Home Health and Hospice Coalition Meeting Minutes October 14, 2024

Published 11/07/2024

Meeting Date: October 14, 2024

Meeting Time: 10 a.m. – 12 p.m. ET

Meeting Location: Virtual

Meeting Hosts

  • Tim Rogers, President and CEO
  • Shannon Pointer, DNP, RN, CHPN, Senior VP, Hospice and Home Health Services and Professional Development Director, AHHC of N.C. and SCHCHA

Meeting Agenda

Review Choice Demonstration

Question: We would like to discuss the process on submission of documents to both Palmetto GBA eServices and the Spot Check processes in RCD when a technical error is found. There have been concerns expressed on if there is a clerical error found and it’s not a compliance issue, but more of a clerical error, that it still counts against the total Spot Check percentage and if that percentage drops too low, they will be put into PCR which some providers do not want to be in. There is also concern with record submission that once submitted in Palmetto GBA eServices, the provider is unable to see the submission and only had the reliance of what they say they submitted and therefore, we want to know if there is a possibility to have the system retain a pdf or scanned copy of what was submitted so that it is viewable by Palmetto GBA but also by the provider so they could do a check of records submitted and quickly and efficiently upload additional items if they, for example, noticed a missed item that should have been submitted. Then if there is a question on whether something was received, both entities could verify what was within the submitted documentation.

Response: Palmetto GBA makes their determinations based upon the documentation that is submitted. The eServices portal transmits the documentation submitted from the provider to another platform where the nurse’s review but does not store files. Palmetto GBA would need to investigate the feasibility of storing files through the eServices platform.

Question: There is concern on having RCD issues with physician handoffs not being affirmed.

Response: If the physician handoff was not evident in the record, the non-affirmation would be valid. Some type of documentation would be expected.

Question: When an agency receives a non-affirmation, no one contacts them to give them additional information that is needed or why they are being non-affirmed.

Response: Reviewers make three attempts to reach the provider. Providers should be sure to put good contact information in the submission to facilitate this process. Providers can also call the PCC with questions or concerns.

Question: Are you able to share any information on the expansion of RCD?

Response: There is no information on expansion at this time.

Disaster Information

Question: Please provide any pertinent Home Health and Hospice updates for the Coalition members from Palmetto GBA, to include any articles and information that could be helpful, including any updates as it relates to any of the disaster declarations within the regions of the Coalition under disaster declarations.

Response: The following CMS and Palmetto GBA resources explain emergency and disaster procedures:

Claims Processing Issues Log

Question: Please update the Coalition on any open CPIL for hospice, or any updates on any resolved CPIL since our last meeting.

Response: Hospice Certifying Physician Claim Edit, Reason Codes 17729 and 17730: The edits are to occur only If the incoming hospice claim contains occurrence code 27 and the date of certification. The editing is occurring without the claims containing occurrence code 27 and the date of certification.

Question: Please update the Coalition on any open CPIL for home health, or any updates on any resolved CPIL since our last meeting.

Response

  1. Reason Code 31755: This CPIL is instructional at this time. The CPIL provides information to the HHAs for the PCC to report these claims to Part A Claims to bypass 31755.
  2. Home Health Reason Code 19963, Notice of Admission (NOA) Not Found: The HHH MACs continue to identify claims that are editing for reason code 19963, NOA not found, improperly. We are identifying those claims and applying a workaround. CMS is creating a fix for this issue that is scheduled to be put into production in the January 2025 System Release.

Medical Review

Home Health Medical Review

Question: Please review the current items on the Palmetto GBA TPE Active Medical Review list for the Home Health states outside of RCD states. (Targeted Probe and Educate Program)

Response

  1. Home Health Services for Eligibility and Medical Necessity Bene Sharing
  2. Home Health Services for Eligibility and Medical Necessity
     

Question: Please provide an update on TPE outside of RCD states for Home Health.

