MedPAC Recommends 3% to 5% Cut for Hospice SNF Residents

On April 4, 2013 Kim Neuman and Sara Sadownik MedPAC staff members spoke at a meeting in the Ronald Reagan Building concerning Medicare Hospice Policy Issues.   They reviewed MedPAC’s recommendations for hospice payment reform.  One of the recommendations was a 3% to 5% cut for Hospice patients who reside in Skilled Nursing Facilities.  They also discussed other issues such as the U-Shaped payment method which would pay hospice’s a higher rate at the beginning of care, lower rates during the middle of care, and a higher rate on the last seven days of the patients life. 

For more information please utilize the following link.

http://www.medpac.gov/transcripts/hospice_April_2013_presentation.pdf

CMS Issues Fact Sheet for Implementation Improvement Standard

On January 24, 2013 the U.S. District Court for the District of Vermont approved a settlement agreement in the case of Jimmo V. Sebelius.  The case involved skilled care being denied by contractors based on a rule-of thumb “Improvement Standard” – under which a claim would be summarily denied due to a beneficiary’s lack of restoration potential, even though the beneficiary did in fact require a covered level of skilled care in order to prevent or slow further deterioration in his or her clinical condition.

CMS agreed to the settlement agreement.  The language in the settlement agreement did not modify or expand existing eligibility requirements for receiving Medicare coverage. 

On April 4, 2013 CMS issued a fact sheet that describes their plans to conduct the following activities under the term of the settlement agreement.

1.     Clarifying Policy & Updating Program Manuals

2.     Develop an Education Campaign to inform stakeholders

3.     Preform a claims review to ensure beneficiaries are receiving care

CMS agrees to complete the manual revisions and educational campaign by January 23, 2014.

For more information please utilize the following link.

http://www.cms.gov/medicare/medicare-fee-for-service-payment/SNFPPS/downloads/jimmo-factsheet.pdf

CMS Rescinds Modifier on Medicare Claims

On April 2, 2013 CMS published Transmittal 2680 to remove the modifier to visits not ordered by the certifying physician for episodes starting July 1, 2013. 

The requirement to report where home health agencies and hospices services are provided remains the same.  Beginning on or after July 1, 2013, HHAs must report where home health services were provided.  The following codes are used for this reporting are listed below:

Q5001: Hospice or Home Health Care provided in patient’s home / residence

Q5002: Hospice or Home Health Care Provided in Assisted Living Facility

Q5009: Hospice or Home Health Care provided in a place not otherwise specified (NO)

If the location where services were provided changes during the episode, the new location should be reported with an additional line corresponding to the first visit provided in the new location.

For more information please utilize the following link.

http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R2680CP.pdf

From the desk of: Theresa M. Forster Vice President for Hospice Policy & Programs National Association for Home Care & Hospice

From the desk of:
Theresa M. Forster
Vice President for Hospice Policy & Programs
National Association for Home Care & Hospice
Washington, D.C.
202-547-7424
tmf@nahc.org

Hi, everyone. This morning representatives from CMS, FISS, and the MACs met to discuss this issue and they decided to turn off the edit that caused hospice claims to be returned to provider (RTPed) with Reason Code 32061. CGS just sent the following notice to its listserv and we would expect that other MACs will soon be alerting their constituencies. Our contacts at CMS have indicated that this should result in the needed relief from this claims processing issue. Many thanks to those of you who wrote with your concerns. Take care, Theresa

_______
Home Health and Hospice News from CGS

Update to Reason Code 32061 System Issue — On April 2, 2013, CGS notified providers through a listserv message that a system problem had been identified which impacted hospice claims (types of bill 81X and 82X). CGS has also determined this is affecting type of bill 34X. These claims were being returned to the provider (RTPd) inappropriately with reason code 32061. The Centers for Medicare & Medicaid Services (CMS) has informed CGS that this edit will be turned off, and contractors can release these claims to continue processing. Providers with claims in status/location T B9997 with reason code 32061 do not need to take any action. CGS is in the process of releasing these claims, and anticipates all claims to be released within the week.

CMS Issues Claim Hold For Home Health Final Claims

The Centers for Medicare & Medicaid Services (CMS) has identified technical issues with certain parts of the April 2013 quarterly system release.  This is effective for claims with dates of service or “Through Dates” on or after April 1, 2013.  This applies to all home health final claims.  CMS has instructed the Medicare Administrative Contractors (MACs) to hold the claims until April 14, 2013, when system fixes are expected to be implemented.  The claims will be released into processing on April 15, 2013

For more information please utilize the following link.

http://www.cgsmedicare.com/articles/COPE21835.html

Comparative Billing Report on Home Health Services

The Comparative Billing Report is provided as a collaborative effort between the Medicare provider community and the Centers for Medicare & Medicaid Services to support best billing practices and effective management of Medicare Program Resources.  The report has several pitfalls.  The first is the report is not wage index adjusted; therefore home health agencies with higher wage indexes can be inappropriately targeted.  The second is the report is not risk based adjusted for patient ages, comorbidities, agency size or referral sources.

The report is based on paid claims with service dates from 1/1/2011 to 12/31/2011.  The report compares the home health agency averages to the state and the national averages for following items:

1.     The average number of home health visits per beneficiary

2.     The average number of PT visits per beneficiary

3.     The average number of OT visits per beneficiary

4.     The average number of SP visits per beneficiary

5.     The average Medicare payments per beneficiary

According to several national home health associations only about half of the home health agencies actually received the reports.   We would encourage every home health agency that has received a report to carefully review the data to determine their standings compared to their state and national averages.  We can be certain that reviewers and surveyors will utilize this data.

For more information please utilize the following link.

http://www.safeguard-servicesllc.com/cbr/documents/CBR022%20Home%20Health%20Services%20Sample.pdf

Med Pac Report Recommends 0% Rate Increase for Hospice in 2014

The report recommends that Congress should eliminate the update to the hospice payment rates for fiscal year 2014.  They continued a previous year recommendation to increase the per day payment rate at the beginning of the hospice episode and relatively lower payment per day as the length of the episode increases.  To include a relatively higher payment for the costs associated with patient death at the end of the episode. 

For more information please utilize the following link.

http://www.medpac.gov/documents/Mar13_EntireReport.pdf