Bulletin: March 10th, 2020

March 10th, 2020



HOME HEALTH and HOSPICE: COVID-19 Response: CMS Issues FAQs to Assist Medicare Providers, CMS MLN List Serve, March 9, 2020 – On March 6, CMS issued frequently asked questions and answers (FAQs) for health care providers regarding Medicare payment for laboratory tests and other services related to the 2019-Novel Coronavirus (COVID-19). The agency is receiving questions from providers and created this document to be transparent and share answers to some of the most common questions.

Included in the FAQs is:

  • Guidance on how to bill and receive payment for testing patients at risk of COVID-19.

  • Details of Medicare’s payment policies for laboratory and diagnostic services, drugs, and vaccines under Medicare Part B, ambulance services, and other medical services delivered by physicians, hospitals, and facilities accepting government resources.

  • Information on billing for telehealth or in-home provider services. Since 2019, the Trump Administration has expanded flexibilities for CMS to pay providers for virtual check-ins and other digital communications with patients, which will make it easier for sick patients to stay home and lower the risk of spreading the infection.

HOME HEALTH and HOSPICE: CMS Develops Additional Code for Coronavirus Lab Tests,  CMS List Serve, March 5, 2020 – The Centers for Medicare & Medicaid Services (CMS) recently took additional actions to ensure America’s patients, healthcare facilities and clinical laboratories are prepared to respond to the 2019-Novel Coronavirus (COVID-19). 
CMS has developed a second Healthcare Common Procedure Coding System (HCPCS) code that can be used by laboratories to bill for certain COVID-19 diagnostic tests to help increase testing and track new cases. In addition, CMS released new fact sheets that explain Medicare, Medicaid, Children’s Health Insurance Program, and Individual and Small Group Market Private Insurance coverage for services to help patients prepare as well. 
HOSPICE: Program Integrity Manual Updated for Identity Theft and Hospice Aggregate Cap Liability, NAHC Report, March 6, 2020 The Centers for Medicare & Medicaid Services (CMS) recently released a new transmittal that updates the chapter of the Program Integrity Manual to address coordination between Medicare Administrative Contractors (MAC) and Unified Program Integrity Contractors (UPIC) in situations of hospice aggregate cap liabilities, as well as addressing Medicare liabilities in situations of provider identity theft.
HOME HEALTH: CMS Proposes New Medicare Cost Report Form for Home Health Agencies, NAHC Report, March 3, 2020 – A special NAHC Report from Dave Macke, Shareholder, CHFP, FHFMA, and a member of OCHCH.
CMS originally issued a proposed rule on April 16, 2019, to change the Medicare cost report form set for home health agencies. This notice provided for an original 60 day comment period. On February 24, 2020, the CMS issued a revised notice of proposed home health cost report forms and provides for a second 30 day comment period. Comments must be received by the CMS no later than March 25, 2020. The CMS made some significant changes to the original notice.
The new forms will be known as the CMS Form 1728-19. The proposed changes were originally intended to be effective for cost reporting periods beginning on or after January 1, 2019 and ending on or after December 31, 2019. The revised effective date was changed to be effective for cost reporting periods beginning on or after July 1, 2019 and ending on or after June 30, 2020. Therefore some agencies are eight months into the affected cost reporting period and the new forms are still not yet final. We recommend that agencies implement these latest changes immediately as we do not anticipate many, if any changes during this second round of comments. Click here to read Dave’s summary of the most significant proposed changes.

>>>RCD & PDGM Needs–                                                                                                          

OPERATION: tackle is OCHCH’s campaign that supports your agency’s PDGM & RCD needs.

