The Centers for Medicare and Medicaid Services (CMS) held a Home Health, Hospice, and DME Open Door Forum on November 9, 2022. What follows is a summary of the relevant ODF content for home health and hospice providers. HOME HEALTH CMS began the Forum with a summary of the CY 2023 Home Health Prospective Payment…
The Centers for Medicare & Medicaid Services recently posted the Hospice Outreach Email for June and it contains reminders and updates on the various Medicare hospice quality reporting program (HQRP) activities. There are two reminders hospices should take note of.
- Upcoming Reconsideration Period for the Fiscal Year (FY) 2023 HQRP
Data submitted in 2021 impacts the FY 2023 annual payment update (APU). If your hospice did not meet the reporting requirements in CY 2021 and will be subject to the FY 2023 APU penalty of 2%, the Centers for Medicare & Medicaid Services (CMS) will notify you in two ways:
- A notification from your Medicare Administrative Contractor (MAC) and
- A notification in your facility’s Certification and Survey Provider Enhanced Reports (CASPER) folder.
The notifications will be distributed on July 12, 2022 and will include instructions for submitting a reconsideration. There is a 30-day timeframe for filing the reconsideration request. For more information on your right to request a reconsideration and the CMS reconsideration process, please visit the Hospice Reconsideration Requests webpage.
- FY 2024 Hospice Quality Reporting Reminder
Hospice quality reporting data submitted in CY 2022 data, starting on January 1, 2022 impacts FY 2024 payments. Beginning with FY 2024, the APU penalty doubles, going from 2% to 4%, for hospices not meeting the HQRP requirements. To ensure hospices achieve the full APU, be certain to meet the quality reporting requirements for data submission in CY 2022:
|Annual Payment Update||HIS||CAHPS|
|FY2024||Submit at least 90 percent of all HIS records within 30 days of the event date (patient’s admission or discharge) for patient admissions/discharges occurring 1/1/22 – 12/31/22.||Ongoing monthly participation in the Hospice CAHPS survey 1/1/2022 – 12/31/2022|
Most hospices that receive the APU penalty do so because of noncompliance with the Hospice Item Set (HIS) submission requirements. This frequently occurs during changes in EHR systems and changes in staffing so hospices should be sure to confirm submission of the HIS timely by downloading the Final Validation Reports. This report identifies HIS submissions received by CMS, and this receipt must occur in order for the hospice to receive “credit” for having submitted the HIS.
The Centers for Medicare & Medicaid Services recently posted the Hospice Outreach Email for June and it contains reminders and updates on the various Medicare hospice quality reporting program (HQRP) activities. There are two reminders hospices should take note of. Upcoming Reconsideration Period for the Fiscal Year (FY) 2023 HQRP Data submitted in 2021 impacts the FY…
Prior to the COVID-19 Public Health Emergency (PHE) many hospice providers had significant success with use of technology-based visits; however, there were a number of hospices that did not utilize technologies to their fullest extent because they believed they were required to provide all visits in-person. Early in the PHE, the Centers for Medicare & Medicaid Services (CMS) communicated that hospices are permitted to use telecommunications technologies to deliver hospice visits provided that such visits and technologies are specified by the Interdisciplinary Team (IDT) on the plan of care and that the goals of care (as outlined) are met.
In response to CMS’ clarification, hospice providers throughout the nation began to utilize technology more broadly in hospice care delivery, and found that, when used appropriately, this mode of care can provide substantial benefits to patients, family members, and hospice staff. However, CMS instructed hospices to not report these visits on hospice claims, which raised significant concern that CMS would not have accurate information on the full scope of services being provided to hospice patients, and that CMS and others would have no way of determining the impact that use of telecommunications technologies has on the quality of hospice care. The National Association for Home Care & Hospice (NAHC) has communicated to CMS a number of times since the start of the PHE that data on hospice “virtual” visits should be collected.
On a related matter, CMS has never required collection of data on chaplain visits on hospice claims, although previously, when the Hospice Item Set (HIS) data was directly submitted by hospice organizations and CMS gathered date for the Hospice Visits When Death is Imminent (HVDII) measure pair, the number of chaplain visits delivered during the last seven days of life was collected. The HVDII measure pair has been replaced with a claims-based measure (Hospice Visits in the Last Days of Life), which does not assess chaplain visits. As chaplains are essential members of the hospice IDT and the provision of chaplain services is a distinguishing element of the hospice benefit, NAHC and others have strongly urged CMS to collect data on chaplain visits on claims.
