Bulletin: January 14th, 2020

January 14th, 2020



HOSPICE: Reminder—the Provider Self-Determined Aggregate Cap Limitation form is due March 2, 2020
  • Please click on the link below for updated instructions for the self-calculation and submission of the CAP.
  • The form is required of hospital-based and freestanding hospices for whom Palmetto GBA processes claims
  • If the form is not received timely, a past due letter will be issued and payments will be suspended
***  File soon so payments will not be suspended ***
HOSPICE: Hospice Licensure Rules Have Been Updated.  Effective January 23, 2020—The following Hospice licensure rules have been updated.  In general the changes impact the role of the Medical Director, inspection definitions and the Palliative Care patient admitted to the Hospice in patient unit.
3701-19-01 Definitions
3701-19-03 Initial license application process; renewal of license; and change of ownership license
3701-19-04 Issuance, denial, transfer, suspension, and revocation of licenses
3701-19-06 Governing body; quality assessment and performance improvement
3701-19-09 General requirements for hospice care program personnel
3701-19-10 Medical director
3701-19-11 Interdisciplinary team and interdisciplinary plan of care
3701-19-16 Home care services
3701-19-18 Counseling and bereavement services
3701-19-20 Admission of patients to the hospice care program
3701-19-22.1 Admission of non-hospice palliative care patients to hospice inpatient facilities
3701-19-23 Central clinical record
HOME HEALTH and HOSPICE: VA/Optum Referral Issue, Forum of States Discussion List January 9, 2020 , From Calvin McDaniels Directr of Government Affairs, NAHC--“We’ve recently received several reports of providers not being able receive referrals for VA patients with the recent transition from TriWest to Optum as the third part administrator for the VHA. Additional details here. NAHC has been in touch with the congressional committees overseeing this transition. They have asked for additional cases and examples of this occurring where veterans are not receiving necessary care. Please reply directly to me (cmcdaniel@nahc.org) if you have experienced this.
HOME HEALTH: CMS Open Door Forum Summary: Updates on iQIES Transition and Home Health, NAHC Report, January 10, 2020 – CMS held a Home Health Open Door Forum (ODF) on January 8, 2020.  This is list of the topics: iQIES Transition, PDGM Update, Home Health Quality Reporting Program, and Review Choice Demonstration (RCD).
HOME HEALTH: REMINDER: iQIES Issues Still Occurring – Call Keith Weaver, Ohio Dept. of Health Automation specialist, at 1-614-995-7898 or e-mail him keith.weaver@odh.ohio.gov.  Keith will assist you by trouble shooting. If he is unable to assist you he will find someone that can!
Keep Beth Foster informed of any issues with iQIES. The OCHCH Regulatory Department (Kathy Royer and Foster) are ready to assist you! PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, iQIES.
HOSPICE: CMS Open Door Forum Summary, NAHC Report, January 10, 2020—CMS held a Hospice Open Door Forum on January 8, 2020.  Topics covered include  Hospice Benefit Component of the Value Based Insurance Design (VBID) Model  and the Hospice Quality Reporting Program.
HOME HEALTH and HOSPICE: MAC Listening Sessions – Your Opportunity to Provide Feedback, NAHC Report, January 7, 2020 – CMS is holding listening sessions to gather feedback and improve experience with the Medicare Fee-For-Service (FFS) program. This is your opportunity to provide feedback on your MAC – Medicare Administrative Contractor. For home health and hospice there are three MACs: Palmetto GBA, CGS, and NGS.

>>>RCD UPDATES –                                                                                                                  

ATTENTION: Review Choice Demonstration (RCD) for Home Health Services Frequently Asked Questions (FAQs) JUST UPDATED!!!  Review the newly updated January 6, 2020!!!
The additional Q&As are in RED.
New and improved:

