Healthcare Provider Solutions

Category: Hospice Regulation & Compliance

Increase in COVID-19 Vaccine Administration Payments (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: June 14, 2021

This minute covers the news release from CMS concerning: Medicare Billing for COVID-19 Vaccine Shot Administration. Effective June 8 of 2021, CMS has now approved that the COVID vaccination administration payment is going to be $75 per shot, which is almost double what they had increased it to earlier this year. The emphasis on getting as many people vaccinated as we possibly can is apparent. Make sure to stay tuned!

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Emergency Preparedness Update (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: May 24, 2021

Today’s video clip covers the Updated Guidance for Emergency Preparedness memo released in March of 2021. You need to thoroughly review all of the changes that have taken place in this update. Make sure to stay tuned!

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Emergency Preparedness UPDATE Blog

By Sharon Litwin, RN, MHA, HCS-D / Posted on: May 12, 2021

The Center for Clinical Standards and Quality/Quality, Safety & Oversight Group updated guidance for surveyors in QSO-21-15-ALL which revised emergency preparedness considering the Public Health Emergency (PHE). Emergency Preparedness (EP) takes a front seat with the Pandemic – CMS has revised the EP condition to add elements related to the Public Health Emergency (PHE) and the Pandemic.

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Hospice Proposed Rule Comments & Happy Nurse’s Month! (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: May 10, 2021

Welcome to Monday Minute with Melinda! This Minute highlights some very key components of the Hospice Proposed Rule that needs your feedback. Make sure to stay tuned!

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COVID Vaccine Administration Billing Update & Extension of the Public Health Emergency (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: April 26, 2021

Welcome to Monday Minute with Melinda! This session reviews the details of the Condition Code that must be used in billing vaccine administration for Medicare Advantage enrolled patients. Additionally, we touch on the extension of the PHE and corresponding CMS Waivers. Make sure to stay tuned!

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FY2022 Hospice Proposed Payment Rule

By Leslie Heagy, RN, COS-C / Posted on: April 21, 2021

In addition to the proposed changes for hospice providers CMS included proposed changes to the Home Health Quality Reporting program (HH QRP) to resume in the reporting for January 2022. The proposed rule for hospice and home health QRP is summarized in today’s blog.

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Sequestration, Reminder Regarding NPPs in Home Health & Update on Claims Processing (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: April 19, 2021

Welcome to Monday Minute with Melinda! Welcome to Monday Minute with Melinda! This session is loaded with updates regarding sequestration, claims processing and the use of NPPs in Home Health. Make sure to stay tuned!

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2022 Hospice Proposed Rule (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: April 12, 2021

Welcome to Monday Minute with Melinda! This video clip gives you some highlights of the just issued proposed rule and resources for obtaining details. Make sure to stay tuned!

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COVID-19 Coding Changes

By Sharon Litwin, RN, MHA, HCS-D / Posted on: April 8, 2021

It remains challenging to code COVID-19 for patients, as there are so many variations seen, especially as time goes on.   However, as of January 1, 2021, we have new diagnosis codes that are to be used for COVID-19 patients. They don’t include all of the patient scenarios for the conditions seen after COVID but it is a start.

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Value-Based Insurance Design (VBID) Model: Medicare Advantage – Hospice Carve-in

By Melinda A. Gaboury, CEO / Posted on: March 24, 2021

Medicare Advantage Value-Based Insurance Design (VBID) Model was developed for CMS to test a broad array of Medicare Advantage (MA) health plan innovations designed to reduce Medicare program expenditures, enhance the quality of care for Medicare beneficiaries, and improve the coordination and efficiency of health care service delivery. The goal is for the VBID Model to contribute to the modernization of MA and test whether these model components improve health outcomes and lower expenditures for MA enrollees.

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COVID-19 Vaccine Administration (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: March 22, 2021

Welcome to Monday Minute with Melinda! This week’s video clip will discuss the billing and reimbursement for COVID-19 Vaccine Administration. Make sure to stay tuned!

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Revisions to Infection Control and Practices during COVID-19 PHE

By Sharon Litwin, RN, MHA, HCS-D / Posted on: March 10, 2021

The Center for Clinical Standards and Quality/Quality, Safety & Oversight Group released a QSO-21-08-NLTC (Non Long Term Care) on December 30, 2020 to State Survey Agency Directors. This QSO revised the COVID-19 Focused Infection Control (FIC) Survey Tool for Acute and Continuing Care, of which home health and hospice are a part.