DON’T MISS THIS OPPORTUNITY!! Please mark your calendars for EVERY FRIDAY @ 10am. The calls will last no more than an hour.
The first part of the call will be information on “Therapy and PDGM” presented by Mike Carr from Axxess.
The last part of the call will be spent on RCD updates and Q&As.
**ATTENTION: For the OCHCH WEEKLY PDGM/RCD CALL we have set up a NEW way to Call-in through ZOOM!!!
Join from a PC, Mac, iPad, iPhone or Android device:
Please click this URL to join. https://zoom.us/j/912545089?pwd=RDg4ZTZ2VWQ4NTN4VC95cXlxR3VoQT09
Password: 814935 Description: Weekly PDGM and RCD call.
Or join by phone:
Dial:US: +1 929 205 6099 
Webinar ID: 912 545 089
**The call-in number WILL CHANGE EVERY WEEK!!!  PLEASE check every week for the new number!!!
If you have trouble getting on the Call – PLEASE CALL OCHCH 1-614-885-0434 Ext.206, or e-mail ryan@ochch.org


>>>RCD UPDATES –                                                                                                                  

Transition from Cycle 1 to Cycle 2 – What you need to know! Ohio Home Health providers are nearing the end of the first cycle of RCD. We wanted to update you on important information on the transition from Cycle 1 to Cycle 2.
FYI - How to Retrieve Your RCD Affirmation Rate and Claims Approval RateCLICK HERE

eRCD is Now Active - eRCD is a new feature on the Provider Dashboard within eServices that provides you with the ability to monitor your Review Choice Demonstration (RCD) results. You will enjoy features such as your RCD affirmation or claim approval rate, and current Additional Documentation Request (ADR) and Pre-Claim Review (PCR) decisions.


eServices: Inbox Filtering Feature Refines Review Choice Demonstration (RCD) for Home Health Services Search

Pre-Claim Review (PCR) and Low Utilization Payment Adjustments (LUPAs), Palmetto GBA updated  March 1, 2020 – With the transition to the Home Health Patient-Driven Groupings Model (PDGM), CMS will phase in the inclusion of LUPAs within the Review Choice Demonstration. Please review and share with your staff.
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 months of November, December, January, and February 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.
Palmetto GBA Will Offer Open-Door Teleconferences on the Review Choice Demonstration: March 13, 2020
Monthly Review Choice Demonstration (RCD) Provider Teleconference Schedule – Next date is April 1, 2020.

Quarterly Review Choice Demonstration (RCD) Medical Review Teleconference Schedule – Next date is Tommorrow March 11, 2020.
Unique Tracking Number (UTN) Location on the Final Claim, Palmetto GBA – This job aid instructs providers on where to enter the 14 digit alpha-numeric unique tracking number (UTN) provided in the PCR notification on the final claim for Electronic claims, Data Entry or the UB04 Claim Form. Please share with appropriate staff



NEW TOOLS – MLN Matters Articles:

The Role of Therapy under the Home Health Patient-Driven Groupings Model (PDGM) - This article provides information on the continuing role of therapy under the newly implemented home health prospective payment system (HH PPS) case-mix adjustment methodology, named the Patient-Driven Groupings Model (PDGM), for home health periods of care starting on and after January 1, 2020.

A new MLN Matters Article MM11656 on Update to the Home Health Grouper for New Diagnosis Code for Vaping Related Disorder (PDF) is available. Learn about diagnosis code U07.0.
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.
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, January, and February are available in the PDGM TOOLKIT.
Patient-Driven Groupings Model (PDGM) Grouping Tool Help Document link – The purpose of the grouping tool Excel file is to help users understand how the payment grouping parameters, which are part of the PDGM, would be used to determine case-mix assignments that are part of the payment calculation under the Home Health Prospective Payment System (HH PPS).  

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.

Our Take

By Beth Foster, RN, BA, CPHQ, CEHCH and
Kathy Royer, RN, BA, MBA, DMin, CHPN, CHPCA, CEHCH
What does ODH have that we need?

The Ohio Department of Health (ODH) has a special website (COVID-19 Resources for Local Health Districts and Providers) that has a lot of resources that covers every aspect of this outbreak. If an individual thinks they may have the coronavirus because they have a fever, cough, and difficulty breathing, they need to call their primary care practitioner (PCP) as soon as possible. The individual should follow the guidance of the PCP.
Also, ODH has a special phone line 1-833-4ASK ODH.