Pre-Claim Review Start of Care/Early Period Checklist

Pre-Claim Review Late Period Checklist 

PCR Resubmissions, Palmetto GBA –  When utilizing the PCR resubmission process, most of the fields are editable. There are however, a few fields that must match the initial request in order to determine if the resubmission is a true resubmission or if the request is for a different beneficiary, HHA, and/or period of time. Please review and share with your staff.
Next OCHCH Weekly RCD Conference Call - Friday, JANUARY 17, 2020 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 and into 2020 will remain the same:
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
ATTENTION: Check out the updated RCD Toolkit located in the members’ section of the OCHCH site. Just login to “My Profile” and in the left column under “HELP DESK ONLINE” click on “RCD Toolkit.”
The links to the RCD Call Recordings for the month of November and December and January are available in the RCD Toolkit.
Dial 855-696-0705
Press “0” at the main menu
Press “0” again
Press “3” for HHH
Press “1” for an RCD agent
REMINDER: 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” and include the UTNs, OR call 614-885-0434 Ext 209.
Monthly Review Choice Demonstration (RCD) Provider Teleconference Schedule – Next date is February 5, 2020.
Quarterly Review Choice Demonstration (RCD) Medical Review Teleconference Schedule – Next date is March 11, 2020.

PDGM and the Review Choice Demonstration (RCD)When PDGM starts, HHAs in the Pre-Claim Review (PCR) option will need to submit a PCR request for each 30-day period.
Important Information for all HHA in Review Choice Demonstration under PDGM, NAHC Report, January 2, 2020 – For those home health agencies (HHAs) that are part of the Review Choice Demonstration and have selected the Pre-claim Review (PCR) option, the long awaited CMS update confirming that HHAs will need to submit a PCR for each 30-day billing period has been posted. Make sure you review the updated RCD Operational Guide, Chapter 6.


OCHCH Weekly PDGM Conference Call is today, Tuesday, January 14, 2020 at 3pm.
DON’T MISS THIS OPPORTUNITY!! Please mark your calendars for EVERY TUESDAY @ 3pm. The calls will last no more than an hour.
Login – https://web.telspan.com/go/ochch/weeklypdgm
Dial: 888-392-4564
Enter: 1115130#
**This PDGM login/call-in information will be the same for each week**
If you have trouble getting on the Call – PLEASE CALL OCHCH 1-614-885-0434 Ext.206, or e-mail ryan@ochch.org
Check out the updated PDGM Toolkit located in the members’ section of the OCHCH site. Just login to “My Profile” and in the left column under “HELP DESK ONLINE” click on “PDGM Toolkit.”

If you have questions PLEASE contact OCHCH by using helpdesk@ochch.org and use subject title, “PDGM,” OR call 614-885-0434 Ext 209.

In addition to the weekly PDGM calls, Beth Foster and Kathy Royer have been and will continue to answer PDGM questions.
OCHCH has a number of recordings available on our website of previous PDGM education webinars for your purchase or access. Moving forward OCHCH is committed to bringing you continued education on the implementation of PDGM and its impacts on our industry.
The links to the PDGM Call Recordings for the month of December and January are available in the PDGM TOOLKIT.
The Home Health FAQs - Home Health Patient-Driven Groupings Model (PDGM) – (January 6th, 2020- link) was just posted to the PDGM TOOLKIT.
The following two webcasts were hosted by the MACs:
Recording of the Home Health Patient-Driven Groupings Model (PDGM) Webcast Part I: November 21, 2019 is available, but new viewers need to register to view it
Recording of the Home Health Patient-Driven Groupings Model (PDGM) Webcast Part Two: December 5, 2019 is available. Please share this information with your staff.

Payments and Payment Adjustments under the Patient-Driven Groupings Model, Palmetto GBA – This article provides information on the implementation of the new Home Health Prospective Payment System (HH PPS) case-mix adjustment methodology named the Patient-Driven Groupings Model (PDGM). The PDGM will be implemented for home health periods of care starting on and after January 1, 2020.  This MLN Matters Number: SE19028 is a very comprehensive tool to share with staff so they develop a better understanding of the PDGM.

OASIS Considerations for Medicare PDGM Patients – This document provides PDGM transition guidance for OASIS time points.
October 2019 CMS Quarterly OASIS Q&As – Please note that guidance Q&As related to PDGM will become effective with assessments with a M0090 date of January 1, 2020 or later. Pages 1 through 10 address PDGM related questions. 

Home Health Reminder and CMS Update to PDGM Split Implementation Instructions, NAHC Report, January 3, 2020

REMINDER: Home Health RAPs HoldMedicare Administrative Contractors (MACs) typically hold claims for a brief period each quarter when they implement system releases. This January, home health Requests for Anticipated Payment (RAPs) are affected by implementation of the Home Health Patient-Driven Groupings Model. MACs will hold RAPs with From Dates on or after January 1, 2020, and process them once the updates are complete.