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Hospice ADRs on the Rise! (VIDEO)

By Melinda A. Gaboury, CEO / Posted on: March 8, 2021

Welcome to Monday Minute with Melinda! This week’s video clip will provide some key elements of responding to Hospice ADRs. Monday Minute with Melinda gives agencies the opportunity to receive critical weekly video updates, Make sure to stay tuned!

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Implementation of Home Infusion Therapy services

By Sharon Litwin, RN, MHA, HCS-D / Posted on: February 18, 2021

The Home Infusion Therapy (HIT) benefit went into effect January 1, 2021. HIT services are excluded from coverage under the Medicare Home Health Benefit. If an agency has a home infusion pharmacy that is an accredited home infusion therapy supplier as well, they can now bill this service portion through the Part B benefit.

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Implementation of Hospice Item Set (HIS) V3.00 & Hospice Quality Reporting Program (HQRP) Reporting Reminders

By Leslie Heagy, RN, COS-C / Posted on: January 20, 2021

The Hospice Quality Reporting Program (HQRP) webpage released an Important Update on 12/31/20 regarding the implementation of the Hospice Item Set (HIS) version V3.00 specifications. The Update stated that on January 1, 2021, CMS will move forward with the implementation of V3.00 of the HIS data submission specifications.

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2021 Hospice Final Payment Rule

By Leslie Heagy, RN, COS-C / Posted on: September 2, 2020

The Hospice FY2021 Final Wage Index and Payment Rate Update from CMS is summarized in this post with changes for Hospice providers. The new regulations will be effective on October 1, 2020. The overall economic impact of this final rule is estimated to be $540 million in increased payments to hospices for FY2021. HPS is working to keep Hospices informed of all the details related to the changes with the 2021 Final Rule.

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New Advanced Beneficiary Notice of Noncoverage (ABN) – Home Health and Hospice

By Leslie Heagy, RN, COS-C / Posted on: July 1, 2020

CMS announced the renewal of the Advanced Beneficiary Notice (ABN). The new ABN form is effective for use on or after August 31, 2020. Home Health and Hospice Providers need to ensure they are using the most current form. All Medicare Beneficiaries and Healthcare Providers have rights and are protected against financial liability through an Advanced Beneficiary Notice (ABN). Home Health providing care under Part A or Part B and Hospice providers under Part A are responsible for giving this notice to the beneficiary in situations where Medicare payment is expected to be denied.

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COVID-19: Interim Final Rule & What It Means for Home Health

By Melinda A. Gaboury, CEO / Posted on: May 14, 2020

There have been two Interim Final Rules, the most recent on May 1, that have been issued by CMS during this historic pandemic of the century. This Public Health Emergency (PHE) has taken the full focus of national officials and in the process, there have been sweeping concessions for healthcare, some permanent and others temporary.

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COVID-19: Emergency Financial Relief for Home Health & Hospice Providers

By Melinda A. Gaboury, CEO / Posted on: April 20, 2020

(UPDATED – 05/14/2020) The CMS Accelerated and Advance Payments Program program was suspended on April 26, 2020 and no further Accelerated Payments are happening at this time. During this Public Health Emergency (PHE) there are several avenues of obtaining cash to keep your agency going. This article addresses two of those. The Accelerated and Advance Payments Program allows agencies to get an advance on Medicare payments and it must be repaid. The other is the CARES Act Provider Relief Fund that is being automatically disbursed. Agencies will not need to repay these funds, however, there are accountability requirements for accepting and using these funds.

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COVID-19: Imperative Home Health and Hospice Updates

By Melinda A. Gaboury, CEO / Posted on: April 1, 2020

This article was last updated on May 7, 2020.

As we are facing the pandemic of the century, home health and hospices are on the frontline of this Public Health Emergency (PHE) along with hospitals, physicians and all other healthcare workers. We at Healthcare Provider Solutions, Inc. would like to take this moment to thank each and every one of you for your true dedication to treating patients and helping the world to be a healthier place. HPS is dedicated to providing the Home Health and Hospice industries with the education and resources necessary to keep you performing at the highest level of success.

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Hospice Targeted Probe and Educate – Avoid Claim Denials

By Leslie Heagy, RN, COS-C / Posted on: February 25, 2020

Targeted Probe and Educate (TPE) is continuing to be a problem for Hospice providers with some advancing to rounds 2 and 3 of the audit. This demonstration, which includes hospices receiving 20-40 claim requests for Additional Development Requests (ADR) in each round, have hospices wondering if they are going to be targeted next. In order to avoid advancing to the next round of TPE, the hospice’s calculated error percentage at the end of each round must be less than the percentage set by the MAC.

