Bulletin: April 21st, 2020

April 21st, 2020


COVID-19 Resource Center

HOSPICE: Non-Cancer Length of Stay (NCLOS) Rates, Palmetto GBA, April 16, 2020--This electronic Comparative Billing Report (eCBR) focuses on Non-Cancer Length of Stay (NCLOS) rates from October 1, 2019, to March 31, 2020. 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: Hospice Payment Rate Update Proposed Rule for FY 2021, CMS MLN Connects, April 16, 2020--On April 10, CMS issued a proposed rule (CMS-1733-P) that would update FY 2021 Medicare payment rates and the wage index for hospices serving Medicare beneficiaries. This rule provides model examples of the hospice election statement and the hospice election statement addendum that reflect the changes finalized in the FY 2020 hospice final rule for elections on or after October 1, 2020.

For More Information: HOSPICE: Hospice Coalition Questions and Answers, Palmetto GBA, April 16, 2020--The February 13, 2020, Hospice Coalition Questions and Answers are now available. Please review and share this information with your staff.
HOSPICE: Calls Grow Louder to Delay Hospice Medicare Advantage Carve-In, Hospice News, April 17, 2020--Stakeholders in the hospice space are calling on the U.S. Centers for Medicare & Medicaid Services (CMS)  to delay the inclusion of hospice in the agency’s value-based insurance design model, commonly called the Medicare Advantage hospice carve-in, on the grounds that providers will not be able to prepare due to the pressures brought on by the ongoing pandemic.
HOME HEALTH: RAP Auto Cancellation Extension Confirmed, Palmetto GBA – Part of the 1135 waivers that CMS approved for home health allowed the Medicare MACs to extend the amount of time that agencies would have to get a final claim filed without the RAP auto cancelling and being taken back. The following is from the Palmetto GBA website: As stated in MLN Matters Number SE20011, Medicare Administrative Contractors (MACs) are allowed to extend the auto-cancellation date of Requests for Anticipated Payment (RAPs). Palmetto GBA has extended the auto-cancel timeframe of RAPs by 90 days from the paid date of the RAP, retroactive to March 1, 2020. This means 150 days from the date the RAP is paid. The normal is 60 from the date it is paid and they have added 90.
HOME HEALTH: What Has Changed for Home Health During the Public Health Emergency?, NAHC Report, April 10, 2020 – On March 30, 2020, CMS issued an interim final rule with comment (IFC) that provides relief from regulations governing health care provider operations in response to the COVID -19 pandemic. NAHC has completed three sets of frequently asked questions and answers (FAQs) on the topics of: Telehealth; Non-physician practitioners (NPPs) certifying and ordering home health services, and Waivers on the Conditions of Participation.
HOME HEALTH: ODA and ODM Response to COVID- 19: Updated April 13, 2020 - The Department of Aging (ODA) and the Department of Medicaid (ODM) provided initial guidance to implement emergency protocols as part of the State’s response to COVID-19. This is a companion document to answer specific questions. All guidance and protocols must be forwarded and shared with all appropriate staff. Please note, this is intended to be a living document and will be updated periodically.
HOME HEALTH and HOSPICE: COVID-19 Managed Care Plan Emergency Provisions April 9, 2020 – The Ohio Department of Medicaid (ODM), in collaboration with the Medicaid Managed Care Plans (MCPs) and MyCare Ohio Plans (MCOPs), has implemented emergency provider agreement changes affecting pharmacy benefits, telehealth services and service authorization requirements. These changes are intended to remove barriers to care, and to safeguard individual health and wellbeing while reducing burdens on Medicaid providers.
A few changes that affect HH and Hospice are:
  • MCPs and MCOPs are extending timely filing limits to accept claims from all provider types for up to 365 calendar days from the date of service.
  • Effective March 27, 2020, ODM managed care plans will defer medical necessity determinations to providers; and
  • No authorization is required

>>>RCD/PDGM UPDATES –                                                                                                                  

If you have PDGM or RCD QUESTIONS PLEASE SEND THEM TO helpdesk@ochch.org
Use PDGM or RCD as the subject title.
If you need OCHCH to contact Palmetto GBA regarding a PCR NON-AFFIRMATION,
Please e-mail a short description and the UTN and your provider number.
DO NOT e-mail any info that could be non-compliant with the HIPAA regulations
Please check out the toolkits for PDGM and also RCD!
>>>RCD UPDATES –                                                                                                                  

RCD Tip: Using the Correct Provider Transaction Access Number (PTAN), Palmetto GBA – If you are a part of a Home Health Agency (HHA) with more than one location and multiple PTANs, please make sure you are using the correct PTAN when submitting Pre-claim Review (PCR) requests.

