes. Since five of the OASIS C-1 items require use of ICD-10, CMS has opted to develop a modified OASIS C-1 which will be known as the OASIS C-1 ICD-9 version. This new version of the OASIS C-1 is scheduled for implementation October 1, 2014. CMS will make interim changes to the OASIS C-1 and also the processes used for reporting OASIS C-1 data to CMS.
Five items on the OASIS C-1 require use of ICD-10 codes. They are M01011, M01017, M01021, M01023 and M01025. These will be replaced with corresponding items on the current version of OASIS C: M01010, M01016, M01020, M01022 and M01024. This version remains in effect until 11:59 pm on December 31 2014. Modified OASIS C-1 ICD-9 version will go into effect at midnight on Jan 1, 2015 and remain in effect until ICD-10 is implemented or another determination is made by CMS.
Changes to the data submission process – on January 1, 2015 assessment data will be submitted to CMS using ASAP (assessment submission and processing system) which (originally scheduled for October 1, 2014 but now delayed). Home health agencies will no longer submit OASIS data to CMS through state databases. As of 6:00 PM eastern on December 26 2014 the state database submission platform will be shut down. OASIS ASAP will be available on midnight on January 1, 2015.
Between 6:00 PM eastern on December 26, 2014 and midnight on January 1, 2015 no OASIS assessments will be accepted. Beginning January 1, 2015 agencies must submit OASIS using the ASAP system version 2.1.0. ASAP version 2.1.1 supports OASIS C-1. Data specifications will be posted for the versions on the CMS webpage under the technical portion of the webpage. There will also be payment grouper updates. Further information can be found here.
The OASIS C-1 webinar originally scheduled for April 2014 has been rescheduled for September 30, 2014 at 2:00 pm eastern. CMS will publish a new survey and cert letter within next two weeks on how to dial in for the webinar. There will be no registration process so agencies are encouraged to call in 20-30 minutes before session. CMS will not accept live questions during webinar. The recorded session and answers to submitted questions will be available a couple of weeks later. OASIS questions can be submitted to: cmsoasisquestions@oasisanswers.com
Home Health Claims Processing Update
On May 8, 2014 CMS released a notice regarding payment calculation errors for claims with HIPPS codes beginning with 3AGP. These HIPPS codes are receiving an incorrect case-mix weight that results in underpayment. Also, certain claims that would be eligible to be paid low utilization payment adjustment (LUPA) add-on amounts are not receiving the add-on payment. These errors affect only home health claims with "Through" dates on or after January 1, 2014.
Home health agencies do not need to take any action. Medicare Administrative Contractors will adjust the claims to correct payments. Claims with the HIPPS codes beginning with 3AGP are now being paid correctly but the LUPA issue is not resolved. CMS will be issuing new software in the near future to correct this issue, most likely later in June. Again, home health agencies do not need to take any action to correct these claims.
Clarification to the Medicare Claims Processing Manual
Between this ODF and the next one CMS will release a CR 8775 revising chapter 10 of the Medicare claims processing manual. This CR provides clarification to billing instructions and is a routine maintenance update.
HHCAHPS
There is still time for home health agencies to participate in HHCAHPS in order to meet the 2016 annual payment update requirements that began April 2014 if the agency begins immediately. Agencies can email hhcahps@rti.org to start HHCAHPS participation. In these situations, agencies will also need to register on the website and contract with an approved vendor. This information is available on HHCAPS websitehttps://homehealthcahps.org or call RTI for assistance at 866-354-0985.
If agencies currently participating ever have trouble submitting their patient file monthly to their survey vendor they should immediately notify the survey vendor. The vendor will document this in the HHCAHPS discrepancy notification report which is used by CMS in determining whether agencies have met participation requirements for annual payment updates. The presenter reminded home health agencies that there must be four quarters of data in order for the HHCAHPS information to be reported on the Home Health Compare website. Questions should be submitted to hhcahps@rti.org and orhomehealthcahps@cms.hhs.gov.
HOSPICE
Medicare Care Choices Model (MCCM)
Applications are due June 19, 2014. CMS stressed that beneficiaries are hospice-eligible but not enrolled in the Medicare hospice benefit while a participant of the MCCM. Patients will receive palliative care from the participating hospices while receiving curative treatment. CMS is seeking at least 30 hospices to participate in the Model. The hospices must demonstrate experience providing case management and care coordination along with shared decision making in conjunction with referring providers and suppliers.