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Documenting Hospice Eligibility for a Cardiopulmonary Diagnosis

By Leslie Heagy, RN, COS-C / Posted on: February 4, 2020

When documenting hospice eligibility for a cardiopulmonary diagnosis you MUST go beyond the disease-specific LCD guidelines to avoid denial under medical review.  Many people who suffer from advanced cardiopulmonary disease share multiple symptoms as the disease progresses, however, the symptoms affect each patient differently and therefore, must be documented this way in order to support each patient’s terminal condition.

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FY2020 Hospice Final Rule: Changes to Hospice Reimbursement

By Leslie Heagy, RN, COS-C / Posted on: September 10, 2019

The rule rebases the continuous home care, general inpatient care and the inpatient respite care per diem payment rates in a budget-neutral manner to more accurately align Medicare payments with the cost of providing care. In addition, the rule modifies the election statement by requiring an addendum that includes information aimed at increasing coverage transparency for patients under a hospice election. Finally, this rule includes changes to the Hospice Quality Reporting Program.

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Targeted Probe & Educate (TPE): Top 5 Hospice Denial Reasons

By Melinda A. Gaboury, CEO / Posted on: May 30, 2019

As long as hospices are carefully documenting the details of each patient’s clinical situation and each patient meets the eligibility requirements for hospice care—these denials are avoidable. Don’t be the hospice that gets technical denials for careless mistakes, like incorrect format of the election statement or completing CTIs with boxed/canned statements that are not specific to the patient.

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8 Major Changes Outlined in the FY2020 Hospice Wage Index Update

By Leslie Heagy, RN, COS-C / Posted on: May 3, 2019

The FY2020 Hospice Wage Index & Payment Rate Update & HQRP Proposed Rule presents significant changes to rates and election statements. This proposed rule needs our full attention and comments! Please do your part and comment by the deadline stated in this article.

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Documenting Hospice Eligibility for Alzheimer’s Dementia

By Leslie Heagy, RN, COS-C / Posted on: March 22, 2019

When admitting a patient to hospice with a primary terminal diagnosis of Alzheimer’s disease, your documentation should clearly show the nature and condition causing the hospice admission in addition to, the hospice disease-specific LCD guidelines.

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Required Hospice GIP Documentation

By Leslie Heagy, RN, COS-C / Posted on: February 4, 2019

General Inpatient (GIP) Care is one of the four levels of care available to patients who elect the Medicare Hospice Benefit. When may GIP level of care be appropriate? When is it NOT appropriate to use GIP level of care?

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New Hospice Comprehensive Assessment Measure added to Hospice Compare

By Leslie Heagy, RN, COS-C / Posted on: January 18, 2019

The NEW Hospice Comprehensive Assessment Measure takes these 7 individual measures and combines them into a single metric. This measure is an “all-or-none” measure, which means that in order to receive credit, the hospice must successfully complete ALL 7 care processes for which the patient is eligible.

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Hospice Item Added to OIG Work Plan – Protecting Medicare Hospice Beneficiaries from Harm

By Leslie Heagy, RN, COS-C / Posted on: January 2, 2019

The OIG released a hospice portfolio report Vulnerabilities in the Medicare Hospice Program Affect Quality Care and Program Integrity in July of 2018, identifying vulnerabilities in the Medicare Hospice Program and made 16 recommendations to CMS to strengthen the hospice program.

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Hospice FY2019 Proposed Rule – Payment and Quality Reporting Program

By Katie Wehri / Posted on: May 4, 2018

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.

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Hospice MedPAC Report to Congress

By Katie Wehri / Posted on: April 4, 2018

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.

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Two Big Changes for Hospice

By Katie Wehri / Posted on: March 21, 2018

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…

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Targeted Probe and Educate – What We Have Learned So Far

By Melinda A. Gaboury, CEO / Posted on: March 13, 2018

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.

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CAHPS – Home Health & Hospice

By Melinda A. Gaboury, CEO / Posted on: March 2, 2018

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…

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Hospice Orientation and Training

By Katie Wehri / Posted on: February 19, 2018

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.

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When Must an Advance Beneficiary Notice Be Used in Hospice?

By Katie Wehri / Posted on: February 2, 2018

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…

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Top Ten Hospice Survey Deficiencies

By Katie Wehri / Posted on: January 22, 2018

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.

