CMS addresses homebound restrictions, hospice COPs in Open Door Forum.
Hospice COPs Still On Track
In addition to prospective payment system billing, physician signature requirements and durable medical equipment accreditation issues (see related articles, this issue), CMS officials addressed hospice conditions of participation and billing in the forum.
One regional home health intermediary has pulled back its restrictive definition of homebound.
Background: In a November message to providers, RHHI Palmetto GBA stated that medical reviewers wouldn’t consider home care patients homebound if the patients drove a car themselves.
Industry representatives argued that that definition is more restrictive than the Centers for Medicare & Medicaid Services’ take on homebound status. The driving requirement isn’t present in CMS manuals and contradicts guidance given to national trade groups, argued Heather Vasek with the Texas Association for Home Care in the Jan. 9 home health Open Door Forum.
The home health benefit manual indicates that driving wouldn’t necessarily negate homebound status, agreed CMS’ Randy Throndset in the call. Benefici-aries’ homebound status is determined on a case-by-case basis and looks at how much effort it takes the patient to leave the home.
On Jan. 11, Palmetto reissued the homebound article without that restriction. “Absences from the home must be undertaken on an infrequent basis, of relatively short duration and require a considerable and taxing effort on behalf of the beneficiary,” Palmetto maintains in the article.
Resource: For a copy of the article, email editor Rebecca Johnson at rebeccaj@eliresearch.com with “Palmetto Homebound Article” in the subject line.
The long-delayed hospice COPs are still on track for a May release at this time. “We’re looking forward to that,” CMS’ Kim Roche said in the forum that drew 588 callers.
And hospices may be breathing a sigh of relief about the extra visit data that CMS will now require starting in July instead of January. But they still have to worry about billing location of services, a requirement that went into effect last year (see Eli’s HCW, Vol. XVI, No. 5).
One caller expressed confusion about the difference between HCPCS codes for nursing homes. CMS’ Terri Deutsch pointed the provider to Nov. 2, 2007 Transmittal No. 1372 (CR 5567), which offers a clarification on the issue.
The bottom line: Hospices should use Q5003 for patients in a non-Medicare-covered skilled nursing facility stay, the transmittal explains. Q5004 is for patients in a Medicare-covered SNF stay.
Resource: The transmittal, which lays out the current and future hospice data claims requirements, is at www.cms.hhs.gov/transmittals/downloads/R1372CP.pdf. A set of questions and answers about the coming hospice billing requirements are at www.cms.hhs.gov/ProspMedicareFeeSvcPmtGen/downloads/Questions_and_Answers_About_CR5567v2.pdf.