Chosen hospices will be highly integrated with the curative providers and coordinate services and managed the cases with the curative providers. Payment is $400 per beneficiary per month to the hospices. CMS stressed that applicants must apply by the provider number. CMS is looking to understand the uniqueness of each service area and population based on these provider numbers that may be under one umbrella company. The MCCM is not a grant. Refer to the CMS Innovation Center website for more information. Submit questions to: carechoices@cms.hhs.gov.
Changes to the Medicare Benefit Policy Manual
ChangeRequest (CR) 8727 was reviewed for hospice providers. This CR updates and clarifies the hospice chapter of the Medicare Benefit Policy Manual. It does not change existing policy. Further information can be found here OR here.
Hospice FY2015 Proposed Rule
Presenters also provided a summary of the payment section of the FY2015 hospice proposed rule. Main points are:
- Proposed 1.3 percent increase in rates (does not include sequestration)
- Definitions of terminal illness and related conditions – the definitions are not proposals; instead CMS is soliciting comments on the definitions
- Proposed timeframes for submission of the notice of election (NOE) and a notice of termination/revocation (NOTR) – within 3 calendar days of effective date of election or effective date of discharge/revocation
- Proposed that the attending physician chosen by the patient be identified on the statement of election and the patient/representative sign an acknowledgement as part of the election statement that he/she chose the named attending.
- Proposed that hospices complete their Inpatient and aggregate cap calculations within 5 months of the end of the cap year remit overpayments at that time or face suspended payments
Hospice CAHPS
Hospices will do a dry run January 1, 2015 through March 31, 2015. Hospice must participate in the dry run for one or more of these months. Beginning April 2015 hospices are required to participate on a monthly basis. There is an exemption for hospices that have served less than 50 survey-eligible patients between January 1, 2014 and December 31, 2014.
Hospices must apply for the exemption if they qualify. CMS is soliciting comments on Hospice CAHPS. Per the presenter CMS is very close to finalizing the survey instrument. Hospices will have a single survey instrument for all settings of care. Topics covered in the survey instrument are:
- Hospice team communication
- Getting timely care
- Treating family with respect
- Emotional support
- Help for symptoms
- Understanding side effects of pain meds
- Information continuity
- Getting hospice care training (i.e. what side effects to watch for and when to give medication, etc.)
The Hospice CAHPS site is expect to go live July 2014.
Questions on Hospice CAHPS can be submitted to: hospicesurvey@cms.hhs.gov.
HQRP
A summary of the update to the HQRP as in the FY2015 proposed rule was provided. CMS is not proposing any additional new measures at this time. They do propose to:
- codify the requirement finalized in last year’s rule which is for hospices to complete and submit an HIS for each patient admission and patient discharge
- exclude from the quality reporting requirements for payment year 2016 all newly certified hospices that receive their CCN on or after November 4, 2014
- codify an exemption for extraordinary circumstances (i.e. disaster waiver)
- codify the reconsideration process for hospices getting a 2% reduction
CMS is seeking comments on public reporting of the hospice quality reporting update.
Presenters reminded hospices that HIS submission begins on July 1, 2014 and that the HIS manual, latest version will be posted shortly.
Q&A
One participant asked if CMS has plans to support the submission of the Hospice NOE and NOTR electronically. CMS panelists responded by indicating that CMS does not have an electronic platform that would support this submission. The panelist was not sure about the possibility of building other systems; and, in the near term, the answer is “no”.
Another participant asked by what date the Hospice CAHPS exemption application must be submitted and if providers that meet qualifications for the exemption must participate in the dry run. These hospices do not have to participate in the dry run if meeting the exemption requirements. The exemption application deadline date has not been determined yet. Hospices will be able to apply for the exemption via the website anticipated to be available in July. CMS will publicize the deadline date in the future.
Another HQRP question was what mode of surveys will be available for Hospice CAHPS and when can the hospices and vendors receive the script for training survey interviewers. CMS indicated that the mode of surveys will be mail, phone and mixed mode (mail with phone follow up). The survey instrument will be available on the website when it goes live in July.
There was a question on the MCCM – if two hospices offices are under same provider number is the application to use the joint information for the provider number or each individual office’s information? The hospice is to submit one application and describe both locations using the data by provider number.
A participant asked if the Medicare condition of participation requirements are applicable to the Medicare managed care patients in a home health agency. CMS answered that any patient served by the provider falls under the conditions of participation except for those requirements that specify applicability only to Medicare or Medicare/Medicaid beneficiaries such as the OASIS.
A caller stated that the HIS submission system only works on Internet explorer and asked if there is any consideration of using other browsers? CMS will need to research this.
The next Home Health, Hospice, and DME Open Door Forum is scheduled for July 9, 2014