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Home Health & Hospice PEPPER Reports

By Melinda A. Gaboury, CEO / Posted on: January 15, 2018

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…

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New Medicare Beneficiary Identifiers

By Melinda A. Gaboury, CEO / Posted on: December 20, 2017

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…

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Hospice Physicians – Enroll in PECOS or State Medicaid Plans?

By Katie Wehri / Posted on: December 8, 2017

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…

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Opioid Disposal and Destruction – Considerations for Hospices

By Katie Wehri / Posted on: November 17, 2017

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…

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Preparing for Hospice Targeted Probe and Educate (TPE)

By Katie Wehri / Posted on: October 31, 2017

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.

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Hospice CTI and Election Statement Made Easy

By Katie Wehri / Posted on: October 16, 2017

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…

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New Medicare Cards – Questions Answered

By Melinda A. Gaboury, CEO / Posted on: October 10, 2017

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…

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Targeted Probe and Educate

By Melinda A. Gaboury, CEO / Posted on: September 25, 2017

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.

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GIP Level of care

Hospice General Inpatient Care

By Leslie Heagy, RN, COS-C / Posted on: September 18, 2017

CMS continues to be concerned about hospice over utilization and hospice underutilization of the general inpatient (GIP) level of care. Are hospices providing access to all four levels of hospice care (routine home care, general inpatient care, respite care and continuous home care)?

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Updates to the Hospice Aggregate Cap

By Katie Wehri / Posted on: September 1, 2017

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…

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Hospice Compare Site Now Live

By Katie Wehri / Posted on: August 18, 2017

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.

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2018 Hospice Final Rule & NOE Electronic Submission

By Katie Wehri / Posted on: August 4, 2017

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…

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Home Care & Hospice Emergency Preparedness

By Katie Wehri / Posted on: July 7, 2017

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…

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Changes Coming to Medicare HIC Numbers – Medicare Beneficiary Identifier

By Aaron Carey / Posted on: June 22, 2017

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…

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Hospice Quality Reporting Program Update – HIS and Hospice Compare

By Katie Wehri / Posted on: June 16, 2017

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…

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Attending versus Referring Physician in Hospice

By Katie Wehri / Posted on: June 1, 2017

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.

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Hospice Proposed Rule

By Leslie Heagy, RN, COS-C / Posted on: April 27, 2017

In addition to the proposed changes for hospice providers CMS included proposed changes to the Home Health Quality Reporting program (HH QRP) to resume in the reporting for January 2022. The proposed rule for hospice and home health QRP is summarized in today’s blog.

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HIPAA for Home Care | Establishing A Compliant Agency

By Drew Rowley / Posted on: March 3, 2017

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?

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NO OASIS Submission Equals NO Payment

By Aaron Carey / Posted on: November 15, 2016

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Hospice Regulatory Update

By Melinda A. Gaboury, CEO / Posted on: August 18, 2016

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Key Points Regarding 2016 Hospice Payment Reform

By Melinda A. Gaboury, CEO / Posted on: February 19, 2016

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Hospice CAHPS Surveys Will Affect Payment

By Melinda A. Gaboury, CEO / Posted on: January 29, 2016

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2016 HHRG Tables & Hospice CBSAs!

By Melinda A. Gaboury, CEO / Posted on: December 22, 2015

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2016 HHRG Tables & Hospice CBSAs!

By Melinda A. Gaboury, CEO / Posted on: December 22, 2015

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Ushering In 2016 – Kick off the Year Right!

By Melinda A. Gaboury, CEO / Posted on: December 11, 2015

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Initials and Not a Full Signature, Allowed?

By Melinda A. Gaboury, CEO / Posted on: October 9, 2015

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The Y2K of Coding!

By Melinda A. Gaboury, CEO / Posted on: October 5, 2015

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Finally Some Relief or Not!

By Melinda A. Gaboury, CEO / Posted on: September 29, 2015

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CMS Issues 2016 FINAL Hospice Payment and Quality Rule

By Melinda A. Gaboury, CEO / Posted on: August 7, 2015

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Hospice Medicaid Room and Board Billing Tips

By Aaron Carey / Posted on: June 7, 2015

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Hospice Update on Attending Physician

By Melinda A. Gaboury, CEO / Posted on: May 20, 2015

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CMS Issues FY2016 Proposed Hospice Payment and Quality Rule

By Melinda A. Gaboury, CEO / Posted on: May 6, 2015

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