Home Health & Hospice Week

Regulations:

Hospices Anxiously Await Physician Final Rule For MFT/MHC Decision

Plus: HOPE tool, HIS data migration seem to be bogged down.

Hospices hoping for a hint at whether they’ll be required to staff Marriage and Family Therapist and Mental Health Counselor disciplines were disappointed in Medicare’s Oct. 11 Open Door Forum for home health and hospice providers.

Recap: The Consolidated Appropriations Act, 2023 “established the new Medicare benefit category for MFT services and MHC services furnished by and directly billed by MFTs and MHCs,” the Centers for Medicare & Medicaid Services explained in the 2024 physician fee schedule proposed rule published back in August. CMS then proposed adding them into the hospice Conditions of Participation personnel requirements. Many providers believed the rule would allow hospices to use MFTs and MHCs, not require them to, but CMS proposed the requirement in the rule. (See more details of the proposal in HHHW by AAPC, Vol. XXXII, No. 31.)

One caller tried to pin down CMS on whether that proposal would be finalized as-is. But the agency’s Mary Rossi- Coajou is staying mum as required by rulemaking procedures.

The PFS final rule will be out on or around Nov. 1 and will address the requirements and procedures around the new provision, Rossi-Coajou told the attendee in the Zoom call. “Once Nov. 1 comes around, we’ll be glad to assist you in any way,” she said.

Hospices are worried about how to find the MFTs and MHCs who have enrolled in Medicare and the timeline for getting them on staff or under contract, the caller indicated.

Other hospice issues addressed in the forum include:

HIS reporting migration. Plans to move Hospice Item Set data submission to iQIES still appear to be on the slow track, a CMS official indicated in a response to a question.

Reminder: CMS announced plans to move HIS reporting over to iQIES a few years ago, but then the project seemed to stall. In a November 2021 Open Door Forum, CMS confirmed the move wouldn’t happen in 2022 (see HHHW by AAPC, Vol. XXX, No. 42) and hasn’t made any announcements about it.

“That transition is still scheduled to happen,” CMS’ Jermama Keys confirmed in the forum. But “I unfortunately do not know the specific time frame at this time,” Keys told a provider in the question-and-answer portion of the forum.

HOPE. Hospices hoping to hear about the Hospice Outcomes and Patient Evaluation assessment tool will have to cool their heels a bit longer. No HOPE news will be forthcoming “in the upcoming weeks,” Keys related.

In the hospice final rule for 2024 released July 28, the Centers for Medicare & Medicaid Services noted that it planned to “provide additional information regarding HOPE testing results on the HQRP website in fall of 2023.” But in the August Open Door Forum, Keys hinted that target date could slide later (see HHHW by AAPC, Vol. XXXII, No. 31).

HQRP webinar. The next Hospice Quality Reporting Program forum will be Nov. 14. “Registration information will be available in late October or early November,” Keys said.

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