Home Health & Hospice Week

Duplicate notices and claims hold even for out-of-area plans.

As if hospices don’t have enough to do, Medicare wants you to do twice the billing work for patients enrolled in a Medicare Advantage plan that is participating in the Value-Based Insurance Design (VBID) model with hospice coverage.

Background: “Starting in January 2021, some plans offered by certain Medicare Advantage Organizations (MAOs) include the Medicare hospice benefit in their benefits package as part of a [Centers for Medicare & Medicaid Services] Innovation Center Model,” HHH Medicare Administrative Contractor Palmetto GBA says in a Jan. 12 post to its website. “Under the Model, the participating MAOs are responsible for coverage and payment of all services covered by Original Medicare, including hospice.”

Watch out: “In 2022, the Model expanded to additional states and plans,” Palmetto reminds hospices.

You can find out exactly which states and plans by looking at the letter and checklist “recently sent” to hospices, Palmetto says. See the letter at https://palmettogba.com/palmetto/providers.nsf/files/CR12524_2022-VBID-Hospice-Provider-Letter-Checklist.pdf/$FILE/CR12524_2022-VBID-Hospice-Provider-Letter-Checklist.pdf; a link to a spreadsheet with the participating plans for 2022 is in the second page of the letter.

Pointer: “You must send all notices and claims to both the participating MAO and your MAC,” Palmetto and CMS say in the letter. “The MAO will process payment, and the MAC will process the claims for informational and operational purposes and for CMS to monitor the Model.”

That goes even if the MAO doesn’t cover your geographic area, the letter elaborates. “A patient may travel for their hospice care, so you may see a patient enrolled in one of the participating plans offering coverage not in your service area,” it explains. “For example, a patient with coverage from a participating plan whose service area is in Ohio may travel to receive hospice care from you in Florida. You should submit all notices and claims to the plan in Ohio,” it instructs.

Good news: You’re not required to contract with an MAO, and “if you choose not to contract, the participating MAO must continue to pay you at least equivalent to Original Medicare rates for Medicare-covered hospice care,” the letter explains. The VBID model also “doesn’t permit prior authori­zation requirements around hospice elections or transitions between different levels of hospice care,” it says.

A link to the letter is online at https://palmettogba.com/palmetto/jmhhh.nsf/DID/7PU0NJ1KG6#ls.