CMS May 8 Open Door Forum: Important Updates
Tuesday, May 14, 2013
by: VNAA Policy Team

Section: Public Policy and Advocacy

On May 8, the Centers for Medicare and Medicaid Services (CMS) held a Home Health and Hospice Open Door Forum, during which the following issues in hospice and home health care were discussed:

Hospice Updates

Hospice Proposed Rule:
The proposed payment rule was published in the Federal Register on May 10 and the 60 day comment period closes June 28. (Please see VNAA's summary and sign up for May 23 call in next related article.)

Provisions in the proposed rule include:

  • Inclusion of Multiple Diagnoses on Hospice Claims:Clarifies that existing policy requires hospices to provide multiple diagnoses on claims, and spells out use of certain diagnosis codes in hospice.
  • Hospice Quality Reporting Program: Proposes changes to HQRP and signals intent to require an experience of care survey. The rule also proposes elimination of NQF 0209 pain measure and collection of data through a Hospice Information Set (HIS). Elements included in the HIS are now posted online here. Questions about hospice quality reporting requirements may be emailed to:
  • Payment: Proposes that payment rate changes be published through an annual notice or rule rather than through an administrative instruction. Wage index files for FY2014 are available online here.
  • Technical Report on Payment Changes: Announces availability of a technical report and literature review related to work on hospice payment reform. The payment reform technical report and literature review are available here.
Hospice Cost Report:
  • CMS has developed a revised hospice cost report that has been published online in order that comments can be made on the increased paperwork burden. Comments are due by June 28. Hereis a link to the location of the cost report materials. 
Hospice Quality Reporting Program (HQRP), Training, Deadlines, 2% Penalty:
  • Training on Hospice Quality Reporting Program will be available this summer.
  • Deadlines for submission of fourth quarter of 2012 quality measures (structural measure and NQF 0209 pain measure) have passed. Providers may be subject to a 2 percent reduction in their FY2014 market basket if they failed to meet January 31deadline for QAPI or April 1, 2013 deadline for NQF 0209.

    April 1, 2014 will be the single deadline for reporting of both the Structural and Pain Measures collected during 2013. Failure to report CY2013 data by the deadline will result in a 2 percent reduction in market basket in FY2015.  Hospices will no longer be required to submit the checklist of the structural measures they use as part of their QAPI programs effective with the April 1, 2014 reporting. Hospices will only be required to answer the questions related to their QAPI measures.
Home Health Updates

Consumer Assessment of Healthcare Providers and Systems (HHCAHPS):
  • Data that is posted on the Home Health Compare Website includes data through September 2012. Agencies should check to see if data is being submitted by their vendors on a regular basis. If data for a month is missed, notify the vendor and document in HHCAHPS discrepancy notification report as filed by vendor so CMS is aware of reason month(s) was missed.
  • An exemption from participating in the HHCAHPS Survey for the calendar year 2015 HHCHAPS is available for Medicare-certified home health agencies (HHAs) that served 59 or fewer unduplicated patients from April 1, 2012 through March 31, 2013. Exemption form must be complete by January 16, 2014 for 2015.
Outcome and Assessment Information Set (OASIS):
  • CMS OASIS web based training has been updated with several new OASIS training modules. The modules can be accessed here. Click on “I am a Provider” link then click “Web based training” then click “Outcome and Information”.
  • The new modules cover the OASIS Overview and Conventions, ADL and IADL parts One and Two, Care Management Therapy Needs, and Emergent Care domains. A History and Diagnosis Module is under development.
  • The OASIS-C instrument, with a December 31, 2014 expiration date, is available on the CMS Website here. There are no changes to the data set other than the expiration.
Claims Processing Update:
  • A new Master Consolidated billing list has been posted to the CMS Website here.
  • The quarterly update to the list of HCPCS codes for consolidated billing is available hereand includes two new therapy codes for negative pressure wound therapy (G0456 and G0457). The codes are therapy codes and have no effect on the supply list.
  • Change Request 8136- which requires home health agencies (HHAs) report new Q codes to indicate the location where services were provided - was reissued on April 2 to add clarifying language for the use of the new Q codes and to remove the requirement for agencies to add a modifier to report orders received from additional physicians.
  • CMS will post Change Request 8244 that will provide instructions to discontinue the use of type of bill (TOB) 33x for home health claims, effective October 1, 2013.
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