Federal Home Health and Hospice Updates
Please see the following home health and hospice updates provided by LeadingAge National:
Hospice: Certifying Physicians Enrollment or Opt-Out Delayed Until June 3rd. As finalized in the Fiscal Year (FY) 2024 Hospice Payment Rate Update Final Rule, physicians who certify hospice services must enroll in or opt out of Medicare. Originally, the implementation of this provision was set for May 1, 2024. Due to technical issues hospices were facing confirming that physicians were indeed enrolled or formally opted out, the Centers for Medicare and Medicaid Services (CMS) delayed the implementation until June 3, 2024. At that time, CMS will begin denying hospice claims if the certifying physician, including hospice physician and hospice attending physician, is not in the Provider Enrollment, Chain, and Ownership System (PECOS) hospice ordering and referring files. CMS created a Hospice Certifying Enrollment Question and Answer (Q&A) document clarifying the requirements. An additional Medicare Learning Network (MLN) Matters article summarizes the changes.
State-Based One-Pagers on Home Health Patient Demographics and Medicare Advantage (MA) Penetration. The Research Institute for Home Care, of which LeadingAge National is a member, along with the Council of State Home Care and Hospice Associations, created two new sets of state-level one-pagers demonstrating patient demographic similarities and differences in MA and Traditional Medicare home health patients, along with year-over-year workforce and enrollment trends. Demographic data points include gender distribution of home health users, racial breakdown of home health users, urban-rural status of home health users, and dual eligibility of home health users. Data is sourced entirely from government sources, including the Medicare Beneficiary Summary File, Outcome and Assessment Information Set (OASIS) data, and the Bureau of Labor Statistics (BLS).
Home Health Claims Processing Updates. On April 11th, CMS issued a Change Request (CR 13543) outlining a new edit in Original Medicare systems to ensure that required county codes are reported on all home health claims. This CR also makes clarifications to home health billing instructions regarding Notice of Admission timeliness exceptions, charge reporting for telehealth visits, and diagnosis code reporting.
New Proposed Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey Available for Review. CMS is proposing in the FY 2025 Hospice Wage Index to implement a revised CAHPS Hospice Survey beginning with January 2025 decedents. A 2021 CAHPS Hospice Survey mode experiment found that these changes to the survey instrument and administration protocols increased response rates. If the provisions are finalized, data collection using the revised survey will begin in April 2025. The revised survey is shorter and simpler than the current survey and includes new questions on topics suggested by stakeholders, including two questions that will be used to calculate a new Care Preferences measure. A draft copy of the proposed survey is available here.
CMS Updates Informal Dispute Resolution (IDR) and Enforcement Procedures for Home Health and Hospice. On May 3rd, the Center for Clinical Standards and Quality at CMS issued a memo revising the State Operations Manual (SOM) Chapter 10 to update IDR process and enforcement procedures for hospice and home health agencies. These procedures were last updated for home health in 2014, when an IDR and alternative sanction process was added for home health. In the Calendar Year (CY) 2022 Home Health Final Rule, CMS finalized enforcement remedies for hospice. The IDR process for hospice agencies was finalized in the CY 2024 Home Health Rule.
Home Health Value-Based Purchasing (HHVBP) Model Interim Performance Reports (IPRs) Available on Internet Quality Improvement and Evaluation System (iQIES). The Preliminary April 2024 IPRs for the expanded HHVBP Model were published on iQIES on April 30th. The quarterly IPRs provide home health agencies with the cohort assignment, performance year measure data for the 12 most recent months, and interim Total Performance Score (TPS). Using the IPR, an agency can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year. There are two versions of the quarterly IPRs: a Preliminary IPR and a Final IPR. The Preliminary IPR provides an agency with an opportunity to submit a recalculation request for applicable measures and interim performance scores if the agency believes there is evidence of discrepancy in the calculation not associated with errors in data submission requirements under federal rules. To dispute the calculation of the performance scores in the Preliminary IPR, an agency must submit a recalculation request within 15 calendar days after publication of the Preliminary IPR. For the April 2024 IPR, agencies must submit a recalculation request by May 15, 2024. The Final IPR will reflect any changes resulting from any approved recalculation request. Members can find complete instructions on submitting a recalculation request here.
Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871