Home Health & Hospice Week

Plus: MCCM increases participation after loosening eligibility criteria.

Reimbursement problems related to hospice payment reform continue to drag on, but at least hospices should soon receive consistent marching orders on what they can fix.

The only claims processing problems left for paying high versus low Routine Home Care rates occur when there are more than 100 days in a beneficiary’s prior benefit period, a Centers for Medicare & Medicaid Services official explained in the May 3 Open Door Forum for hospice and home care providers. There’s also a problem when there are transfers in the benefit period.

Good news: That means that, except for those patients with 100-plus days in prior periods or transfers in the period, hospices can submit claims for RHC corrections now, the CMS staffer told forum attendees.

For adjustments that are beyond the timely filing period, CMS will instruct the HHH Medicare Administrative Contractor to allow exceptions because Medicare program problems caused the delay, the CMS source said.

Bad news: But, it will be up to you to submit the adjustments — CMS won’t automatically correct claims paid in error, another CMS official confirmed in the question-and-answer portion of the call.

Similarly, CMS has resolved the payment problems related to Service Intensity Add-ons, the CMS official noted in response to a caller. But hospices will have to submit their own claims for adjustment; CMS won’t automatically correct them.

A forthcoming MLN Matters article will explain the adjustment process and contain more details, the CMS reps said. Watch for that article at www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNMattersArticles/2017-MLN-Matters-Articles.html.

Other hospice issues addressed in the forum include:

• MCCM. For the first time, CMS publicly released its Medicare Care Choices Model participation figures. The demonstration project that is testing concurrent care has enrolled 834 beneficiaries, a CMS official revealed in the forum.

Since the program began in 2016, hospices had complained that the eligibility criteria made it very difficult to enroll participants (see Eli’s HCW, Vol. XXV, No. 32). In response, CMS in May 2016 eliminated the requirement for Part D enrollment, and reduced the requirement for two prior inpatient hospital stays to one hospital encounter. When that didn’t seem to go far enough, CMS in January 2017 reduced the requirement for Medicare enrolment prior to model participation from 24 months to 12 months, and scaled down the requirement that within 12 months of model enrollment, the beneficiary must have three office visits with the same physician practice for the eligible diagnosis to three office visits with any physician practice for any condition.

MCCM enrollment is increasing, the CMS staffer said. “We are pleased that the model appears to be introducing the Medicare hospice benefit to individuals who might not have considered hospice otherwise.” Enrollment should further increase when Cohort 2 starts in January. Education and training for that phase of MCCM will begin this summer, the CMS source noted.

But hospices may not be cheering yet. “The changes that CMS made to the eligibility criteria have improved the circumstances,” allows Theresa Forster with the National Association for Home Care & Hospice. “But it appears that additional action may be needed to get a level of participation that ensures that the results of the demonstration provide guidance for potential future policy changes,” Forster tells Eli.

More stats: CMS released some more figures about the program. Beneficiaries who chose the hospice benefit immediately following MCCM screening numbered 392. And 371 benes (79 percent) entered MCCM and then were discharged from MCCM and elected the Medicare hospice benefit, the CMS official said.

• Hospice Compare. If you thought the “winter 2018” date CMS cited in the proposed rule for 2018 hospice payment for launching the CAHPS portion of Hospice Compare meant the end of next year, you were wrong.

Public display of CAHPS measures on Hospice Compare will begin “early in the year of 2018,” a CMS official clarified in the forum. Hospice Compare, which will initially just include the Hospice Item Set-based measures, is still on track for a summer 2017 launch.

• New HIS measures. Just because CMS didn’t officially propose two new HIS measures yet, doesn’t mean you should disregard them. Medicare is thinking about proposing measures on potentially avoidable hospice care transitions and access to levels of hospice care, a CMS staffer pointed out in the forum.

Hospice transitions at end of life “are burdensome to patients, families, and the health care system at large, because they are associated with adverse health outcomes, lower patient and family satisfaction, higher health care costs, and fragmentation of care delivery,” CMS notes in the proposed rule for 2018 hospice payment published in the May 3 Federal Register.

The levels of care measure “has the potential to improve access to various levels of care for patients and caregivers,” CMS adds in the rule.

“Appropriate use of CHC and GIP increases the likelihood of a hospice patient dying in his or her location of choice, decreases health resource utilization resulting in potential cost savings, and increases patient and caregiver satisfaction.”

Stay tuned: “These two measure concepts are under development, and details regarding measure definitions, specifications and timeline for implementation will be communicated in future rulemaking,” CMS says. “We are soliciting comments regarding high priority concept areas for future measure development.”

Instructions for submitting comments by the June 26 deadline are in the rule at www.gpo.gov/fdsys/pkg/FR-2017-05-03/pdf/2017-08563.pdf.