Home Health & Hospice Week

Changes to claims ill-timed, experts say.

Payment delays and even denials could greet you in 2008 if CMS forges ahead with its plans to turn Medicare hospice claims into a data-collection device.

"The new requirement will likely throw hospices and their software vendors into an unnecessary and costly period of chaos," says attorney Mary Michal of Reinhart Boerner Van Deuren in Madison, WI.

Background: Until recently, Medicare kept claims simple for hospice providers, requiring only a small number of service lines to report the number of days at each of the four hospice levels of care. Starting this year, the Centers for Medicare & Medicaid Services began requiring hospices to report the site of service, and the agency added a line item dating requirement for one level of care (continuous home care).

Now, CMS is posed to launch an ambitious phase two of its move to make hospice claims more "meaningful." For claims with dates of service on or after Jan. 1, hospices must stipulate the number of visits each beneficiary received in the course of delivering the various levels of care.

Count 'em: Providers must tally the visits for the following disciplines, for each week, at each location of service: Registered nurse, nurse practitioner, licensed nurse, nurse's aide, social worker, and the physician or nurse practitioner serving as the beneficiary's attending physician.

Alert: Hospices also must estimate and submit a cost associated with each visit reported. Because hospices don't charge per visit, they don't have that information readily available, says Janet Neigh of the National Association for Home Care & Hospice. That makes compliance a hardship, she tells Eli.

Keep Big Picture In Mind

Stakeholders are still working to convince CMS to delay the Jan. 1 effective date, which clashes with other big changes for hospice and home health agencies.

One-two punch: The latest round of claim requirements come just as hospices are preparing to absorb major revisions to Medicare Conditions of Par-ticipation for hospice providers.

And many hospice providers are also HHAs faced with a Jan. 1 deadline for the home health prospective payment system changes, noted NAHC at a Sept. 12 meeting with CMS (see Eli's HCW, Vol. XVI, No. 34).

"The problem is the timeline. They are asking for too much too soon," stresses Neigh.

Trying to stay in compliance could drain patient-directed resources. "This can't be good for patient care," says Michal.

Providers are also concerned about the type of data CMS is opting to collect--skewing the concept of what hospice is toward a strictly medical model of care.Chaplains' time with patients won't be counted, nor will services aimed at meeting patients' psycho-social needs, notes Judi Lund Person of the National Hospice and Palliative Care Organization.

"The data to be collected on visits does not mirror the hospice benefit," agrees Neigh.

Long-term worry: If the data CMS collects paints an incomplete picture of hospice care, Medicare payments could erode, some say.

"[The value of] collecting data from hospices is certainly not in question," says Michal. "But let's be sure that it's the right data, collected in a meaningful way."

Resources: A Medlearn Matters article with a link to Transmittal 5567 is available at www.cms.hhs.gov/MLNMattersArticles/downloads/MM5567.pdf. CMS has also issued a Questions & Answers document.