Important Hospice Quality Reporting Reminders

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.

  1. 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.

  1. 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.

Important Hospice Quality Reporting Reminders

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…

Final Reminder! Hospice Mandatory Reporting Reminder: Deadline for Self-reporting of Aggregate Cap is Feb 28

Hospice providers are required to self-calculate and submit their Aggregate Cap Report for the 2021 Cap year no later than February 28, 2022. Failure to file the self-determined cap report with your Medicare Administrative Contractor (MAC) in a timely fashion may result in payment suspension. If you have a Cap-related liability, you are required to submit payment at the time…

Update! Home Health Claims Processing Issues

NAHC became aware of home health claims processing problems in the last several weeks, caused by a Centers for Medicare & Medicaid (CMS) Service systems issue and some Medicare Administrative Contractor (MAC)-specific issues. (See January 12, 2022 NAHC Report for more information.) NAHC quickly began addressing these issues when it was brought to our attention.…

Hospice Mandatory Reporting Reminder: Deadline for Self-reporting of Aggregate Cap is Feb 28

Hospice providers are required to self-calculate and submit their Aggregate Cap Report for the 2021 Cap year no later than February 28, 2022. Failure to file the self-determined cap report with your Medicare Administrative Contractor (MAC) in a timely fashion may result in payment suspension. If you have a Cap-related liability, you are required to submit payment at the time you submit your report.

In order to calculate the Cap, you must be able to access your hospice’s PS&R data, so if you do not have access to CMS’ Identify Management System (formerly EIDM), through which the PS&R data is available) it is advisable that you take action immediately to ensure timely access so that you can meet the reporting deadline.

All three MACs for Home Health and Hospice have online instructions for self-calculation and submission of the Cap report; the information is available at the following locations:

Palmetto GBA

Recent postings to the Palmetto GBA website about the aggregate cap report are  available HERE and HERE.

Palmetto serves Home Health and Hospice providers in Alabama, Arkansas, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Mississippi, New Mexico, North Carolina, Ohio, Oklahoma, South Carolina, Tennessee, and Texas.

CGS

Recent CGS online postings about the aggregate cap report are available HERE.

CGS serves Home Health and Hospice providers in Colorado, Delaware, Iowa, Kansas, Maryland, Missouri, Montana, Nebraska, North Dakota, South Dakota, Pennsylvania, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia.

NGS

NGS has updated its Hospice Cap self-calculation guidance; it is available online on the NGS website HERE.  The form is available in the NGS FORMS section.

NGS has two Home Health and Hospice Jurisdictions (JK and J6) and serves providers in the following states:  Alaska, American Samoa, Arizona, California, Connecticut, Guam, Hawaii, Idaho, Maine, Massachusetts, Michigan, Minnesota, Nevada, New Hampshire, New Jersey, New York, Northern Mariana Islands, Oregon, Puerto Rico, Rhode Island, US Virgin Islands, Vermont, Wisconsin, and Washington.

Hospice Mandatory Reporting Reminder: Deadline for Self-reporting of Aggregate Cap is Feb 28

Hospice providers are required to self-calculate and submit their Aggregate Cap Report for the 2021 Cap year no later than February 28, 2022. Failure to file the self-determined cap report with your Medicare Administrative Contractor (MAC) in a timely fashion may result in payment suspension. If you have a Cap-related liability, you are required to submit payment at the time…

Home Health Claims Processing Issues

NAHC has become aware of some home health claims processing problems last week and this week because of a Centers for Medicare & Medicaid (CMS) systems issue and some Medicare Administrative Contractor (MAC)-specific issues.  NAHC quickly began addressing these issues when it was brought to our attention. The issues are: Notice of Admission (NOA) claims…

MACs to Send Direct Mailing to Hospices Regarding MA VBID Hospice Component Model

In January 2021, the Centers for Medicare & Medicaid Services (CMS) initiated a four-year demonstration model (the MA VBID Hospice Component) under which eligible Medicare Advantage (MA) plans are permitted to offer hospice services as part of the benefit packages. For calendar year (CY) 2022, the MA VBID Hospice Component will expand such that plans…

MACs to Send Direct Mailing to Hospices Regarding MA VBID Hospice Component Model

In January 2021, the Centers for Medicare & Medicaid Services (CMS) initiated a four-year demonstration model (the MA VBID Hospice Component) under which eligible Medicare Advantage (MA) plans are permitted to offer hospice services as part of the benefit packages. For calendar year (CY) 2022, the MA VBID Hospice Component will expand such that plans in 22 states and territories will participate in the model in some areas of each state. In order to ensure that plans appropriately pay hospices serving patients enrolled in a participating plan and that plans are properly paid by CMS for those patients, special billing rules apply to hospices serving patients in the model.

In an effort to raise general awareness of the MA VBID Hospice Component model and to provide education on participation and billing for MA enrollees that receive hospice services in affected areas, CMS recently issued Change Request 12524/Transmittal 11160 – Direct Mailing Notification to Hospice Providers Regarding the Hospice Benefit Component, Value-Based Insurance Design (VBID) Model, Medicare Advantage Organizations (MAOs), directing the Medicare Administrative Contractors (MACs) to conduct a direct mailing to all hospice providers in their jurisdictions affected by the service areas identified for the CY2022 MA VBID Hospice Component.  These service areas are in the following states and territories:

  • Alabama
  • California
  • Colorado
  • Florida
  • Georgia
  • Hawaii
  • Idaho
  • Illinois
  • Indiana
  • Kentucky
  • New Mexico
  • New York
  • Ohio
  • Oklahoma
  • Oregon
  • Pennsylvania
  • Texas
  • Utah
  • Virginia
  • Washington
  • Wisconsin
  • Puerto Rico

According to the transmittal, CMS requires participating MA organizations to communicate with hospice providers in the service area of their participating plans. Hospice providers are also encouraged to communicate with MA plans regarding any questions about the model, billing, coverage, and enrollment. Hospice providers must submit claims and notices to participating MA plans to receive payment when their enrollees elect to receive hospice care. Hospice providers must submit claims and notices to their Medicare contractor, as well, for informational purposes. Enrollees of participating MA plans may seek hospice care with any Medicare-certified hospice provider.

In addition to this specific direct outreach, the MACs have also been directed to conduct education for hospice providers about the CY2022 MA VBID Hospice Benefit Component through relevant outreach events, listserv messages and web postings, which shall include information about CMS and MAC educational products and resources about the model.

Recent NAHC Report coverage of issues related to the MA VBID Hospice Benefit Component Model is available at the following links:

CMS Releases List of MA Plans Offering Hospice under VBID Model in CY2022

CMS Issues Guidance on Determining Hospice Beneficiary Enrollment in MA VBID Hospice Model for CY2022

Home Health & Hospice MAC “Operation Collaboration” Summit Sessions Now Available Online

Earlier this year, the Home Health and Hospice (HHH) Medicare Administrative Contractors (MACs) – National Government Services (NGS), CGS and Palmetto GBA – hosted the 2021 Virtual HHH MAC Collaborative Summit titled, “Operation Collaboration: We are all in this Together”. The Summit was comprised of joint sessions that occurred on September 15 and 17, and…