Home Health & Hospice Week

COPs are now in effect, CMS reminds hospices in forum.

Whether you love or hate Medicare’s recent proposal to collect more data on hospice claims, you’ll have a while before you have to deal with it.

The Centers for Medicare & Medicaid Services doesn’t expect to implement its "phase 3" data collection proposal until after 2009, CMS’s Katie Lucas said in the Dec. 9 Open Door Forum for home care providers. "We do not have a date at this time for implementation," Lucas told attendees.

Background: CMS wants hospices to report visits in 15-minute increments for disciplines that already have NUBC revenue codes -- physical, occupational and speech therapy, skilled nursing, aide, and clinical social work (see Eli’s HCW, Vol. XVII, No. 41, p. 322). Reporting visits in those units would require line-item billing. CMS also wants to count some social work phone calls as visits.

CMS received 59 e-mailed responses to the proposal during the public comment period that closed Nov. 22, Lucas noted. CMS may request at least one more round of input before implementing phase 3, she added.

Aim: CMS intends to use the data to "assess resource utilization" and conduct more comprehensive analysis of the benefit, Lucas explained. That means even though it won’t have a direct payment impact, hospices had better be careful to bill accurately when the requirements begin, observers note.

Pay Attention To CoPs Or Risk Non-Compliance

Any surveyor who shows up at your door will expect you to be living up to the new hospice conditions of participation that took effect Dec. 2.

"The new rules are now effective," a CMS staffer warned in the forum.

The new COPs address nursing home relationships, medical directors, contracting with other providers, and a wide range of other issues.