Home Health & Hospice Week

Report your managing employees ASAP under new definition.

Stay up to date with recent hospice regulatory changes.

Change #1: The Centers for Medicare & Medicaid Services has revised the Hospice Item Set Manual.

HIS Manual V3.01, which was effective Jan. 31, 2024, mostly revises dates and incorporates the changeover from the National Quality Forum (NQF) to the Consensus Based Entity (CBE).

Reminder: As of March 2023, Battelle began serving as the CMS CBE for the Measure Applications Partnership (MAP) (see HHHW by AAPC, Vol. XXXII, No. 23). “Battelle’s Partnership for Quality Measurement (PQM)™ uses a consensus-based process involving a variety of experts — clinicians, patients, measure experts, and health information technology specialists — to ensure informed and thoughtful endorsement reviews of qualified measures,” the contractor says on its website.

The HIS Manual also updates the penalty amount for failing to meet Hospice Quality Reporting Program submission requirements. “Determinations of noncompliance made in 2022 will go into effect in FY 2024 (10/1/2023), reducing the FY 2021 APU by 4 percentage points,” the manual reads.

Reminder: “To be compliant for the FY 2022 APU reporting year and all subsequent reporting years, providers must submit at least 90 percent of their HIS records in accordance with the 30-day submission deadline,” the revised manual specifies.

Overall, “these minor changes to the text in the manual had no impact on the current data sets. HIS Admission V3.00 and HIS Discharge V3.00 are still the current versions,” CMS explains on its Hospice Item Set webpage.

Links to the 126-page HIS Manual and a three-page change table are at www.cms.gov/medicare/quality/hospice/ hospice-item-set-his.

Don’t Forget To Include Medical Directors

Change #2: CMS wants to make sure hospices are on board with new “managing employee” definitions and requirements, according to a revised MLN Matters article.

In the 2024 home health final rule, CMS clarified that the definition of “managing employee” includes the administrator and medical director of a hospice (see HHHW by AAPC, Vol. XXXII, No. 39-40). CMS then updated the Medicare Program Integrity Manual with that requirement in December with Change Request 13333.

Back in December, related article MM13333 noted that “CMS revised the definition of managing employee. For purposes of this definition of managing employee, this includes, but isn’t limited to, a hospice or skilled nursing facility (SNF) administrator and a hospice or SNF medical director.”

Now, CMS has updated MM13333 to add “every Medicare provider and supplier must report all current managing employees. If a hospice … hasn’t reported a medical director or administrator as a managing employee, they must report now.”

See the updated article at www.cms.gov/files/document/mm13333-medicare-program-integrity-manual-cy-2024- home-health-prospective-payment-system-updates.pdf.