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Category: Hospice Regulation & Compliance

Hospice FY2019 Proposed Rule – Payment and Quality Reporting Program

By Katie Wehri / Posted on: May 4, 2018 13–15 minutes to read

The FY 2019 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements proposed rule was recently made available. Of concern is the fact that CMS found 66% of hospice cost reports would have been rejected had certain edits been in place. Check back soon for future blog articles containing more detailed information about the quality reporting program updates and comments in the proposed rule.

Hospice MedPAC Report to Congress

By Katie Wehri / Posted on: April 4, 2018 5 minutes to read

Each year the Medicare Payment Advisory Commission (MedPAC) submits its annual report to Congress which contains information and recommendations related to Medicare fee-for-service (FFS) programs. This article details the 2018 annual report recommendations for Hospice.

Two Big Changes for Hospice

By Katie Wehri / Posted on: March 21, 2018 6 minutes to read

Recently, through the Bipartisan Budget Act of 2018 (Budget Act), Congress made changes directly impacting hospices. Hospices should review the changes and consider how the change will impact them and prepare accordingly. The first change…

Targeted Probe and Educate – What We Have Learned So Far

By Melinda Gaboury / Posted on: March 13, 2018 7 minutes to read

Targeted Probe & Educate began on 10/1/17 and is full speed ahead. HPS has discovered nuances with TPE that we did not expect nor have we experienced in past ADR reviews. This review includes targeted medical review and education along with the potential of elevated action toward the agency. This elevated action could take place if the agency is not meeting the standards laid out by the Medicare MAC.

CAHPS – Home Health & Hospice

By Melinda Gaboury / Posted on: March 2, 2018 5 minutes to read

Are you monitoring the agency’s CAHPS results? There are numerous questions on the survey that the patients must complete, but only selected ones go into the outcome measure calculations. Home Health CAHPS results have been reported on the Home Health Compare website for quite some time, while the results for the CAHPS Hospice Survey just began being public reported on Hospice Compare 02/22/18. One of the lowest scoring…

Hospice Orientation and Training

By Katie Wehri / Posted on: February 19, 2018 12–15 minutes to read

There are more than 4,000 hospices in the United States. They serve approximately 1.5 million people, and their families. All staff members need to be trained, oriented to hospice and their role in delivering care. This article dives deep into the topic of Hospice orientation and training. We also provide the information necessary to succeed with the implementation of your program.

When Must an Advance Beneficiary Notice Be Used in Hospice?

By Katie Wehri / Posted on: February 2, 2018 7 minutes to read

All Medicare and Medicare Advantage beneficiaries and providers have rights and are protected against financial liability through an Advance Beneficiary Notice (ABN). The provider is responsible for giving this notice to the beneficiary in certain instances. The ABN used by hospice providers is…

Top Ten Hospice Survey Deficiencies

By Katie Wehri / Posted on: January 22, 2018 4 minutes to read

The top ten hospice Medicare certification/recertification survey deficiencies have remained fairly consistent for the past several years. This article contains the top ten list for 2017. For calendar year 2017, nine of the top ten deficiencies were the same as in calendar year 2016 – with L531 coming on the list at number ten and L591.

Home Health & Hospice PEPPER Reports

By Melinda Gaboury / Posted on: January 15, 2018 7 minutes to read

Over the past couple of years, HPS has reported and discussed that Home Health and Hospice PEPPER Reports are very important and should be reviewed by all agencies. We have also been open about the number of agencies in the country that have never opened the reports. HPS is happy to report that, for the 8 months ending December 20, 2017, 58.5% of all hospices have opened their reports. Only 5 states and 1 territory are below 50%. The sad news is that home care…

New Medicare Beneficiary Identifiers

By Melinda Gaboury / Posted on: December 20, 2017 4 minutes to read

HPS has given you a couple of updates on the new Medicare Beneficiary Identifier (MBI) cards over the past few months and we continue that update today. Following are more questions answered about the new Medicare numbers and how that will affect your agency. Key dates to remember: April 1, 2018 – Patients will begin to receive new Medicare cards and agencies should begin the process of asking…

Hospice Physicians – Enroll in PECOS or State Medicaid Plans?

