Category: Regulation

CMS ODF- May 8th

The next Home Health, Hospice & DME Open Door Forum is scheduled for Wednesday, May 8, 2013 at 2:00 PM Eastern Time (ET).

Agenda:

Opening Remarks- Chair – Randy Throndset, Division Director, Division of Home Health, Hospice and HCPCS (CM)

Moderator – Matthew Brown (OC)

 Announcements & Updates:

  1. Health Insurance Marketplace Update
  2. HHCAHPS
  3. OASIS Modules
  4. Hospice Update
  5. Hospice Cost Report Update/PRA
  6. Claims Processing Update
  7. Re-Issued G-Code Reporting CR
  8.  Open Q&A

Open Door Participation Instructions:

This call will be Conference Call Only.

To participate by phone:

Dial: 1-800-837-1935 & Reference Conference ID: 78867258.

 Encore: 1-855-859-2056; Conference ID: 78867258.

Encore is an audio recording of this call that can be accessed by dialing 1-855-859-2056 and entering the Conference ID beginning 2 hours after the call has ended. The recording expires after 2 business days.

For ODF schedule updates and E-Mailing List registration, visit the ODF website

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PECOS Delay – Official Announcement

CMS has added  an MLN Matters article about the PECOS delay which was announced earlier this week.  It is titled:  SE1305 – Full Implementation of Edits on the Ordering/Referring Providers in Medicare Part B, DME, and Part A Home Health Agency (HHA) Claims (Change Requests 6417, 6421, 6696, and 6856).

NAHC  has posed the following questions to CMS:

  1. Must home health agencies issue a beneficiary notice to patients whose services will be terminated because of failure of their physician to be enrolled in PECOS and, if so, what notice?
  2. May home health agencies hold beneficiaries liable for the cost of care?
  3. Do apostrophes appear in PECOS files and in the edit files that will be used by the MACs (conflicting guidance from CMS to providers about use of apostrophes)
  4. Will claims be edited against the original Phase 2 May 1, 2013 “from” date or will this date be amended?
  5. Would CMS please add the effective date of physician enrollment to the Ordering/Referring File?

The Alliance appreciates NAHC pushing for these answers and will share information as we get it.

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CMS Issues Fact Sheet-Jimmo Lawsuit

CMS has recently issued a Fact Sheet on the Jimmo v. Sebelius Settlement Agreement. The settlement agreement puts an end to the Medicare contractors inappropriately applying an “Improvement Standard” in making claims determinations for Medicare coverage involving skilled care. ”It is intended to clarify that when skilled services are required in order to provide care that is reasonable and necessary to prevent or slow further deterioration, coverage cannot be denied based on the absence of potential for improvement or restoration”.  

Forthcoming Activities:

1)     Clarifying Policy-Updating Program Manuals:  This is the first action CMS will undertake as specified in the settlement agreement, revising the relevant program manuals used by Medicare Contractors

2)     Educational Campaign-Informing Stakeholders:  CMS will conduct national conference calls with providers and suppliers, as well as, Medicare contractors, Administrative Law Judges, medical reviewers, and agency staff, to communicate the policy clarifications and answer questions. CMS will also begin an educational campaign for contractors, adjudicators, and providers and suppliers utilizing a variety of written materials, including:

• Program Transmittal;

• Medicare Learning Network (MLN) Matters article;

• Updated 1-800 MEDICARE scripts.

3)     Claims Review:  CMS will engage in accountability measures, including review of a random sample of home health coverage decisions to determine overall trends and identify any problems, as well as, a review of individual claims determinations that may not have been made in accordance with the principles set forth in the agreement.

According to the terms of the settlement agreement, CMS will complete the manual revisions and educational campaign by January 23, 2014, which is within one year of the approval date of the settlement agreement.

 

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CMS Rescinds Reporting Modifier for Home Health Claims

Good news for Home Health Agencies…

CMS will no longer require home health agencies to apply a modifier to changes/additions to the plan of care by a physician other than the certifying physician for episodes starting on or after July 1. That’s the result of an April 3rd transmittal published on the CMS website. CMS states, “Transmittal 2650, dated February 1, 2013, is being rescinded and replaced with Transmittal 2680, to remove… instructions regarding reporting a new modifier.”