During the January 2022 meeting of the Medicare Payment Advisory Commission (MedPAC), the Commission approved a recommendation that the Secretary of Health & Human Services collect data on telehealth visits going forward as long as the agency permits telehealth visits in hospice. In putting forth the recommendation for the MedPAC March 2022 Report to Congress, Commission staff noted that, “Requiring hospices to report telehealth visits would increase the program’s ability to monitor beneficiary access to care.” MedPAC’s recent action prompted the national hospice associations (NAHC, NHPCO, LeadingAge, and NPHI) to join together in a letter to CMS Administrator Chiquita Brooks-LaSure urging that CMS:
- Implement a modifier or HCPCS code and create a field on the hospice claim for telehealth visits from any discipline, to more accurately represent the full range of visits that hospices provide
- Take the necessary steps to establish a HCPCS code specifically for chaplains in hospice and require reporting of chaplain visits on claims
The full letter to Administrator Brooks-LaSure is available HERE. NAHC will provide updates on this and related issues in future issues of NAHC Report.
Prior to the COVID-19 Public Health Emergency (PHE) many hospice providers had significant success with use of technology-based visits; however, there were a number of hospices that did not utilize technologies to their fullest extent because they believed they were required to provide all visits in-person. Early in the PHE, the Centers for Medicare &…
- CAHPS Star Rating
- CASPER toolkit
- HIS, HCI, HVLDL
A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview. Stay tuned to NAHC Report for member resources on the CAHPS Hospice Survey Star Rating.
The Centers for Medicare & Medicaid Services (CMS) conducted an overview of the star rating in a webinar on December 16, 2021 and the materials from the webinar – slide deck, transcript, and recording — are now available here.
CMS also updated and rebranded a provider toolkit for hospices, Getting Started with Hospice CASPER Quality Measure Reports: February 2022. The toolkit is to assist hospice providers in understanding and using the CASPER Quality Measure (QM) Reports that now include claims-based measures. There are two reports:
- The Hospice-Level QM Report includes the HIS Comprehensive Assessment at Admission (NQF #3235), HCI, and HVLDL measure scores.
- The Hospice Patient-Level QM Report identifies each patient with a qualifying HIS record used to calculate the hospice-level quality measure values for a select period.
The reports are detailed, and hospices may be especially interested in the Hospice Care Index (HCI) and Hospice Visits in Last Days of Life (HVLDL) information.
NAHC conducted a webinar on these measures in December where we reviewed the most frequently asked questions about the HVLDL and explained the HCI – each of its ten indicators, calculation of the index score, and expected performance for each of the indicators and the index. Information from the webinar and from a hospice’s QM reports are helpful for performance improvement. The recording of the webinar is available here.
CAHPS Star Rating CASPER toolkit HIS, HCI, HVLDL A CAHPS Hospice Survey Star Rating will be added to Care Compare for hospices with the August 2022 refresh. How the star rating is calculated, what will be publicly reported, and information about the current “dry run” and provider preview information are part of the overview. Stay tuned…
Important Nov 30 webinar on this topic! There are several new documents and updates for the Hospice Quality Reporting Program (HQRP) that hospices should be aware of as the new reporting year quickly approaches. These are outlined below. In addition to these updates, NAHC will answer all your questions about this topic in a new…
Hospices can now access their confidential Quality Measure (QM) reports in CASPER for two new publicly reported measures, Hospice Care Index (HCI) and Hospice Visits in the Last Days of Life (HVLDL). These two claims-based measures will be publicly reported on Care Compare no sooner than May 2022. Hospices have been anxiously waiting to see…
On August 31 the Centers for Medicare & Medicaid Services (CMS) hosted a webinar on what hospices need to know from the FY2022 hospice final rule. The presentation covered the key changes made to the Hospice Quality Reporting Program (HQRP) through the final rule, including: Removal of the seven individual Hospice Item Set (HIS) process…