In The News

[UPDATED] CMS Finalizes Hospice Special Focus Program, 36-Month Rule

Hospice News

The U.S. Centers for Medicare & Medicaid Services (CMS) has finalized its 2024 home health rule, including the implementation of a hospice Special Focus Program (SFP).

The rule also finalizes the proposed “36-month”rule for hospice providers. The requirement mirrors a regulation that has existed for several years for home health agencies. The final rule forbids any change in majority ownership during the 36 months after initial Medicare enrollment, including acquisitions, stock transactions or mergers.

Despite comments from stakeholders in the hospice community, CMS decided to proceed with its proposed algorithm for selecting providers for the SFP.

“We proposed to identify a subset of 10% of hospice programs based on the highest aggregate scores determined by the algorithm. The hospices selected for the SFP from the 10% would be determined by CMS,” the agency indicated in the final rule. “To identify ‘poor performance,’ we have identified several indicators, namely, survey reports with Condition-Level Deficiencies (CLDs) and complaints with substantiated allegations, and CMS Medicare data sources from the Hospice Quality Reporting Program (HQRP) (Medicare claims and Consumer Assessment of Healthcare Providers and Systems (CAHPS®).”

CMS will also examine hospices’ performance on certain Conditions of Participation (CoPs) that the agency says “directly contribute to the quality of care delivered to patients, their caregivers, and families,” according to the final rule.

Though each of the 23-hospice specific CoPs will continue to have equal weight when it comes to Medicare certification and enforcement decisions, CMS is giving “special attention” to 11 CoPs. The agency contends that a condition-level deficiency on any of these rules may indicate that a hospice is providing poor quality care.

While the hospice community has generally embraced the concept of the SFP, some raised questions about this methodology.

Each of the major national hospice industry organizations voiced concerns about the algorithm that CMS will use beginning in 2024, including LeadingAge, the National Partnership for Healthcare and Hospice Innovation (NHPI), the National Association for Home Care & Hospice (NAHC) and the National Hospice and Palliative Care Organization (NHPCO).

In August, these organizations sent a joint letter to CMS asking to delay the program to allow for the development of a new methodology…

Read Full Article

 

Developmental Pathways Case Management Challenges

Hello providers,

Over the past several months DP has worked closely with the Colorado Department of Health Care Policy and Financing (HCPF) along with our neighboring case management agencies to plan and carry out the necessary steps associated with Case Management Redesign (CMRD).

As we have reached the scheduled November 1 transition date, we have identified pressure points or what we are calling “known issues” with the transition process, which are outside our local control.

As you may remember, CMRD includes dozens of inter-related projects that are owned and managed by our State partners at Health Care Policy and Financing (HCPF), which serves as our State Medicaid agency. These projects were often funded, at least in part, through nearly $530M in funds from the American Rescue Plan Act (ARPA) and are all intended to improve the long-term care (LTC) system for its members.

These projects encompass several ambitious and far-reaching goals that are intended to improve access to services.

  • This includes implementing an entirely new case management database, called the Care and Case Management (CCM) System.
  • The CCM system is a critical component of case management supports.
  • Unfortunately, as is often the case with big technology shifts, there have been system glitches requiring complex solutioning, as managed by a third-party contractor with HCPF called AssureCare.

These ongoing issues with the CCM system have made it very challenging to access full, complete case management records, resulting in data disruptions that are out of our control as your case management agency.

These disruptions are occurring simultaneously with the unwind of the Public Health Emergency flexibilities and through the planned CMRD transitions, which are required to occur before July 1, 2024, for the State of Colorado to maintain its federal funding for long-term care services.

DP along with other Case Management Agencies (CMAs) have met with HCPF multiple times to troubleshoot the database issues and will continue doing so. Of particular importance is our ability to provide seamless case management transition & ongoing supports in a person-centered, timely manner.

Known Issues Include:

1) Access to case management data:

Case managers may not be able to immediately access or update member information in the designated state database. This means individuals, families, and/or providers may be asked to repeat some information that is “on file” but not immediately accessible to our teams.

When this occurs, we identify the issue & work with the state to resolve it. 

2) Ability to create, update, or print service plans:

Sometimes case managers cannot create or update service plans. When this happens, we have to temporarily document supports in another way & work with the state to fix the issue.

This means that we may not have formal service plan information immediately available to share with individuals, families, and/or providers. 

3) Ability to submit prior authorization requests (PARs) for providers to authorize supports.

Case managers have been having issues both creating & submitting support authorizations (called PARs) in the state’s system, which creates the authorizations that allow providers to bill & be paid for services.

If we can’t upload PARs, providers may struggle with payment.

We are working with the state and providers to ensure, whenever possible, that services are not disrupted but some providers may pause services until the issue(s) are resolved.

4) Disruption in Medicaid eligibility related to the Public Health Emergency (PHE):

Some people are experiencing disruptions to their Medicaid eligibility following the end of the COVID-19 public health emergency (PHE).

The best resource for information about this is found on this website: https://hcpf.colorado.gov/phe-end.

Individuals should contact their local county human services office and/or case managers immediately if they experience a disruption in Medicaid eligibility.

5) Disruption in provider billing:

Due to issues with submitting PARs (#3 above) and Medicaid eligibility disruptions (#4 above), some providers are not being paid for services they have provided.

This is extremely frustrating for all parties and we are working closely with our state partners to resolve billing issues as quickly as possible.

