Category: Hospice Regulation & Compliance
Documenting Hospice Eligibility for a Cardiopulmonary Diagnosis
By Leslie Heagy, RN, COS-C / Posted on: February 4, 2020When 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.
VIEW POSTFY2020 Hospice Final Rule: Changes to Hospice Reimbursement
By Leslie Heagy, RN, COS-C / Posted on: September 10, 2019The 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, 2019As 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.
VIEW POST8 Major Changes Outlined in the FY2020 Hospice Wage Index Update
By Leslie Heagy, RN, COS-C / Posted on: May 3, 2019The 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.
VIEW POSTDocumenting Hospice Eligibility for Alzheimer’s Dementia
By Leslie Heagy, RN, COS-C / Posted on: March 22, 2019When 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.
VIEW POSTRequired Hospice GIP Documentation
By Leslie Heagy, RN, COS-C / Posted on: February 4, 2019General 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?
VIEW POSTNew Hospice Comprehensive Assessment Measure added to Hospice Compare
By Leslie Heagy, RN, COS-C / Posted on: January 18, 2019The 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.
VIEW POSTHospice Item Added to OIG Work Plan – Protecting Medicare Hospice Beneficiaries from Harm
By Leslie Heagy, RN, COS-C / Posted on: January 2, 2019The 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.
VIEW POSTHospice FY2019 Proposed Rule – Payment and Quality Reporting Program
By Katie Wehri / Posted on: May 4, 2018The 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, 2018Each 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.
VIEW POSTTwo Big Changes for Hospice
By Katie Wehri / Posted on: March 21, 2018Recently, 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…
VIEW POSTTargeted Probe and Educate – What We Have Learned So Far
By Melinda A. Gaboury, CEO / Posted on: March 13, 2018Targeted 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.
VIEW POSTCAHPS – Home Health & Hospice
By Melinda A. Gaboury, CEO / Posted on: March 2, 2018Are 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…
VIEW POSTHospice Orientation and Training
By Katie Wehri / Posted on: February 19, 2018There 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.
VIEW POSTWhen Must an Advance Beneficiary Notice Be Used in Hospice?
By Katie Wehri / Posted on: February 2, 2018All 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…
VIEW POSTTop Ten Hospice Survey Deficiencies
By Katie Wehri / Posted on: January 22, 2018The 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.
VIEW POSTHome Health & Hospice PEPPER Reports
By Melinda A. Gaboury, CEO / Posted on: January 15, 2018Over 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…
VIEW POSTNew Medicare Beneficiary Identifiers
By Melinda A. Gaboury, CEO / Posted on: December 20, 2017HPS 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…
VIEW POSTHospice Physicians – Enroll in PECOS or State Medicaid Plans?
By Katie Wehri / Posted on: December 8, 2017The 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…
VIEW POSTOpioid Disposal and Destruction – Considerations for Hospices
By Katie Wehri / Posted on: November 17, 2017With 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…
VIEW POSTPreparing for Hospice Targeted Probe and Educate (TPE)
By Katie Wehri / Posted on: October 31, 2017As 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.
VIEW POSTHospice CTI and Election Statement Made Easy
By Katie Wehri / Posted on: October 16, 2017CMS 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…
VIEW POSTNew Medicare Cards – Questions Answered
By Melinda A. Gaboury, CEO / Posted on: October 10, 2017HPS 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…
VIEW POSTTargeted Probe and Educate
By Melinda A. Gaboury, CEO / Posted on: September 25, 2017HPS 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.
VIEW POSTHospice General Inpatient Care
By Katie Wehri / Posted on: September 18, 2017CMS 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…
VIEW POSTUpdates to the Hospice Aggregate Cap
By Katie Wehri / Posted on: September 1, 2017The 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…
VIEW POSTHospice Compare Site Now Live
By Katie Wehri / Posted on: August 18, 2017On 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.
VIEW POST2018 Hospice Final Rule & NOE Electronic Submission
By Katie Wehri / Posted on: August 4, 2017Late 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…
VIEW POSTHome Care & Hospice Emergency Preparedness
By Katie Wehri / Posted on: July 7, 2017We 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, 2017Former 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…
VIEW POSTHospice Quality Reporting Program Update – HIS and Hospice Compare
By Katie Wehri / Posted on: June 16, 2017CMS 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…
VIEW POSTAttending versus Referring Physician in Hospice
By Katie Wehri / Posted on: June 1, 2017A 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.
VIEW POSTHospice Proposed Rule
By Katie Wehri / Posted on: April 27, 2017Late 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…
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HIPAA for Home Care | Establishing A Compliant Agency
By Drew Rowley / Posted on: March 3, 2017HIPAA 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?
VIEW POSTKey Points Regarding 2016 Hospice Payment Reform
By Melinda A. Gaboury, CEO / Posted on: February 19, 2016…
VIEW POSTHospice CAHPS Surveys Will Affect Payment
By Melinda A. Gaboury, CEO / Posted on: January 29, 2016…
VIEW POST2016 HHRG Tables & Hospice CBSAs!
By Melinda A. Gaboury, CEO / Posted on: December 22, 2015…
VIEW POST2016 HHRG Tables & Hospice CBSAs!
By Melinda A. Gaboury, CEO / Posted on: December 22, 2015…
VIEW POSTUshering In 2016 – Kick off the Year Right!
By Melinda A. Gaboury, CEO / Posted on: December 11, 2015…
VIEW POSTInitials and Not a Full Signature, Allowed?
By Melinda A. Gaboury, CEO / Posted on: October 9, 2015…
VIEW POSTCMS Issues 2016 FINAL Hospice Payment and Quality Rule
By Melinda A. Gaboury, CEO / Posted on: August 7, 2015…
VIEW POSTHospice Update on Attending Physician
By Melinda A. Gaboury, CEO / Posted on: May 20, 2015…
VIEW POSTCMS Issues FY2016 Proposed Hospice Payment and Quality Rule
By Melinda A. Gaboury, CEO / Posted on: May 6, 2015…
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