Bulletin November 12th, 2019

November 12th, 2019



HOSPICE: Non-Cancer Length of Stay (NCLOS) Rates, Palmetto GBA List Serve, November 7, 2019 – This electronic Comparative Billing Report (eCBR) focuses on Non-Cancer Length of Stay (NCLOS) rates from April 1, 2019 to September 30, 2019. CBR information is one of the many tools used to assist individual providers to become proactive in addressing potential billing issues and performing internal audits to ensure compliance with Medicare guidelines. Please share with appropriate staff.
HOSPICE: Medicaid Timely Filing, Medicaid List Serve, November 1, 2019 – The following message has been posted to the MITS portal and will also display on the remittance advice for all hospice providers: “November 30, 2019 is the deadline for hospice providers to resubmit claims for dates of service on or after 01/01/2016. Beginning December 1, 2019, the 365-day timely filing claim requirement will resume, meaning that untimely claim submissions will be denied. Providers with questions may contact ODM Provider Assistance for fee-for-service questions at 1-800-686-1516.”

HOME HEALTH: What the 2020 Medicare Home Health Final Rule Means, NAHC Report, November 6, 2019 – On October 31, 2019, the Centers for Medicare & Medicaid Services (CMS) issued the Final Rule for the 2020 payment model, Patient Driven Groupings Model (PDGM), including rates of payment that would start January 1, 2020. The new payment model had been finalized in its design in the 2019 rulemaking cycle and the Final Rule offers some minor tweaks in the payment model and sets out 2020 payment rates. The rule also includes unrelated adjustments in other rules affecting home health, including the 2021 home infusion therapy benefit, quality measures, and the Home Health Value Based Purchasing Demonstration program.

HOME HEALTH and HOSPICE: CMS to Shutter Common Working File for Eligibility Queries Effective February 1, 2020, NAHC Report, November 7, 2019 – CMS has been working over recent years to migrate queries related to benefit eligibility from the Common Working File (CWF) and to establish the HIPAA Eligibility Transaction System (HETS) as the single source for beneficiary eligibility transactions. These actions have been closely monitored since a key concern related to the change centers on the HETS system containing inadequate hospice benefit period information. Over recent days, CMS installed the third quarter HETS updates which are believed to contain changes which, among other changes, is expected to modify the system to allow for full access to hospice benefit period information. These changes clear the way for the final transition to HETS as the sole source for beneficiary eligibility transactions.

RCD UPDATES –                                                                                                                      

OCHCH Members: Thank you very much for participating in OCHCH’s November 8th RCD WEEKLY CALL!

