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 Self Pay option.
- Response option “J. Self-pay”: For purposes of completing Item A1400, the minimum threshold for a “self-pay” patient would be ability to pay for any low-cost medication, supply or service (e.g., medication co-pay or over-the-counter medication). Based on this definition of self-pay, for certain providers, a large majority of patients may be identified as self-pay; this is acceptable.
- Select response option J if the patient has any amount of personal funds available to contribute to healthcare expenses during the hospice episode of care. CMS recommends selecting this response option if the patient is paying for or able to pay for any of their own medications, supplies, services, room and board, etc.
- Self-Pay should be chosen even if the patient is not actively paying for anything, but could pay for something or has the funds if needed. Additionally, the intent of the self-pay response option is not to assess patients’ ability to self-pay, but rather to determine availability of funds to cover costs of care. Selecting the self-pay response option obligates neither the hospice nor the patient to use those funds to pay for care, should a need to self-pay arise. In this sense, collection of data to complete Item A1400 should not influence the delivery of hospice services based on the patient’s ability to self-pay for care, or based on availability of other pay sources the patient may have. This HIS item is not used for quality measure calculation.
- For the purposes of completing Item A1400, existence of pay sources can be based on patient/caregiver report, and gathering additional supplementary financial information is not likely to be necessary. It is possible to collect the information during the referral/intake/admission process when verifying insurance sources, or during preadmission/admission discussions of what the hospice benefit will cover and what the patient may be responsible for. CMS understands that these conversations may take place as part of an overall assessment of the patient’s ability to pay for such items that may not traditionally be paid for by the Hospice Benefit.
With this clarification, hospices will likely see the number of their patients with the Self-pay option increase. As stated above, this is acceptable. Healthcare Provider Solutions, Inc. takes this opportunity to remind hospices that the response to A1400 should include ALL of the patient’s payor sources regardless of whether or not that payor is expected/likely to provide reimbursement, and that the response to this item should not be modified if the patient’s payor source(s) change after the admission period.
Hospices can find the additional guidance from CMS regarding all response options for item A1400 here.
The release of Hospice Compare is getting closer, and many hospices want to know exactly what will be posted about their program on this new site. CMS released Hospice Provider Preview Reports on June 1. These reports show hospices the data that will be included in their Compare page. Hospices are strongly encouraged to review this data for accuracy, and request any corrections by June 30, 2017. Corrections will only be made if a hospice can prove that an error has been made in the underlying measure calculations and CMS concurs. Requests for CMS review of the calculations can only be made via email following the instructions found in the middle of the page on the Hospice Quality Public Reporting webpage. Again, corrections to the data will only be made if there is an error in the calculation. Hospices should note that any changes to their calculations resulting from a formal review by CMS will not be reflected in the immediately subsequent Compare data, but will be reflected in the subsequent Compare “refresh.”
Hospice providers may continue to submit corrections to their HIS data for up to 36 months beyond the target date (the date of the admission or discharge) on a given assessment, although corrections that are made to any HIS assessment record for which the target dates fall within the applicable reporting period (initially Quarter 4- 2015 to Quarter 3-2016), will only be reflected in subsequent quarterly preview reports and Compare refreshes.
Going forward, Preview Reports will be available approximately 8 months after the end of each data collection period (based on 12 rolling months of data). Hospice Compare will receive a quarterly refresh of data. For example, the HIS data selection period to be publicly reported this summer will include data for patient stays discharged during Quarter 4- 2015 to Quarter 3-2016. The last month in Quarter 3-2016 is September. Therefore, Preview reports were available June 1, 2017 – 8 months after September 2016.
The seven HIS quality measures to be included in the initial release of Hospice Compare are:
- NQF #1641 Treatment Preferences
- NQF #1647 Beliefs/Values
- NQF #1634 Pain Screening
- NQF #1637 Pain Assessment
- NQF #1639 Dyspnea Screening
- NQF #1638 Dyspnea Treatment
- NQF #1617 Bowel Regimen
The Hospice Compare display will include, among demographic data, the following:
- Number of eligible patient stays in the denominator (excluding stays less than 20)
- The hospice’s observed percent
- National rate
CMS has notified hospices that the order of the measure(s) in the Preview Reports may not represent the order displayed on Hospice Compare. Also, the titles of the measure(s) are not the consumer language titles that appear on the Hospice Compare website, and the numbering of the footnotes on this preview report is different from the footnotes displayed on the Hospice Compare website.
*For those hospices not able to access CASPER, please begin with the CMSNet online registration process at https://www.qtso.com/accessisbc.html