Home Health & Hospice Week

Hospices seek clarification on diagnosis coding provisions in proposed rule.

The hospice industry is still reeling from provisions in the 2014 proposed payment rule that will change the amount and types of codes they can report on patients’ claims. Providers sought answers to their outstanding coding questions in the Centers for Medicare & Medicaid Services’ May 8 Open Door Forum for home care providers.

Recap: In the rule published in the May 10 Federal Register, CMS tells hospices that "All providers should code and report the principal diagnosis as well as all coexisting and additional diagnoses related to the terminal condition or related conditions." And the agency tells hospices they no longer will be allowed to use Adult Failure to Thrive (783.7) and Debility (799.3) as primary diagnoses on the claims. (See Eli’s HCW, Vol. XXII, No. 16 and No. 17 for more details.)

Some provisions in the rule may be proposed, but the coding sections are a "clarification" of existing policy and guidelines and hospices should be complying with them already, said CMS’s Randy Throndset in the forum.

Coding more than one diagnosis for hospice patients and using another diagnosis that is causing the debility or AFTT are all required by ICD-9 coding guidelines, insisted CMS officials in the call.

Watch for edit deadline: CMS says in the rule it plans to implement an edit that will return hospice claims that use Debility or AFTT as the principal diagnosis. CMS has not yet issued a date those edits will take effect, but pending instructions including the date will be coming out soon, said CMS’s Wendy Tucker in the forum.

While the policies are already in effect, CMS is taking feedback on the clarification, Throndset allowed. Comments on the rule are due June 28.

(For more information and analysis on the new coding requirements for hospice, see a future issue of Eli’s Home Care Week.)

Other hospice issues addressed in the forum include:

• Cost reports. CMS issued proposed cost report changes at the same time as the rule, although in a separate Paperwork Reduction Act notice at www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing.html — scroll down to the "Hospice Cost and Data Report" listing on April 29. CMS is taking comments on the cost report until June 28, noted CMS’s Gail Duncan in the forum.

"The cost report is substantially expanded from the current cost reporting form, and focuses on a process to have costs reported based on the level of care," the National Association for Home Care & Hospice says. "To accurately complete the draft Hospice Cost and Data Report will require most hospices to substantially expand their chart of accounts and accumulate statistical information not presently being accumulated."

Hospices will need to segregate all direct patient care costs by multiple cost categories into the four respective levels of hospice care, NAHC notes. And CMS has expanded the general service cost centers and sections on non-reimbursable activities such as marketing. "The expansion of general cost centers far exceeds what was anticipated," the trade group says.

• Quality program. CMS will be providing updated training materials about the hospice quality reporting program, noted CMS’s Robin Dowell in the forum. CMS has eliminated the requirement to report domains for the structural quality measures collected, Dowell explained.