HHA are still required, effective July1, to report on claims the location where services were provided using one of three Q-codes.

  • Q5001: Home health care provided in patient’s home/residence
  • Q5002: Home health care provided in assisted living facility
  • Q5009: Home health care provided in place not otherwise specified

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New HIPAA Rules Issued: Disclosures and Revised Notices of Privacy Practices

The following information was submitted by Elizabeth Hogue, Esq:

The U.S. Department of Health and Human Services (HHS) has issued final rules to:

  • Modify the Health Insurance Portability and Accountability Act (HIPAA) Privacy, Security and Enforcement Rules to implement statutory amendments under the Health Information Technology Economic and Clinical Health Act (HITECH Act) to strengthen the privacy and security protection for individuals’ health information;
  • Modify the rule for Breach Notification for Unsecured Protected Health Information (Breach Notification Rule) under the HITECH Act to address public comments received on the interim final rule;
  • Modify the HIPAA Privacy Rule to strengthen the privacy protections for genetic information by implementing section 105 of Title 1 of the Genetic Information Nondiscrimination Act of 2008 (GINA); and
  • Make other modifications to the HIPAA Privacy, Security, Breach Notification and Enforcement Rules to improve their workability and effectiveness, and to increase flexibility and decrease burden on regulated entities.

The final rules were published in the Federal Register on January 25,2013, and will be effective on March 26, 2013.  Covered entities and business associates must comply with the final rules by September 23, 2013.  This is the third in a series of articles that will address key provisions of the rules, their impact on post-acute providers, and practical solutions for compliance. Continue reading “New HIPAA Rules Issued: Disclosures and Revised Notices of Privacy Practices”

Hospice Reporting Reminder- Deadline April 1st

The following is a noticed released by CMS last week reminding Hospice Providers of the April 1st deadline for submission of the hospice pain measures (NQF #0209). 

Hospice Quality Reporting Program: NQF #0209 Deadline April 1

Important Alert: The deadline to submit the NQF #0209 data is quickly approaching. Hospices that fail to submit and attest to their data will receive a 2 percentage point reduction in their Annual Payment Update (APU) for the FY 2014.

To comply with the Payment Year 2014 Hospice Quality Reporting Program (HQRP) requirements, providers should currently be entering their NQF #0209 data on the data entry and submission website. Providers that have not already created a data entry account should do so now.

The deadline for reporting NQF #0209 data for Payment Year 2014 is April 1, 2013. In order to avoid a 2 percentage point reduction in their Annual Payment Update (APU), providers must have submitted their structural measure data by January 31, 2013 and must submit their NQF #0209 data by April 1. Providers that may have missed the structural measure deadline can still visit the data entry website, create an account, and enter their NQF #0209 data. The link to the data entry site, along with a Technical User Guide giving step-by-step instructions on the data entry process, can be found on the Data Submission portion of the CMS HQRP website.

User Account Deactivation Requests for the HQRP

If you anticipate needing a deactivation request for your HQRP user account, please submit the user account deactivation request to the Technical Help Desk via fax at 888-477-7871 or email at help@QTSO.com prior to March 25, 2013. Any deactivation requests received on or after March 25 puts a hospice organization at risk for missing the NQF #0209 deadline, which is April 1. Please note: all data submitted by a user who is deactivated is permanently deleted.

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National Provider Call: Activation of PECOS Edit May 1

Register for the National Provider Call on Wednesday, March 20; 3-4pm

CMS will hold a national provider call on March 20 from 3-4pm ET on the “Implementation of Phase 2 Edits on the Ordering/Referring Providers in Medicare Part B and Part A -Home Health Agency Claims.”

Effective May 1, 2013, CMS will instruct contractors to turn on Phase 2 denial edits; checking Medicare claims for home health services ordered by physicians who are not enrolled in the Medicare Provider Enrollment, Chain, and Ownership System (PECOS). If physicians are not enrolled these claims will be denied.