INSTRUCTIONS: Change Request 11081 Home Health (HH) Patient-Driven Groupings Model (PDGM) -Split Implementation – On December 20, 2019 Transmittal 4482/Change Request (CR) 11081 was posted, replacing Transmittal 4244 from February 15, 2019. This new CR adds FISS as a responsible party to business requirement 11081.5.1 and adds a requirement and updates attachment 3 to facilitate handling claims with no matching assessment. Also, manual sections are updated to reflect changes made by subsequent transmittals for CRs 11272, 11527 and 11536. All other information remains the same. There is more detailed information in this CR to guide home health agencies in handling various claim situations under PDGM. (FYI - CMS needs to corrected the RAP percentage to state 20%/80%.)


Our Take

RCD Claim Approval Rate Calculations

Palmetto GBA has received questions regarding the claim approval rate calculation results while in the RCD.

Palmetto responded with - Please be reminded:
  1. There are NO recalculations for the RCD end of cycle results.
    OUR TAKE: This means the 6 month cycle results cannot be appealed or changed.
  2. Appeals and partial payments do not count towards your claim approval rate.
    OUR TAKE: Good to know!
  3. All initial decisions do apply toward your claim approval rate.
    OUR TAKE: Good to know! In PCR agencies can submit as many times as they want to until a final affirmation is received. In this case all of the non-affirmations do not count.
  4. The RCD ADR process is different from the TPE process. During the RCD ADR review process:
  • There are no easily curable telephone calls, and
  • The Medical Reviewer does not contact the HHA for missing documents
    OUR TAKE: Also, Good to know for the home health agencies (HHAs) that chose the postpayment review option that they need to respond to the ADR request with the correct documentation submitted the first time. HHAs will receive ADR requests for every claim submitted, which should be at least every 30 day pay period.

OUR TAKE: HHAs that selected postpayment review option and after the first 6 months received an approval rate of 90% or greater (based on a 10 request/claim minimum), might consider selecting from one of the three subsequent review choices:
• Choice 1: Pre-Claim Review (less paper work), or
• Choice 4: Selective Postpayment Review (more paper work)
(HHAs that select this choice will remain in this choice for the duration of the demonstration regardless of their claim approval rate), or
• Choice 5: Spot Check Review (Palmetto will select a random sample of 5% of a HHA’s submitted claims, based on their previous 6 months’ claim volume, for pre- payment review)
REMINDER: Ohio’s initial 6 month PCR/POSTPAYMENT review goes through March 31, 2020. Palmetto will spend April calculating the approval rates for each HHA. In May HHAs will be making a new option choice, if they want too.
Additional resources can be found on Palmetto’s website: www.palmettogba.com/rcd or on the CMS website.

If you need assistance, please contact Palmetto GBA’s Jurisdiction M Provider Contact Center at 855–696–0705.

Beth Foster, RN, BA, CPHQ, CEHCH

HelpDesk Question of the Week


HOSPICE:  Recertification
Question: We have a pt with  a third certification  date starting 1/3   Our medical director did the face to face on 12/12 and wrote the attestation on 1/3 is this permissible to have the attestation signed on the first day of the new certification period? 
Answer: Here is the guidance on recertification from the Hospice Medicare Benefit Policy Manual Chapter 9:
For the subsequent periods, recertifications may be completed up to 15 days before the next benefit period begins.  For subsequent periods, the hospice must obtain, no later than 2 calendar days after the first day of each period, a written certification statement from the medical director of the hospice or the physician member of the hospice’s IDG.  If the hospice cannot obtain written certification within 2 calendar days, it must obtain oral certification within 2 calendar days.  When making an oral certification, the certifying physician(s) should state that the patient is terminally ill, with a prognosis of 6 months or less.  Because oral certifications are an interim step sometimes needed while all the necessary documentation for the written certification is gathered, it is not necessary for the physician to sign the oral certification.  Hospice staff must make an appropriate entry in the patient's medical record as soon as they receive an oral certification.



Regulatory & Policy Digest


HOSPICE: Reminder--Hospice Provider Preview Reports Now Available, CMS, December 16, 2019 – Hospice provider preview reports and Hospice Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Survey ® provider preview reports have been updated and are now available. These two separate reports are available in your Certification and Survey Provider Enhanced Reports (CASPER) non-validation reports folder. Hospice providers are encouraged to review their Hospice Item Set (HIS) quality measure results from Quarter 2, 2018 to Quarter 1, 2019 and their facility-level CAHPS® survey results from Quarter 2, 2017 to Quarter 1, 2019.

