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Federal Home Health and Hospice Update

Home health and hospice providers should note several updates provided over the last few days from LeadingAge National:

CAHPS Hospice Survey Data Submission Deadline in Two Weeks. The data submission deadline for hospice patients who passed away in January, February, and March 2022 (Quarter 1 2022) is Aug. 10, 2022. Survey vendors are responsible for successfully submitting files by 11:59 p.m. ET on Aug. 10, 2022. It is the responsibility of hospice agencies to ensure that their contracted survey vendor has appropriately submitted this information. Once a series of edit checks are complete, survey vendors and hospices will receive an email indicating that Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey Data Submission Reports are available for viewing in their respective folders in the CAHPS Hospice Survey Data Warehouse. Reports will be posted by 5 p.m. ET on the next business day after submission by the survey vendor. Questions regarding submission can be directed to the CAHPS Hospice Survey Data Coordination Team at cahpshospicetechsupport@rand.org.

CMS Looking for More Hospices to Test HOPE Tool. The Centers for Medicare and Medicaid Services (CMS) and its contractor, Abt Associates, are recruiting additional Medicare-certified hospice providers to participate in a beta test of the draft hospice patient assessment instrument called Hospice Outcomes & Patient Evaluation (HOPE). Recruitment is ongoing, and training will occur on a rolling basis. Data collection begins when training is completed and is expected to continue through fall 2022. While any Medicare-certified hospice can participate, the testing does require certain staffing expectations, which hospice providers will need to consider before committing to testing.

  • Testing requires one to two joint visits per week between different disciplines.
  • CMS anticipates hospices will need six to eight registered nurses, three to four social workers, and three to four chaplains.
  • For joint visits, two registered nurses visit one patient at the same time to complete the HOPE nurse assessment.
  • Two social workers visit the patient at the same time to complete the HOPE social work assessment.
  • Two chaplains visit the patient at the same time to complete the HOPE chaplain assessment.
  • One of the two registered nurses, social workers, and chaplains may attend their joint visit via video call, such as Zoom.
  • HOPE assessments are completed at hospice admission, for symptom reassessment, and at live discharge.

Those interested in participating should email HOPETesting@abtassoc.com. The detailed recruitment announcement is available on CMS's Hospice Quality Reporting Program (QRP) Provider and Stakeholder Engagement webpage.

Home Health Care Compare July Refresh. Home Health Care Compare has been updated for the July refresh. The Home Health Care CAHPS (HHCAHPS) Survey results are based on responses from patients who received home health care from Medicare-certified home health agencies from January 2021 through December 2021. Data are also available on the HHCAHPS website through the “Archived Publicly Reported Data” link under the “General Information” tab. On this webpage, you can access:

  • Home health agency-level data;
  • State and national averages;
  • Star rating cut points; and
  • Patient mix adjustment coefficients for the linearized data used to construct the star ratings.

Corrections to Processing of Canceled Home Health Notices of Admission and of Period Sequence Edits. On July 21st, CMS issued Change Request (CR) 12790 to correct two problems in Notice of Admission (NOA) processing. Both changes attempt to correct additional NOA burdens for providers. The CR will be effective for claims processed on or after Jan. 1, 2023.

  • Previous CR 12227 contained requirements for removing a home health admission period created by an NOA using Type of Bill (TOB) 032D if the NOA was submitted in error. This CR did not take into account reversing changes to the previous admission period resulting when an NOA is received in a transfer situation from one home health agency to another. Currently, if a transfer NOA is submitted in error and subsequently canceled with a TOB 032D, it will remove the transfer agency’s admission period but will not restore the original calculated 30-day End date on the period of the previous agency’s episode. The new CR revises Medicare systems to restore the previous period’s End date when a transfer NOA is canceled, which will avoid administrative burdens for home health agencies.
  • The new CR also updates Medicare systems to prevent claims that have been medically reviewed and later identified for adjustment due to an incorrect period sequence from erasing additional medical review coding if medical review has been completed OR prevents additional unnecessary record requests to providers if they are still under medical review.

New Resources for Home Health Prospective Payment Rule. To help members navigate the CMS Home Health Prospective Payment System Rate Update, LeadingAge National is taking action. If implemented, these cuts to home health providers would further erode access to care and services needed by older adults and their families. Provided here are helpful talking points, a sample op-ed template, and slides from LeadingAge National's recent Home Health Member Network meeting.

Updated Quarterly OASIS Q&As. CMS has released July 2022 Outcome and Assessment Information Set (OASIS) Q&As. This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks. As a reminder, responses may be time-limited and may be superseded by future CMS guidance. This quarterly guidance includes clarifications on the following items:

  • D0150/D0160 – Patient Mood Interview (PHQ-2 to 9) and Total Severity Score: If agencies miss providing this assessment or questions within the assessment, CMS outlines in these Q&As how to properly code the missed or unasked questions for these items. Additionally, CMS states that this guidance should supersede what is in the current draft OASIS-E Guidance Manual posted in May 2022.
  • D0150 – Patient Mood Interview (PHQ-2 to 9): CMS provides guidance on determining when to conduct the PHQ-2 (D0150A and D0150B) versus the full PHQ-9 (D0150A-DO150I).
  • GG0130/GG0170 – Self-Care and Mobility: Providers asked for examples of how to assess “not based on availability of such assistance” when coding self-care and mobility.
  • GG0170 – Mobility: Providers asked for clarification with waking and wheelchair activities what CMS means by “the 90-degree turn should occur at the patient’s ability level.”
  • GG0170M, N, and O – Mobility: When coding for uses of stair lift, CMS answers questions on what is being assessed, either type and amount of assistance required to get off the stair lift, or type and amount to use the stair lift itself.
  • M2020/M2030 – Management of Oral Medication and Management of Injectable Medication: CMS provides clarification on coding for where medications are “routinely stored” in situations where an individual resides in an assisted living facility that may have policies on medication storage.
  • N0415 – High-Risk Drug Classes: Use and Indication: CMS clarifies how to document if there is a patient-specific indication noted for all medications in the drug class.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871