Home Health & Hospice Week

New reporting could delay cash flow, hospices worry.

Hospices are better prepared to tackle the new claims data requirement than they were six months ago. But it will still be a major effort for uncertain results, critics say.

Last year, the Centers for Medicare & Medicaid Services set a Jan. 1 deadline for hospices to begin reporting visit data for some of their staff. After a strident outcry from the industry over unanswered reporting questions and other problems, CMS made the data reporting optional until July 1.

"Hospices are more ready now that they were on Jan. 1," judges Janet Neigh with the National Association for Home Care & Hospice. CMS has issued clarifications and more guidance on how to count visits that is helpful to providers.

Reprieve: Hospices welcomed CMS' April announcement releasing them from collecting data on non-hospice staff in inpatient settings, notes the head of billing and collections for a large for-profit hospice based in the Southeast.

"This really was a sigh of relief for many of us," the source says. "It's difficult enough to count direct patient care at the bedside in a setting where rounds are not to be counted as visits."

Eliminating non-hospice staff makes the inpatient visit counting problem "much more manageable," says Judi Lund Person with the National Hospice and Palliative Care Organization.

Don't forget: "Hospices must still count the inpatient visits made by their own personnel," Neigh reminds providers.

Another clarification came from regional home health intermediary Cahaba GBA in a June 23 email to providers. In a recent teleconference on the visit reporting requirements, a hospice asked whether a nurse's visit to pronounce a patient's death counts as a skilled nurse visit.

"Yes," Cahaba answers. "A nurse visit at time of 'death' is to assess the patient's condition to determine if they are deceased and would be a reasonable and medically necessary skilled nurse function."

"Visits after the pronouncement of death would not be reported," the RHHI adds.

Hospices have also had time to work with their software vendors and begin submitting test claims, Person points out. "We are still concerned that test claims are not going through clean for every FI but many providers are working on that issue," Person tells Eli.

All for naught? But while hospices are better prepared to report the data, there are still plenty of challenges about the new requirement.

Hospices still must arrive at a per visit charge with fairly limited guidance from CMS. "Do you look at the labor expense and work yourself back to a charge? Do you use your cost report? Do you compute the charges based on expenses where the services took place?" asks the billing and collections manager. "This is the challenge."

New territory: The concept of a visit charge is completely [...]