Ohio home health and hospice agencies should work with their local health district if and when they suspect that an individual may have the symptoms of the coronavirus. This is the link to Find Local Health Districts near you.


Reminder: Since facilities (aka home health and hospice agencies) are expected to develop and maintain an emergency preparedness plan that is based on the facility‐based and community‐based risk assessment using an “all‐ hazards” approach, Kathy and I recommend that agencies pull out your emergency preparedness plan and review your approach with your staff. It would not surprise us if an ODH surveyor asks your staff, “What are you doing to protect yourself and patients from COVID-19.” Remember to add Corona virus to your all hazards list!



Beth Foster, RN, BA, CPHQ, CEHCH and Kathy Royer, RN, BA, MBA, DMin, CHPN, CHPCA, CEHCH


HelpDesk Question of the Week

  HOSPICE: Discharge
Question: We are trying to understand what codes are required to be used when discharging patients (live) from hospice for certain situations.  Please help clarify:
  • A patient is discharged when they become Medicare eligible so they can be readmitted with the proper payer/benefit period.  (To me this seems like a revocation?? So the patient can now use their benefit to pay for hospice services)
The COPS describe very limited opportunities and it is sometimes a challenge to know which to use.  Is there any information available regarding what code to use in unusual situations?
Answer: If a patient has been a hospice patient and then becomes eligible for Medicare you will do a full admission complete with signature on the NOE so the Hospice Medicare Benefit can begin. Medicare does not have any guidance on what discharge code to use when the patient becomes eligible for Medicare because it is actually a discharge out of your EMR so you can admit and start the Medicare benefit periods. Revocation is the closest form of discharge to serve this purpose.




Regulatory & Policy Digest


HOME HEALTH and HOSPICE: CMS Offers Guidance and Makes Announcements Regarding Coronavirus, Strategic Health Care, March 9, 2020 – CMS announced that, effective immediately and, until further notice, State Survey Agencies and Accrediting Organizations will focus their facility inspections exclusively on issues related to infection control and other serious health and safety threats, like allegations of abuse – beginning with nursing homes and hospitals. Click here. The agency released guidance for infection control and prevention through FAQs and considerations for patient triage, placement and hospital discharge. Click here. CMS offered specific guidance for nursing homes for infection control and prevention of the virus, click here. CMS developed a second Healthcare Common Procedure Coding System (HCPCS) code that can be used by laboratories to bill for certain COVID-19 diagnostic tests to help increase testing and track new cases, click here.
HOME HEALTH and HOSPICE: CMS Updates State Operations Manual Appendices, NAHC Report, March 5, 2020 – The Centers for Medicare & Medicaid Services (CMS) updated the appendices of the State Operations Manual (SOM) to include regulatory revisions based on recent federal regulation changes that are part of the Omnibus Burden Reduction (CMS-3346-F; CMS-3334-F; CMS3295-F; CMS3277-CN). The SOM updates are found in the applicable Appendix for each provider type – Appendix B for home health agencies (Pages 158-161), Appendix M for hospices (Pages 337-338), and Appendix Z for Emergency Preparedness (not updated yet).

HOSPICE: Hospice Quality Reporting Program: Timeliness Compliance Threshold for HIS Submissions, CMS MLN Connects, March 5, 2020 – CMS posted an updated fact sheet (PDF) on the timeliness compliance threshold for Hospice Item Set (HIS) submissions, including policies finalized in the FY 2016 final rule and a preliminary algorithm for the calculation. Visit the HIS webpage for more information.