By Katie Wehri / Posted on: December 8, 2017 4 minutes to read

The answer is – it depends. There is no Medicare requirement specific to hospices needing to ensure hospice medical directors/physicians or hospice patients’ attending physicians need to be enrolled in PECOS. This does not mean that hospice physicians should not be enrolled, however. Provisions of the Affordable Care Act require all providers of medical or other items or services and suppliers that qualify for a National Provider Identifier (NPI) to include their NPI on all applications to enroll in the Medicare and Medicaid programs and…

Opioid Disposal and Destruction – Considerations for Hospices

By Katie Wehri / Posted on: November 17, 2017 12–14 minutes to read

With the expanding focus on opioid misuse in this country, hospice has gotten some extra attention regarding its responsibilities in this epidemic. Most all hospices were disposing of unused/unwanted medications of hospice patients who were in their home up until late 2014 when the Disposal of Controlled Substances Act (Disposal Act) was finalized and implemented by the Drug Enforcement Administration (DEA). Prior to this time, there was not…

Preparing for Hospice Targeted Probe and Educate (TPE)

By Katie Wehri / Posted on: October 31, 2017 9 minutes to read

As previously reported, the targeted probe and educate (TPE) process is replacing the medical review process used by Medicare Administrative Contractors (MAC). Each of the three MACs – Palmetto GBA, NGS and CGS – can choose the topics for review under TPE based on existing data analysis procedures.

Hospice CTI and Election Statement Made Easy

By Katie Wehri / Posted on: October 16, 2017 8 minutes to read

CMS reminded hospices recently about the need to comply with Medicare hospice election statements and certification of terminal illness (CTI) requirements. This reminder comes shortly after CMS’ announcement of the expansion of the targeted probe and educate (TPE) method of medical review to hospices and other provider types. We believe there is a strong possibility that CMS will…

New Medicare Cards – Questions Answered

By Melinda Gaboury / Posted on: October 10, 2017 6 minutes to read

HPS reported on the coming changes to the Medicare cards a few months ago. Today we offer more answers as have been gathered from CMS via the Medicare Learning Network page of the CMS site. The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, requires the removal…

Targeted Probe and Educate

By Melinda Gaboury / Posted on: September 25, 2017 5 minutes to read

HPS reported recently regarding continued Probe & Educate for Home Health agencies. This is to clarify that the CMS expansion on Probe & Educate is for Home Health and Hospice and will be effective 10/1/2017. This is referred to as Targeted Probe & Educate (TPE). This review will include targeted medical review and education along with an option for potential elevated action, up to and including referral to other Medicare contractors including the Zone Program Integrity Contractor (ZPIC), Unified Program Integrity Contractor (UPIC), Recovery Audit Contractor (RAC), etc.

Hospice General Inpatient Care

By Katie Wehri / Posted on: September 18, 2017 10 minutes to read

CMS is concerned about hospice over utilization and hospice underutilization of the general inpatient (GIP) level of care. CMS wonders if hospices are providing access to all four levels of hospice care (routine home care, general inpatient care, respite care and continuous home care) when it sees that some hospices have billed very little or no GIP care during a specified time period. On the other hand, CMS wonders if the…

Updates to the Hospice Aggregate Cap

By Katie Wehri / Posted on: September 1, 2017 5 minutes to read

The inpatient cap limits the number of days of inpatient care for which a hospice can bill Medicare to no more than 20% of total Medicare days billed, and the aggregate cap limits the total dollar amount of payments from Medicare that can be received. The aggregate cap was originally intended to ensure that hospice payments would not exceed Medicare expenditures in a conventional setting. The aggregate cap amount is…

Hospice Compare Site Now Live

By Katie Wehri / Posted on: August 18, 2017 4 minutes to read

On August 16, 2017 the long-awaited Hospice Compare site went live. The Compare site is part of the Hospice Quality Reporting Program (HQRP) mandated by the Affordable Care Act (ACA). CMS uses Compare sites as part of the quality programs for various provider types. All are similar in that they offer a snapshot of the quality of care provided to patients that is available to the public.

2018 Hospice Final Rule & NOE Electronic Submission

By Katie Wehri / Posted on: August 4, 2017 14–17 minutes to read

Late Tuesday, August 1, 2017 the final hospice rule – FY 2018 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements – was posted. The rule contains the FY2018 finalized payment rates, aggregate cap, and hospice quality reporting changes. On July 27, 2017 CMS released Transmittal 3813/Change Request (CR) 10064 – Accepting Hospice Notices of Election via Electronic Data Interchange. Hospices will be happy to hear…

Home Care & Hospice Emergency Preparedness

By Katie Wehri / Posted on: July 7, 2017 12–14 minutes to read

We will continue to update this article to keep you informed on the latest concerning Home Care & Hospice Emergency Preparedness. UPDATE – July 7, 2017 – Since the release of this article, the interpretive guidelines for emergency preparedness have been released. HPS has created a detailed table for Home Health and Hospice providers to assist our Alliance members in managing the EP information…