In order to receive call-in information, you must register  on the CMS website CMS Upcoming National Provider Calls. During the registration process, advanced questions may be posted

National Provider Call Agenda:

  • Provider Types Eligible to Order/Refer
  • Action Steps for Billing Providers
  • Action Steps for  Providers Who Order/Refer
  • Resources

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Are You Prepared for the May1st PECOS Edit?

Effective May 1st, CMS will deny home health claims where the physician on the claim does not have an enrollment record in the Provider Enrollment, Chain and Ownership System (PECOS).

CMS released MLN Matters-SE1305, on March 1st, detailing information regarding this new “phase 2” edit.  Phase 2 is part of CMS’s implementation of Section 6450 of the Affordable Care Act, which requires physicians or other eligible professionals to be enrolled in the Medicare Program to order or refer items or services for Medicare beneficiaries, even if those physicians do not directly bill Medicare for any services.

Home Health claims will be denied with one of two reason codes, according to the March 1st MLN Matters article:

  • 37236: The statement “from” date is on or after May 1, the type of bill is “32” or “33” and the attending physician’s national provider identifier (NPI) is not present in PECOS. The claim could also be denied if the NPI is present in PECOS but the name given on the claim doesn’t match the one on the physician’s enrollment record.
  • 37237: Same as above, but this denial reason code will be assigned only when the type of bill frequency code is “7,” which indicates an adjustment, or “F-P.”

Check your referring physicians’ status in PECOS; agencies may be forced to hold billing the claim for physicians who are not enrolled.

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ICD-10: Take Readiness Survey

CMS and the Workgroup on Electronic Data Interchange (WEDI) are conducting a survey on healthcare industry readiness for ICD-10. The purpose of the survey is to closely track industry progress in order to identify areas where additional focus may be needed. The survey is open through Wednesday, February 20, 2013 and available to any individual associated with health care organizations

The online survey, located at https://www.surveymonkey.com/s/WEDISurveyICD-10, will be used by WEDI and the Centers for Medicare & Medicaid Services to evaluate challenges and identify areas in need of additional education and assistance. This is a great opportunity to provide input about your readiness for the ICD-10 transition in 2014.

WEDI’s Survey on Industry Progress Now Open

The Workgroup for Electronic Data Interchange (WEDI) is conducting its latest online ICD-10 Industry Progress Survey. The survey will help CMS and WEDI:

  • Measure the health care industry’s ICD-10 progress
  • Evaluate challenges and identify areas where industry needs more education and assistance

The survey is open to all individuals associated with health care organizations, including vendors, health plans, providers, and payers.

Before taking the online survey, please scroll to the link at the end of the WEDI survey press release to preview the questions. The press release also includes a link to the online survey form.

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Invitation to Comment on QIO Changes

CMS’s Center for Clinical Standards and Quality (CCSQ) is inviting providers to offer input on plans for redesigning the Quality Improvement Organization (QIO) Program. By law, the mission of the QIO Program is to improve the effectiveness, efficiency, economy, and quality of services delivered to Medicare beneficiaries. QIOs convene providers, practitioners, and patients to build and share knowledge, spread best practices, and achieve wide-scale improvements in patient care, increases in population health, and decreases in health care costs.

CMS has just released the slides from the January 24th Special Open Door Forum, Future Development of the QIO: Getting Your Feedback.  This invitation to provide comments on the future development of the QIO is an excellent opportunity for home health agencies to request the support and resources they deserve in the QIO program. Home health has been left out of the last two Scope of Work (SOW) plans, which focused on hospital and skilled nursing facilities. The 8th SOW was the last time the QIO focused on home health.

Home health agencies should write to CMS and advise them of ways that QIOs can provide home care with guidance and tools to effectively care for the millions of Medicare beneficiaries they serve, help them learn to comply with their treatment regimens, trouble shoot  potential complications, and avoid costly emergent care and institutional services, as well as expand their involvement in preventative services,

Please share your comments and ideas on the role Quality Improvement Organizations can play in home health.  Submit your comments to OCSQBox@cms.hhs.gov by Friday, February 8th at 5:00 p.m. ET

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