RCD for Ohios Home Health Services Has Been PAUSED

Ohio Providers Transition to Review Choice Demonstration (RCD) Cycle Two, Palmetto GBABeginning May 1, 2020, you will be able to choose the next round’s review option. Typically, the selection period is open for a two-week period. Due to the current Public Health Emergency (PHE) related to COVID-19, the last day to make a selection has not yet been determined. Palmetto GBA will announce the last day to make a selection as soon as possible on our website and via email update. If you are not signed up for the Palmetto GBA email updates, please visit https://tinyurl.com/GetListserv to sign up.

Save the date for a WEBINAR – “Ohio Providers Transition to Review Choice Demonstration (RCD) Cycle Two by Palmetto GBA, Friday, May 1, 2020 – 10am-11:30am

Our Take

OUR TAKE: Ohio’s COVID-19 Response Is Complicated but Sends a Simple Message: Home Health Is NOT A Priority
Over the past couple of weeks the State of Ohio has released more detail on its response to COVID-19, and boy is it detailed. The state aims to prevent the hospitals from being overwhelmed by creating more bed capacity, including creating new beds within skilled nursing facilities that are being called “health care isolation centers.”
The state has also divided Ohio geographically into three separate “zones” within which the major hospital systems are coordinating care with the isolation centers and health departments. The graph that shows how this will all work resembles more of Charlotte’s Web than a workable schematic to manage patients.

The detail doesn’t stop there. The pre-surge planning tool kit created by the state outlines how this will all work and includes a triage protocol, forms, processes, procedures, graphs, bells, whistles, and everything else but the kitchen sink. Unfortunately, in this case the kitchen sink is home health.
Despite all the detail in these plans, a simple message emerges that ironically confirms what the amazing people in home and community-based services have long thought: home health is NOT a priority in Ohio. If Medicaid funding is holding steady at 1998 levels didn’t convince you, take a look at the pre-surge planning toolkit. It’s right there clear as day. Home health and hospice is a patient source for hospitals and facility-based care, not the contrary, and certainly not the solution to congregate endangerment.
Please don’t misunderstand. This isn’t an indictment of the state’s work here. It’s clear that a lot of good people put a lot of time into this planning. We know that the talented people in the DeWine Administration have had their hands full dealing with a sickness that hasn’t been seen in over 100 years. This is simply an acknowledgement of reality.
To be fair, ODM Director Maureen Corcoran has done a great deal to support our industry’s requests. We’ve gotten flexibility on EVV, telehealth capabilities, priority status for PPE at local EMAs, and a myriad of other flexibilities given to Medicare providers. OCHCH is even being included in long-term care discussions alongside facility-based care despite not being part of the formal state plans. In fact, the only thing we haven’t gotten is COVID-19 testing capabilities and more funding.
Look, the state would not agree with my characterization of home health’s priority status. They would say that the focus on institutional care is simply because congregate settings are being the hardest hit. While that is true, it’s also true that this plan was constructed before they knew an issue with congregate settings existed. Whatever the case, it’s difficult to see any scenario where home and community-based services are a priority and facility-based care is not a priority, even one where home care and hospice providers and patients are the hardest hit.
We were never going to be a priority. We don’t need fancy modeling to tell us this. We were never going to be a priority because the general public and policy makers don’t know how our system works, don’t know the value we bring to the health care system. I can’t be the only person asking why we’re not using the health care delivery system that keeps people out of facilities if congregate settings is our biggest COVID-19 problem.
We have been relentless from day-one trying to get our members what they need to fight COVID-19, and to champion the ability to address the state’s issues when we have the right resources. Unfortunately, considerations to include home health as a solution for the state have only just begun. This upsets me and I hope it upsets you too.
While I’ve spent the better part of a month toiling over why, I’ve come to the conclusion that it doesn’t matter why. It is what it is. All that matters is what we’re going to do about it. Our industry must come together and educate people about home and community-based services so that we’re a priority for the State of Ohio policy makers moving forward. 