OCHCH recently launched an awareness campaign to provide your agency with the assistance, information, resources, and training you need to tackle the challenges of RCD and PDGM. This campaign is called OPERATION: tackle.
As part of OPERATION: tackle we are hosting weekly conference calls on RCD that started on October 25th and will continue for the foreseeable future. These conference calls will provide an opportunity for us to share the latest developments of RCD, for you to share your challenges, and for our members to share best practices in a real time environment. On the November 8th call you heard Beth Foster sharing the top issues/questions from the November 6, 2019 Palmetto GBA RCD Monthly Provider Teleconference. Also, the OCHCH team answered your questions!
Friday afternoon, November 8th, the following information was shared on the Listserv as follow-up to the weekly OCHCH RCD Call:
AND the MLN Matters® Special Edition (SE) 1436 that is intended for Medicare-enrolled physicians who certify patient eligibility for home health care services and submit claims to Medicare Administrative Contractors (MACs) for those services provided to Medicare beneficiaries.
Palmetto GBA Medical Reviewers expect a date for each goal to be met; there should be designated short-term and long-term goals; and the goal met date is documented.  
Palmetto GBA Clarified Answers to Questions from the November 8th call:
  1. After the provider receives their PCR affirmation, if new services are added, is the provider required to get an affirmation for the new services or would the provider add the new services to the Plan of Care at the next recert?  Also how will this impact the final claim? This is answered in FAQs #80 and #85.
80. If I received a provisionally affirmed decision and UTN for a beneficiary for a 60- day episode and later in the episode the beneficiary’s condition supports adding additional services (e.g. therapy), will I need to submit a new pre-claim review request?
The pre-claim review initial request should be submitted after you have had enough time to evaluate the beneficiary’s condition to determine the services (HCPCS) that will be required for the episode. However, if later in the episode the beneficiary’s condition supports additional services that were not on the initial provisionally affirmed pre- claim review request, you would not need to submit an additional pre-claim review request for that episode.
85. Do we have to submit a new PCR request if we receive supplemental orders for additional services in the episode of care after the PCR request has already been completed?
No, a new PCR request will not be required if additional services are added after the PCR has been processed. The provider would reflect the HCPCS for those added services on their final claim and assure that the documentation, including the order for those services is maintained in the medical record.
“The only things I will add to the above is that it won’t affect a final claim and we will be monitoring for agencies that continually add HCPCs on the final claim.”
  1. Does the diagnosis in the face to face document need to match exactly the diagnosis for which Home Health is providing services? No, but they have to be in the same family/related. MLN Matters® Number: SE1436 states “A face-to-face encounter: Was related to the primary reason the patient requires home health services.”
  1. If a patient was in the Hospital, was then discharged to a SNF and then discharged home with a referral to Home Health, could Home Health use the face to face from the hospitalist?  This is assuming the hospital face to face addressed the reason the Home Health agency would be providing services and was done within 90 days prior to the start of care. Yes, the Home Health can use the face to face from the hospitalist as long as it meets all the other Face-to-Face requirements, such the timeframe, allowed provider type, related to the primary reason, etc.
  1. OCHCH also shared our Members’ concerns about the Provider Call Center (PCC).  Palmetto representative Dan George responded that he will pass the information on. OCHCH will be following up with Palmetto GBA!
Next OCHCH Weekly RCD Conference Call - Friday, NOVEMBER 15, 2019 at 10am!
DON’T MISS THIS OPPORTUNITY!! Please mark your calendars for EVERY FRIDAY @ 10am. The calls will last no more than an hour.
Call-in info through December 2019 will remain the same as the Nov. 1st & 8th call:
Login - https://web.telspan.com/go/ochch/ochchpdgm
Dial: 888-392-4564
Passcode: 7896828#
If you have trouble getting on the Call – PLEASE CALL OCHCH 1-614-885-0434 Ext.206, or e-mail ryan@ochch.org
Talk to you soon!
The RCD Demonstration started on September 30, 2019. All episodes of care, both initial and recertifications starting on or after this date are subject to the requirements of the choice selected.
Dial 855-696-0705
Press “0” at the main menu
Press “0” again
Press “3” for HHH
Press “1” for an RCD agent
All RCD provider questions must go through the Palmetto GBA Provider Contact Center (PCC) at 855-696-0705. However, if your questions are not being answered, you are not receiving a call back in a timely manner, or you need assistance to contact Palmetto GBA, PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, “RCD”, OR call 614-885-0434 Ext 209.
Find RCD Answers through the updated October 16, 2019 Review Choice Demonstration (RCD) for Home Health Services Frequently Asked Questions (FAQs)
Monthly Review Choice Demonstration (RCD) Provider Teleconference Schedule – Next date is 12/04/2019



The following webcasts are hosted by the MACs:

Home Health Patient-Driven Groupings Model (PDGM) Webcast Part One: November 21, 2019 
This is the first of two collaborative webcasts about the Home Health Patient-Driven Groupings Model (PDGM), hosted by your Home Health Medicare Administrative Contractors (MACs), CGS, National Government Services and Palmetto GBA. This presentation will begin on Thursday, November 21, 2019 at 02:00 PM Eastern Standard Time. During this webcast, you will receive information to help your agency prepare to implement billing changes for the PDGM on January 1, 2020. PDGM is the Medicare payment model used to reimburse home health agencies. Please plan to attend.

Home Health Patient-Driven Groupings Model (PDGM) Webcast Part Two: December 5, 2019 

This is second part of two collaborative webcasts about the Home Health Patient-Driven Groupings Model (PDGM), hosted by your Home Health Medicare Administrative Contractors (MACs), CGS, National Government Services and Palmetto GBA. This presentation will begin on Thursday, December 05, 2019 at 02:00 PM Eastern Standard Time. During this webcast, you will receive information to help your agency prepare to implement clinical changes for the PDGM on January 1, 2020. PDGM is the Medicare payment model used to reimburse home health agencies. Please plan to attend.


HelpDesk Question of the Week


Helpdesk Question of the Week –

HOSPICE: Initial Assessment
Question:   We have a SNF asking us to admit a patient prior to being sent home on hospice services on the same day of planned discharge. They have requested this in the past and we have declined to admit until the patient is home based on the standard below. I feel the facility is asking us to admit the morning of discharge so we would then be responsible for the transportation. They state that hospice companies do it “all the time” so I wanted to make sure we are reading the standard correctly and not taking it out of context.
Any insight on this?
From the State Operations Manual, Appendix M, Guidance to Surveyors-Hospice:
§418.54(a) Standard: Initial assessment
The hospice registered nurse must complete an initial assessment within 48 hours after the election of hospice care in accordance with §418.24 is complete (unless the physician, patient, or representative requests that the initial assessment be completed in less than 48 hours.)
Interpretive Guidelines §418.54(a)
The purpose of the initial assessment is to gather the critical information necessary to treat the patient/family’s immediate care needs. The assessment needs to take place in the location where hospice services are being delivered. The initial assessment is not a “meet and greet” visit whereby the hospice introduces itself to the patient/family and begins to evaluate the patient’s interest in and appropriateness for hospice care. It must assess the patient’s immediate physical, psychosocial, emotional and spiritual status related to the terminal illness and related conditions. The initial assessment is necessary to gather the essential information necessary to begin the plan of care and provide the immediate necessary care and services.

