Home Health & Hospice Week

Watch for forthcoming Q&As to shed some light on the topic.

Stay tuned for clarifications on Medicare’s interdisciplinary group requirements in light of hospices’ new ability to use Marriage and Family Therapists and/or Mental Health Counselors.

Reminder: In the physician fee schedule proposed rule for 2024, the Centers for Medicare & Medicaid Services floated the idea of requiring MFTs/MHCs for IDGs depending on a patient’s needs. But in the PFS final rule published in the Nov. 16 Federal Register, CMS changed its tune. “The hospice IDG will only be required to include one [social worker], one MFT, or one MHC,” the rule said. “The hospice is not required to include all three of these professions as members of the IDG,” the agency clarified.

And in a November Open Door Forum for home health and hospice agencies, CMS further confirmed that hospices don’t have to hire MFTs/MHCs at all, among other clarifications (see HHHW by AAPC, Vol. XXXII, No. 43).

But hospices still have a lot of questions about the change.

For example: “Hospice programs are wondering if they always need to have a social worker in the [interdisciplinary] group even though they might be using a marriage and family therapist or a mental health counselor,” said one attendee in the question-and-answer portion of the forum. “I just think more guidance needs to be issued,” she told CMS — including a Medicare State Operations Manual addition perhaps.

Help is on the way, indicated CMS. “We currently have [questions and answers] related to this topic area finishing up CMS clearance right now,” an agency official responded in the forum. They “hope to have them out to the industry and also be posted on the hospice center web page … [to] answer these questions,” she said.

While the Q&As will ideally be out in short order, an official SOM update may take a while longer. “Once the Q&A is out, our survey side of CMS will be sending out a QSO memo with the guidance … currently being worked on,” the CMS staffer explained. “But guidance takes a little bit because it has to go through clearance at CMS,” she pointed out.

Other hospice topics addressed in the forum include:

• HOPE. As CMS’ Jermama Keys indicated in the November forum, hospices aren’t likely to get any news on the Hospice Outcomes and Patient Evaluation assessment tool before the hospice proposed rule comes out this spring (see HHHW by AAPC, Vol. XXXII, No. 43). That’s even though CMS said it planned to “provide additional information regarding HOPE testing results on the HQRP website in fall of 2023” in the hospice final rule for 2024.

“The HOPE is still in progress and … updates will be provided in an upcoming rulemaking,” Keys said in response to a question.

• Care Compare. Watch for the February refresh of hospices’ Care Compare data next month, Keys told forum attendees. CMS issued preview reports for the data back in November, Keys noted.
• CAHPS. The next deadline for hospice CAHPS data is Feb. 14, Keys highlighted.