Home Health & Hospice Week

Medicare cracks down on hospice bundling.

Unlike home health agencies, hospices don’t have any Recovery Audit Contractor topics approved yet — and thus no RAC audits. However, that doesn’t mean they are unaffected by RAC and other audit activity.

The Centers for Medicare & Medicaid Services has posted three hospice-related topics for RAC and Medicare Administrative Contractor review since July, including one approved Dec. 11. They dovetail with CMS’s recent emphasis on hospice bundling in its annual payment rules.

Topic #1: The newest topic, “0122-Outpatient Hospice-Related Services,” targets Part A claims for “services related to a hospice terminal diagnosis provided during a hospice period ... included in the hospice payment and ... not paid separately.” When hospital claims like this get denied under the audit, you can expect the facilities to come looking to you for payment, experts warn. The topic applies to RACs in Regions 1-4 and all A/B MACs.

Topic #2: In September, CMS approved the RAC topic “0114-DME while in Hospice.” On its RAC topic website, CMS notes that “all DME billed after the admit date of a beneficiary to hospice services and before the discharge date of a beneficiary from hospice services, will be denied as inclusive to hospice services unless there is a GW modifier present indicating DME is not related to the hospice diagnosis.” Again, durable medical equipment suppliers will come looking to hospices for payment for their denied claims. The topic applies to the Home Health & DME RAC Performant in Region 5, as well as MACs in all states.

Topic #3: In July, CMS approved “0105-Physician Services during Hospice Period.” CMS says that “physician services billed during an active hospice period should be paid by the hospice provider if services are related to the hospice beneficiary’s terminal condition or if a physician is employed or paid under arrangement by the beneficiary’s hospice provider. Medicare should not be billed for either of the aforementioned scenarios.” The topic applies to RACs in Regions 1-4 and MACs in all states.

Review These Home Health RAC Topics

Last December, CMS approved its first home health topic for Performant, as well as all HHH MACs, “0075-Complex Home Health Review: Documentation and Medical Necessity” (see Eli’s HCW, Vol. XXVII, No. 6).

And this year in October, CMS approved a topic relating to physician home visits, “0115-Home Visits Physician Services Overlapping Inpatient Stay.” CMS notes that “Home Visits for physician services should not overlap an active inpatient stay. Providers cannot billed for services that are rendered.” The topic applies to RACs in Regions 1-5 and all MACs.