Answer:  Yes you are reading the standard correctly.  The patient is to be admitted to hospice in the location where they will receive hospice services as the Interpretive Guidelines note.




Regulatory & Policy Digest


HOME HEALTH and HOSPICE: New Medicare Card: HICN Claims Reject January 1, 2020, Palmetto GBA – Starting January 1, you must use Medicare Beneficiary Identifiers (MBIs) when billing Medicare regardless of the date of service:

  • We will reject claims submitted with HICNs with a few exceptions

  • We will reject all eligibility transactions submitted with Health Insurance Claim Numbers (HICNs)

See the MLN Matters Article to learn how to get and use MBIs.
HOSPICE: Reminder--Physician Assistants as Hospice Attending Physician, Forum of States List Serve, November 1, 2019 – CMS will revise § 418.106(b)(1) to permit a hospice to accept drug orders from a physician, NP, or PA. The PA must be an individual acting within his or her state scope of practice requirements and hospice policy, and the PA must be the patient’s attending physician, and he or she may not have an employment or contractual arrangement with the hospice. The finalized changes to the hospice conditions of participation at § 418.106(b)(1) are effective January 1, 2020. 
Hospice: Senator Rosen: Remove Barriers to Hospice, Palliative Care, Hospice News, November 6, 2019--Stakeholders in the hospice space must work with policymakers to remove barriers that complicate patients’ access to care, according to Sen. Jackie Rosen (D-Nev.) — including the requirement for a six-month terminal prognosis.
HOME HEALTH and HOSPICE: 2ND REMINDER – OAHP & MyCare Ohio Plans Long-Term Care Provider Survey, OAHP – The MyCare Ohio Plans, which include Aetna, Buckeye, CareSource, Molina, and United Healthcare, are collaborating on an initiative to identify opportunities to reduce administrative burden for Long Term Care (LTC) providers. This is your chance to request changes to: the Prior Authorization process; plans not following payer of first resort; plans not following the Medicare regulations and Medicaid rules; providers not able to contract with plans; require all plans to standardize process; delayed reimbursement; receiving less than the Medicaid rate; etc. The survey will be open until November 14, 2019. Click here for more info and the link to the survey.
HOME HEALTH and HOSPICE: 2ND REMINDERCMS Pushes Effort to Curb Medicare Fraud, NAHC Report, October 25, 2019 CMS has also released two requests for information (RFI) to obtain input on how to advance their anti-fraud Medicare program. The first RFI, CMS asks for comments on using technology to improve anti-fraud activity and ease provider burdens. In the second RFI, CMS asks for feedback on their program integrity efforts.  Please submit your comments to Beth Foster at beth@ochch.org or to Kathy Royer at kathy@ochch.org by November 15, 2019.
HOME HEALTH and HOSPICE: Home Health and Hospice Agencies – In the November 5th Bulletin we had an article that promoted a partnership with Health Services Advisory Group (HSAG) to join CMS’ new initiative, Healthy Communities. A few days later on November 7th OCHCH received the following notice from Bonnie Hollopeter, Quality Improvement Task Lead for HSAG: “We were just informed that HSAG was not awarded the Ohio contract. If I have the opportunity to work for the new QIN-QIO, I will keep in touch. Thank you for your support over the years.” 
OCHCH will keep you informed on the Quality Innovation Network - Quality Improvement Organization (QIN-QIO) that that was awarded the Ohio contract.
HOSPICE and HOME HEALTH: HIPAA Eligibility Transaction System (HETS) Medicare Secondary Payer (MSP) Information, Palmetto GBA
HOSPICE and HOME HEALTH: ePass is Available to Ease the Burden of Repeated Authentication When Calling Palmetto GBA's Provider Contact Center, Palmetto GBA

HOME HEALTH: Local Coverage Determination (LCD) and Medical Coverage Database (MCD) Article Updates, Palmetto GBA – The Home Health Speech-Language Pathology L34563 HHH LCD was revised by removing all coding from the LCDs. There has been no change in the coverage with the LCD revision. The Billing and Coding was placed in the Home Health Speech-Language Pathology A53052 HHH MCD article. Please review these updates and share them with your staff.
HOSPICE and HOME HEALTH: Hospice and Home Health Claims Processing Issues Log, Palmetto GBA

Upcoming Education & Events


For Upcoming webinars, conferences, workshops and events click HERE

Click Here to Register!


News Clips & Links

HOSPICE: Emmanuel Hospice Unveils Virtual Reality Program, Hospice News, November 6, 2019


Ohio Council for Home Care & Hospice  1105 Schrock Rd., Suite 120, Columbus, OH 43229
(614) 885-0434   www.ochch.org