Download Flow Chart


Joe Russell, Executive Director, Ohio Council for Home Care and Hospice

HelpDesk Question of the Week


HOME HEALTH and HOSPICE: Questions About COVID-19
Question: Hi I am looking for COVID stats on individual counties.  Do you have a resource for this?
Answer: The Ohio Department of Health has statistics by county. Click on this link: www.Coronavirus.ohio.gov  and then click on the “Covid-19 Ohio Dashboard.”  Hover over the county and the statistical data is displayed. 


Regulatory & Policy Digest


HOME HEALTH and HOSPICE Medicare Quarterly Updates, Changes and Reminders Webcast - Wednesday, April 22 at 1 p.m. ET. , Palmetto GBA – Join Palmetto GBA for the Home Health and Hospice (HH&H) Medicare Quarterly Updates, Changes and Reminders Webcast on April 22, 2020, at 1 p.m. ET. This 60-minute webcast is designed to provide pertinent updates, changes and reminders to assist the provider community in staying compliant with Medicare rules and regulations for HH&H and will include new billing regulations and hot topics that impact provider billing.

HOME HEALTH and HOSPICE: Credit Balance Reporting Extension Information for Quarter Ending March 31, 2020, Palmetto GBA – In light of the challenges providers are facing with the COVID-19 pandemic, Palmetto GBA is extending the due date for the March 31, 2020, credit balance reports by 90 days. This extension will allow providers to submit their March 31, 2020, reports along with their June 30, 2020, credit balance reports. All credit balance reports for the March 31, 2020, and June 30, 2020, quarter ends will be due on July 30, 2020. Extending the due date will delay the mailing of the first quarter delinquency letters and 100 percent withholding until after July 30, 2020. Please review this information and share it with your staff.

HOSPICE: Hospice Caps Job Aid, Palmetto GBA, April 21, 2020--This job aid explains the two caps that affect Medicare payments under the hospice benefit. Please review and share this information with your staff.
HOSPICE: CMS: Care Planning, Hospice Aide Services Top Survey Deficiencies  Hospice News, April 17, 2020--Issues related to care planning and hospice aide and homemaker services topped the list of most common deficiencies found during regulatory surveys during 2019, according to the U.S. Centers for Medicare & Medicaid Services (CMS). 
HOSPICE: CMS Announces Final Hospice Capitation Rates for MA 2021 VBID Model, NHPCO NewsBriefs April 16, 2020--On April 15, CMS released the 2021 Hospice Capitation Ratebook and Actuarial Methodology, finalizing the CY 2021 hospice capitation rates for the Value-Based Insurance Design (VBID) model. In addition to a few technical corrections, the CY 2021 Gross National Composite Rate increased by 0.6%. OCHCH will be sending out additional details soon.
HOSPICE: Hospices Encounter Barriers to Safe Opioid Disposal, Hospice News, April 17, 2020--A number of hospices nationwide are hitting barriers to effectively disposing of medications following a patient’s death while remaining in compliance with current law and regulation, according to a report released today by the U.S. Government Accountability Office (GAO). Proper disposal of medications is a critical factor to preventing drug diversion. 
HOSPICE: Hospices Can’t Use Telehealth for SIA Cliams During Pandemic, Hospice News, April 9, 2020
HOME HEALTH: Ensure Required Patient Assessment Information for Home Health Claims, Palmetto GBA – Special Edition (SE) article SE20010 reminds Home Health Agency (HHA) providers what steps need to be taken to make sure claims match the corresponding Outcome and Assessment Information Set (OASIS) assessment successfully. Be sure your billing staff is aware of this information.

HOME HEALTH: COVID-19 Accelerated Payment Hotline FAQs, Palmetto GBA

HOME HEALTH: iQIES File Issue Causes Claims to RTP with Reason Code 37253, Palmetto GBA 

Education & Events


For Upcoming webinars, conferences, workshops and events click HERE

Click image to find out more!

News Clips & Links

HOME HEALTH and HOSPICE: How to Lead Through a Crisis, Center for Creative Leadership  

HOSPICE: Hospices Face Ethical Dilemmas During the COVID-19 Pandemic, Hospice News, April 14, 2020
HOSPICE: Hospice Providers Quickly Opening Inpatient Units for COVID-19 Patients, Hospice News, April 20, 2020
HOSPICE: Hospices Hurting from Diminished Fundraising, Philanthropy, Hospice News, April 20, 2020

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