On March 18, 2014, the Centers for Medicare & Medicaid Services (CMS) announced the launch of its Medicare Care Choices Model (MCCM). Under the MCCM, as many as 30 Medicare-certified hospices will be selected to provide palliative support services in the form of routine home care (RHC) and inpatient respite to patients with advanced cancers, chronic obstructive pulmonary disease, congestive heart failure and HIV/AIDS who meet hospice eligibility requirements.
Since announcement of the model, CMS has received numerous inquiries from hospices interested in participating in the model; in response, CMS has issued a series of frequently asked questions (FAQs) to address those inquiries. The latest version was issued on May 30; the FAQs are reprinted below for the convenience of interested hospices.
May 30, 2014
Can a networked group of hospices that are under State Action Immunity combine to apply for the Medicare Care Choices Model?
Yes. By law, or under State Action Immunity, none of these applicant hospices may compete for service. All agencies must serve everyone, regardless of where they live in the service area and regardless of payment source. Combined applicants must explain in their application their past experience working with other Medicare certified and enrolled hospices to provide coordinated care services with other providers in their service area. For these applicants, data must be shown separately by each applicant’s National Provider Identifier (NPI) number and then totaled across all of the applicants’ provider numbers. This combined application will be reviewed and determination for awards will be based on the merits of the group of applying hospices as a whole. Payment to hospices selected to participate in the Model will be made directly to the hospice utilizing its NPI number. Each hospice in the networked group remains responsible for its unique beneficiaries.
If a Medicare certified and enrolled hospice has exceeded the aggregate cap limit in the years specified in the Request for Applications and is currently in good standings with repaying monies back to Medicare, can that hospice apply for the Medicare Care Choices Model?
No. A hospice that has exceed their aggregate cap limit for the time period stated in the Request for Applications does not meet the qualifying criteria specified in the section Basic Requirements of Eligible Applicants. The applicant must demonstrate it is in good standing as demonstrated by not exceeding the inpatient hospice cap or the aggregate hospice cap for the cap years (11/1-10/31) 2012, 2011, and 2010 for which data are available.
Would the hospice agency be able to limit the number of beneficiaries they enroll in the Model?
Yes. The request for applications Model Design section requests information on the number of beneficiaries the applicant anticipates enrolling in the Model as well as an explanation of how the applicant arrived at this estimate.
Is review of the individualized care plan that includes the patient centered goals required every 15 days or every 30 days?
As per the Conditions of Participation at §418.56 (d) Standard: Review of the plan of care, the hospice interdisciplinary group (in collaboration with the individual's attending physician,) must review, revise and document the individualized care plan as frequently as the patient's condition requires, but no less frequently than every 15 calendar days.
Does the Model require a Hospice RN Case Manager (RNCM) to complete an in-person assessment for the purposes of updating the patient-centered goals and plan of care or, under this Model; is it acceptable to make updates based on telephone check-ins with the patient and patient’s team of healthcare providers?
The Conditions of Participation at §418.56 require the interdisciplinary group, as a whole, to update the comprehensive assessment at least every 15 days, and more frequently as the patient’s condition requires. While not explicit in the Conditions of Participation, the process to update the plan of care requires a face-to-face visit and assessment by the RN as the revised plan of care must include information from the patient's updated comprehensive assessment and must note the patient's progress toward outcomes and goals specified in the plan of care.
Is a RN case manager required for this Model, or could a hospice develop a model utilizing a Social Worker case manager?
The Conditions of Participation at §418.56 require that the hospice interdisciplinary group must designate a registered nurse, who is a member of that interdisciplinary group, to provide coordination of care and to ensure continuous assessment of each patient’s and family’s needs, and to ensure continuous implementation of the interdisciplinary plan of care. Whether the hospice chooses to add a social worker as a case manager, in addition to the required RN coordinator, is up to the Model participant.
Can a main hospice with multiple other hospices, each having their own National Provider Identifier (NPI), submit one application or must each hospice apply individually to participate in the Model?
Each hospice location participating in the Model must have an individual National Provider Identifier and must apply individually using its provider number. Each application will be reviewed and evaluated on the merits of that particular hospice. Payment to hospices selected to participate in the Model will be made directly to the hospice utilizing its provider number. CMS seeks to enroll geographically diverse hospices of differing sizes that serve demographically different populations.
The Request for Applications uses the term “traditional home”; does this include a group or boarding home?
Under the Medicare Care Choices Model, “home” is defined as a location or residence, other than a hospital or other facility, where the patient receives care in a residence. A beneficiary residing in a group home, defined as a residence, with shared living areas, where clients receive supervision and other services such as social and/or behavioral services, custodial service, and minimal services (e.g., medication administration), or a boarding home, defined as a home or facility (often a larger converted residence) where an individual rents a room and receives no supportive services would be eligible to participate. In order to be eligible for the Model, the qualifying beneficiary must have resided in a home, not an institutional setting for the purposes of receiving nursing or aide services, for a period of at least 30 days prior to their enrollment in the Model.