Response: Here are the latest edit effectiveness results for Home Health:

Hospice Medical Review

Targeted High-Risk Hospice

Question: CPI stated in an email that “Providers in the states who have recently had TPE reviews conducted will be excluded by the MAC.”

a. What does “recently” mean here?

Response: CMS sets the criteria and selects the providers. We cannot define “recently.”

b. Does this replace TPE in these states?

Response: This doesn’t replace TPE in these states (Texas for Palmetto GBA), but a provider should not be on TPE and enhanced oversight review at the same time.

c. How many days before next round of claims is pulled and how many claims on second round?

Response: This is determined by CMS.
 

Question: Are there any details that can be shared about what to expect from the enhanced oversight TPE requirements that will be imposed on hospice providers in Ariz., Calif., Nev. and Texas, other than what has been released in MLN7215293? Have any of these TPE audits started yet? CPI stated in an email that this should be viewed as an “abbreviated TPE.”

Response: CMS sets the criteria and selects the for the Expanded Prepayment Review of Existing Hospices. The Period of Enhanced Oversight audit is targeting newly enrolling hospice providers or change of ownership (CHOW) that meets all the regulatory requirements under 42 CFR 489.18. The Expanded Prepayment Review of Existing Hospices targets existing providers in these states (Texas for Palmetto GBA). Both these audits are not TPE audits, and do not follow the same process as TPE.

Question: Please review the current items on the Palmetto GBA TPE Active Medical Review List for Hospice.

Response: Targeted Probe and Educate.

Question: Please provide any pertinent Hospice updates for the Coalition members from Palmetto GBA, to include any articles and information that could be helpful.

Response

Hospice General Questions

Provider Enrollment

Question: We are aware of a hospice provider that was put on a stay of enrollment due to a revalidation issue. The hospice received a rebuttal response letter from Palmetto GBA acknowledging the timely rebuttal with a favorable determination to remove the stay of enrollment. However, claims with admissions dates that occurred during the stay of enrollment are not paying.

Response: Stay of enrollment can be applied for several reasons (not in compliance for providing change of information, non-response to revalidation, etc.) Stay information is entered in PECOS and the claim system is updated. This process started in June of this year.

Updates on Hospice Certifying Physician Claim Edit

Question: Is there any feedback that can be shared regarding the second phase of the hospice certifying physician claim edit that was implemented this month?

Response: CMS determines if mass adjustments will occur by the MACs. A mass adjustment will most likely occur but claims that are billed incorrectly will deny again. Hospices can adjust claims and correct the physician fields on the claims using adjustments. Adjustment of non-medical claim denials is allowed in Medicare’s Claim System and providers shall initiate an adjusted claim through their electronic billing software (Direct Data Entry cannot be used). If a provider’s billing software doesn’t allow adjustments of non-medical claim denials, they should reach out to their vendor. Some hospices have been adjusting physician billing errors denials with 8X7 type of bills and receiving payment. The following resource provides more information.

Resource: Hospice Certifying Physician Billing Instructions.

Question: This question is regarding a hospice patient transfer. How do we handle an issue that is out of the hospice’s control, but is still denied as an exception utilizing the KX modifier?

Response: The KX modifier is only applicable for requesting a late Notice of Election (NOE) exception and it does not apply to late transfer notices. Please see Jurisdiction M HHH — Hospice NOE Exception Examples for more information and exception examples for late NOEs, including overlap with another hospice because that hospice had not completed their discharge billing timely.

Question: Are there any details that can be shared about the possible extension of hospice telemedicine flexibilities being extended beyond Dec. 31, 2024?

Response: There has been no announcement extending telemedicine at this time.

Question: With the end of the hospice VBID demonstration project coming up at the end of the year, are there any additional details we should know, other than what’s been most recently released in the CMS guidance document?

Response: The article below provides information on the termination of VBID.

Resource: Termination of the Hospice Benefit Component of the VBID Model on December 31, 2024


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