Providers have 30-days to review their HIS and CAHPS® results (Decembe16, 2019 through January 15, 2020) prior to the February 2020 Hospice Compare site refresh, during which this data will be publicly displayed. 
Should a provider believe the denominator or other HIS quality metric to be inaccurate or if there are errors within the results from the CAHPS® Survey data, a provider may request CMS review. Providers must adhere to the process outlined on the Public Reporting: HIS Preview Reports and Requests for CMS Review of HIS Data webpage and the Public Reporting: CAHPS® Preview Reports and Requests for CMS Review of CAHPS® Data webpage.

HOSPICE: Hospice Quality Reporting Program News, CMS MLN Connects, January 9, 2020

View the December Hospice Quality Reporting Program (HQRP) outreach email (PDF) for information on:

  • Reporting for CY 2020

  • Quarterly update for the third quarter of 2019

  • November Hospice Compare refresh

  • Hospice Outcomes & Patient Evaluation (HOPE) tool

For more information, visit the HQRP Requirements and Best Practices webpage.
HOME HEALTH: Home Health Compare: Preview Reports for April Refresh, CMS – Certification and Survey Provider Enhanced Reports (CASPER) reports preview data that will be displayed on the Home Health Compare website in April:

  • Provider Preview Report

  • Quality of Patient Care Star Rating Preview Report

For More Information:

HOSPICE and HOME HEALTH: Provider Enrollment Application Fee Amount for CY 2020, - On November 12, CMS issued a notice: Provider Enrollment Application Fee Amount for Calendar Year 2020 [CMS–6089–N]. Effective January 1, 2020, the application fee is $595 for institutional providers that are:

  • Initially enrolling in the Medicare or Medicaid program or the Children's Health Insurance Program (CHIP)

  • Revalidating their Medicare, Medicaid, or CHIP enrollment

  • Adding a new Medicare practice location

This fee is required with any enrollment application submitted from January 1 through December 31, 2020.

HOSPICE and HOME HEALTH: Provider Contact Center (PCC) Frequently Asked Questions (FAQs): October 1, 2019 - December 31, 2019, Palmetto GBA  – Palmetto GBA is publishing these Quarterly Frequently Asked Questions (FAQs) based upon data analytics identifying topics generating a high volume of telephone inquiries between October 1, 2019, through December 31, 2019. We hope the answers to the questions below help you maximize your time by reducing your need to contact the Provider Contact Center (PCC). Please review this information and share it with your staff.

HOSPICE and HOME HEALTH: Reminder - Provider administrators must recertify user access per CMS requirements, Palmetto GBA – Why am I being asked to complete eServices recertification? Palmetto GBA and CMS are dedicated to ensuring that access to Medicare data is secure. To do this, CMS requires that all provider administrators recertify access for all of the users on the account. Please read this article to learn more.

HOME HEALTH and HOSPICE: CMS Quarterly Provider Update, Palmetto GBA

HOME HEALTH: Manual Updates Related to Calendar Year (CY) 2020 Home Health Payment Policy Changes, Maintenance Therapy, and Remote Patient Monitoring, Palmetto GBA

HOME HEALTH and HOSPICE: Submitting the Credit Balance (838) Report and Due Dates by January 30, 2020. Palmetto GBA
HOME HEALTH and HOSPICE: January 2020 Integrated Outpatient Code Editor (I/OCE) Specifications Version 21.0, Palmetto GBA
HOME HEALTH and HOSPICE: C-ACE Pro32 Version 4.5 Update File, Palmetto GBA

HOME HEALTH and HOSPICE: New Medicare Beneficiary Identifier (MBI) Get It, Use It, Palmetto GBA 

HOSPICE and HOME HEALTH: eTicket Enables Providers to Save Time with Every Call , Palmetto GBA 

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

The dates are set for the 2020 Annual Conference!  Get extra socks, because we are going to knock them off again!

Save the Date: September 22nd and 23rd at the Hyatt Regency in Columbus, Ohio!

News Clips & Links

PALLIATIVE CARE: Medicare Advantage Plans Offering Palliative Care Quadrupled for 2020, Hospice News, January 13, 2020
PALLIATIVE CARE: Palliative Care Well-Poised to Address Social Determinants of Health, Hospice News, January 13, 2020

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