HOSPICE: CMS Revises Safeguards for Medicare Patients in Hospice Care Fact Sheet, NAHC Report, March 4, 2020 As reported at the beginning of February, the Centers for Medicare & Medicaid Services (CMS) posted a MLN Hospice Fact Sheet, Safeguards for Medicare Patients in Hospice Care, and NAHC communicated with CMS regarding our concerns about some of the fact sheet’s contents. Specifically, a reference to the Long Term Care Ombudsman as a resource for patients when this type of Ombudsman does not have authority to assist hospice patients not residing in long term care facilities. Additionally, NAHC is concerned that the list of examples of potential neglect by a hospice included some examples that may not be neglect by a hospice or it is unclear if some of the listed examples would constitute neglect.

HOME HEALTH: PDGM in Real Time Webinar SeriesIt is not too late to participate! NAHC is pleased to present a series of six free webinars that address a variety of PDGM-essential topics, combined with an open forum where participants share and gain insights with Home Care & Hospice Financial Managers Association (HHFMA) experts about what is working and not working in the early weeks of PDGM. Register now to receive access to both the live and recorded webinars.

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 image to find out more!

News Clips & Links

HOME HEALTH and HOSPICE: $8.3 Billion Coronavirus Funding Bill Signed by the President, Strategic Health Care, March 9, 2020 – A sweeping emergency funding package containing $8.3 billion to support efforts against the 2019-Novel Coronavirus (COVID-19) is mostly targeted towards state agencies to provide funds for local providers. In addition to funding for infectious disease control and vaccines and prescription drugs, the bill also funds some construction and renovation of facilities to enhance the response. Funds will be distributed through state and local authorities. Providers should contact their state and local health departments. The new law also allows HHS to waive certain Medicare telehealth restrictions and allows providers to furnish telehealth services to Medicare beneficiaries outside of rural communities. Click here for the summary of the emergency appropriations package, and here for the Congressional Budget Office analysis. 
HOME HEALTH and HOSPICE: MedPAC Says Some ACOs Are Gaming the System, Strategic Health Care, March 9, 2020 – Accountable Care Organizations may be purposefully removing clinicians with high-cost patients and bringing in clinicians with low-cost patients without adjusting their benchmark rates, according to Medicare Payment Advisory Commission staff briefing. Under the program, if the ACO performance year spending is less than the agreed-upon benchmark, then there will be shared savings between the ACO and Medicare. MedPAC says the growing risk of unwarranted shared savings payments to ACOs may put Medicare savings at risk.  Currently, CMS calculates the benchmark based on the clinicians' taxpayer identification number and does not calculate benchmark changes in the national provider identifiers billing; however, a clinician can switch which TIN to bill under - resulting in unwarranted savings. MedPAC will vote in April on a recommendation to use the same set of NPIs to compute both performance year and baseline spending. For the full MedPAC presentation, click here
HOME HEALTH and Hospice: Infant-Toddler Wellness Campaign Looks to Boost Child Care, Home Visiting Access, The Hannah Report, February 26, 2020 – Health, child care, policy and philanthropic groups launched a child wellness campaign on February 26 to back policies for expanding access to services they say are needed to help Ohio's infants and toddlers, particularly those living in poverty, gain strong footing for life. Spearheaded by Groundwork Ohio and supported by dozens of organizations across the state, "Ready, Set Soar Ohio" focuses on promoting policies to aid child development from gestation through age 3, when the bulk of brain development takes place -- and when the seeds of future learning and health disparities often are planted, especially for the quarter of young Ohio children who live in poverty.
HOME HEALTH and HOSPICE: Coronavirus Scare Likely to Boost Telehealth Adoption Among Home-Based Care Providers, HOME HEALTH CARE NEWS, March 9, 2020
PALLIATIVE CARE: Palliative Care Data Collaborative Aims to Improve Quality, Hospice News, March 4, 2020
PALLIATIVE CARE and HOSPICE: Staffing a Barrier to Palliative Care Growth, Hospice News, March 4, 2020
HOSPICE: Hospices Contend with Drug Diversion, Hospice News, March 9, 2020
HOSPICE: Pennant Group Anticipates Strong Hospice Growth in 2020, Hospice News, March 9, 2020


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