Changes Coming to Medicare HIC Numbers – Medicare Beneficiary Identifier

By Aaron Carey / Posted on: June 22, 2017 5 minutes to read

Former President Harry S. Truman was the very first Medicare beneficiary to be issued a Health Insurance Claim Number (HICN) when then President Lyndon B Johnson signed the Medicare program into law on July 30, 1965. Ever since then, Medicare beneficiaries upon entitlement, have been issued a Health Insurance Claim Number (HICN). The primary issuer of the HICN is the social security administration with the railroad retirement Board issuing HIC numbers for railroad workers. Beginning in 2018 the Medicare HIC number will be replaced with a new identifier called a Medicare Beneficiary Identifier (MBI). The MBI numbers will be…

Hospice Quality Reporting Program Update – HIS and Hospice Compare

By Katie Wehri / Posted on: June 16, 2017 9 minutes to read

CMS recently released clarification of the response options for HIS item A1400, Payor Information. Many hospices have been asking how to complete this item with questions about the Self Pay option, in particular. In addition to the information in the HIS Manual, CMS provides the following additional information specific to the…

Attending versus Referring Physician in Hospice

By Katie Wehri / Posted on: June 1, 2017 9 minutes to read

A physician refers a patient to hospice care – what role does this physician play in the care of the patient and in certifying the patient? It depends. Let’s look at the various hospice requirements that involve a physician.

Hospice Proposed Rule

By Katie Wehri / Posted on: April 27, 2017 31–37 minutes to read

Late Thursday, April 27 the proposed hospice rule – FY 2018 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Requirements – was posted. The rule contains the proposed FY2018 payment rates, aggregate cap, and hospice quality reporting changes. The proposal is also an opportunity for CMS to provide comments on various other issues and solicit feedback. The proposed rule is open for inspection and CMS is accepting comments from hospices, stakeholders, and the public until June 26. CMS will review the comments and the final rule is anticipated to be released at the end of July. This detailed post will be continually updated with the latest information from CMS regarding the 2018 proposed hospice rule…

HIPAA for Home Care | Establishing A Compliant Agency

By Drew Rowley / Posted on: March 3, 2017 5 minutes to read

HIPAA has become an acronym synonymous with healthcare. We see it practiced and preached daily throughout the home care and hospice industry. However, too often breach notifications are at the top of our industry headlines. These breaches are costing our agencies time, money, and patient credibility. If we as agency owners, administrators, and employees understand the severity of a breach then why are breaches still occurring?

NO OASIS Submission Equals NO Payment

By Aaron Carey / Posted on: November 15, 2016 5 minutes to read

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Hospice Regulatory Update

By Melinda Gaboury / Posted on: August 18, 2016 8 minutes to read

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Hospice PEPPER

By Liz Landreth / Posted on: June 14, 2016 4 minutes to read

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Key Points Regarding 2016 Hospice Payment Reform

By Melinda Gaboury / Posted on: February 19, 2016 4 minutes to read

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Hospice CAHPS Surveys Will Affect Payment

By Melinda Gaboury / Posted on: January 29, 2016 2 minutes to read

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2016 HHRG Tables & Hospice CBSAs!

By Melinda Gaboury / Posted on: December 22, 2015 2 minutes to read

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2016 HHRG Tables & Hospice CBSAs!

By Melinda Gaboury / Posted on: December 22, 2015 2 minutes to read

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Ushering In 2016 – Kick off the Year Right!

By Melinda Gaboury / Posted on: December 11, 2015 5 minutes to read

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Initials and Not a Full Signature, Allowed?

By Melinda Gaboury / Posted on: October 9, 2015 3 minutes to read

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The Y2K of Coding!

By Melinda Gaboury / Posted on: October 5, 2015 5 minutes to read

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Finally Some Relief or Not!

By Melinda Gaboury / Posted on: September 29, 2015 4 minutes to read

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CMS Issues 2016 FINAL Hospice Payment and Quality Rule

By Melinda Gaboury / Posted on: August 7, 2015 6 minutes to read

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Hospice Medicaid Room and Board Billing Tips

By Aaron Carey / Posted on: June 7, 2015 5 minutes to read

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Hospice Update on Attending Physician

By Melinda Gaboury / Posted on: May 20, 2015 8 minutes to read

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CMS Issues FY2016 Proposed Hospice Payment and Quality Rule

By Melinda Gaboury / Posted on: May 6, 2015 6 minutes to read

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