Resources From HCPF

Contact Information for DP

In closing,

We know transitions are hard and that complications like the ones listed above only make them feel harder.  While the issues listed above are not being experienced unilaterally by all members or all providers, we are collectively working tirelessly to get meaningful solutions in place as quickly as possible.

Rest assured, both CMAs and HCPF remain committed to fixing these system glitches and improving our collective overall service experience as providers supporting some of Colorado’s most vulnerable citizens. 

On behalf of our CMA partners at HCPF, we will continue to collaborate on shared solutions and will do all we can to support you and your provider agencies during this transitional time.

Thank you for your patience and understanding during these critical transitions,

Developmental Pathways

 

Use of [Hospice] Volunteers

The Health Group

CMS waived the requirement for hospices to use volunteers (42 CFR §418.78(e)) during the Public Health Emergency (“PHE”); however, the requirement is again effective January 1, 2024.  Many hospices had difficulty complying with this requirement even before the PHE.

Hospices need to begin addressing this requirement immediately.  Rebuilding the volunteer base post PHE is not going to be an easy task for many hospices.  Hospices may be subjected to a standard level survey citation if they don’t meet the five percent (5%) of hospice patient care hours requirement.  A standard level deficiency means that the hospice is not compliant with one of the standards under a condition of participation.  The hospice remains certified with this type of deficiency but will need to submit a plan of correction to the surveying agency describing how the deficiency will be mitigated.

Hospices must capture Volunteer Coordination costs in the accounting records for inclusion in the Hospice Cost & Data Report.  If a Hospice employee provides volunteer coordination services and other services, the compensation should be segregated in the accounting records or appropriate information should be provided to that individual responsible for cost report preparation, allowing for any necessary reclassification of costs.

Additionally, the Hospice should capture the hours spent by volunteers into the following, at a minimum:

  • Patient support – patient’s residence,
  • General support – patient’s residence (housekeeping, meals, errands, etc.),
  • Patient support – hospital,
  • Patient support – SNF, long-term care,
  • Administrative services support,
  • Fundraising activities, and
  • Bereavement.

A qualified cost report preparer, internal or external, should be able to reasonably allocate Volunteer Services Coordination costs on the Hospice Cost & Data Report based on this information.  Additional categorization of volunteer hours will further enhance the quality of the Hospice Cost & Data Report.

 

What States Get Right And Wrong When It Comes To Home-Based Care Support

Home Health Care News | By Joyce Famakinwa

When it comes to long-term care services and home-based care, some states are much further ahead than others. But one thing most of those states agree on is that there’s still room to improve.

Last month, when AARP released its long-term services and supports state scorecard report, Minnesota came out on top, ranking number one on the list. That means the state scored high when it comes to factors such as affordability and access, choices of settings and providers, safety and quality, and more.

“Minnesota has long taken pride in doing very well in providing care for Minnesotans, whether it be the older adults or people with disabilities, so I think we have continued to work on that,” Kathy Messerli, executive director at the Minnesota Home Care Association, told Home Health Care News. “I would also say that while it’s hard to find a silver lining for the pandemic, one of them was certainly an increased awareness of the services that could be provided in the home, and the quality and the outcomes that come from that.” . . .

.. The AARP report ranked states overall, but it also detailed individual rankings for various performance indicators.

Read Full Article

Explore the Report Card

 

Lymphedema Compression Treatment Items

Starting January 1, 2024, Medicare will pay for lymphedema compression treatment items for Medicare Part B patients.

What’s Covered?

We’ll pay for standard and custom-fitted lymphedema compression treatment items for each affected body part, including:

  • Compression garments, including those for daytime and nighttime, which offer different levels of compression
  • Compression bandaging systems and supplies provided during the initial decongestion phase and maintenance phases of treatment
  • Gradient compression wraps with adjustable straps
  • Necessary accessories for gradient compression garments and wraps, including:
    • Aids for putting on and taking off (donning and doffing) items for different body parts, like lower limb butlers or foot slippers that help patients put on compression stockings
    • Fillers
    • Lining
    • Padding
    • Zippers

How Often?

We pay for compression garments:

  • Daytime: 3 garments every 6 months
  • Nighttime: 2 garments every 2 years

We also pay for items, as needed:

  • To replace lost, stolen, or irreparably damaged items
  • If a patient’s condition changes, like a change in limb size

Who’s Eligible?

We’ll pay for these treatment items when:

  • The patient has Medicare Part B coverage (their annual Part B deductible and 20% coinsurance will apply)
  • The patient has lymphedema (a chronic condition that causes swelling in the body's tissues) and will use the item to primarily and customarily treat it
  • An authorized practitioner prescribes the item

Can I Furnish These Items?

You must be an enrolled DMEPOS supplier to get Medicare payment for furnishing these treatment items. Become a DMEPOS supplier.

What Are My Responsibilities?

When you furnish a lymphedema compression treatment item, you’re responsible for all aspects of providing the item, unless you work out an arrangement with a professional fitter to perform the services. This includes:

  • Taking measurements of the patient’s affected body area
  • Performing necessary fitting services
  • Training the patient how to take the treatment item on and off
  • Showing the patient how to take care of the treatment item
  • Adjusting the treatment item, if needed

How Can I Bill?

Starting January 1, use new and existing codes in the January 2024 Alpha Numeric HCPCS File. We’ll publish the January file soon.

Where Can I Get More Information?

 
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