Home Health and Hospice Coalition Meeting Minutes: June 3, 2024

Published 07/05/2024

Meeting Date: June 3, 2024

Meeting Time: 10 a.m. – 12 p.m. ET

Meeting Location: Airport Sheraton Charlotte/Virtual via Zoom

Meeting Hosts

  • Tim Rogers, President and CEO
  • Shannon Pointer, DNP, RN, CHPN, Senior VP, Hospice & Palliative Care
  • Shannon Mintz, RN, MBA, COS-C, VP of Home Health and Regulatory Affairs, AHHC of NC and SCHCHA

Meeting Agenda

RCD Questions Submitted for Response

Question: Home Health Review Choice Demonstration Certifying Provider Change. There were multiple questions submitted regarding this notice. This article link now redirects back to the main Palmetto GBA web page.

Answer: This article has been removed from the Palmetto GBA website. We are working with the other MACs and CMS to issue education.

Question: Providers submitting claims for PCR — Recent Non-Affirmations because of Combo/Trio Coding. If a provider feels they are coding correctly but continue to receive non-affirmations, what should they do?

Answer: Palmetto GBA reviews in accordance with Medicare Benefit Policy Manual (PDF) The provider can reach out to Palmetto GBA with any disagreements via our PCC, POE Education Referrals, or directly to HH RCD POE.

Question: Wound Measurements for pre-claim review (RCD), is this a new requirement?

Answer: No, this is not new education. Requirements can be found here: Medicare Benefit Policy Manual Chapter 7, Home Health Services (PDF) — 40.1.2.8, Wound Care (Rev. 10438, Issued: 11-06-20, Effective: 03-01-20, Implementation: 01-11-21.

Question: When an announcement is made, like RCD being extended, what is the required amount of notice that must be given to providers before implementation?

Answer: 60 days are required for new states to be implemented.

Question: Can you provide an update on this previously asked question and response from our October 2023 meeting?

Question: It has been brought to our attention that some providers are receiving denials in ADR spot check when the OASIS is submitted greater than 30 days from M0090 date but submitted and in accepted status prior to billing — and it has been brought to our attention that some believe Palmetto GBA will not pay the initial ADR if the OASIS is submitted greater than 30 days from the M0090 date. Some providers have been told that they can appeal, but this seems to be related to a condition of participation, rather than a condition of payment.

Answer: This issue is in research. We will inform the provider community when we have an answer.

Answer: This is no longer an issue. Palmetto GBA is not denying for this reason.

Hospice

Question: Updates on Hospice Certifying Physician Claim Edit?

Answer: Anyone in the “Attending Field” needs to be properly enrolled and listed in PECOS; or properly “Opted Out.” The data in the CMS Database file which shows “Y” or “N” in the new Hospice Column is transmitting from PECOS. If physicians are listed in PECOS correctly, they will show correctly in the CMS Database file. Edit is comparing this information to determine if properly certified, and if “Y” is shown for hospice, edit will not fire for physician and can be listed in the “Attending Field”. If “N” is shown, the physician is does not have a current active enrollment in PECOS. or on the “Opt Out Affidavit” Tool.

The MLN MM13531 article (PDF) states for claims submitted on or after October 7, 2024, with dates of service as of June 3, 2024, or later, the system will check the “Referring Reference Physician NPI” field and the “Attending NPI” field on hospice claims to make sure the certifying physicians including hospice physicians and attending physicians are enrolled or opted out for Medicare. If the patient doesn’t have an attending physician or they are the same as the hospice certifying/recertifying, the hospice should report the hospice certifying/recertifying physician in the “Attending NPI” field. If physicians are different, then will be subjected to the ordering and referring denial edits for the initial certification period.

For recertifications, if both fields are completed, the system will check the “Referring Physician NPI” field for the certifying physician. You should enter the attending physician in the “Attending NPI” field and the certifying physician in the “Referring Physician NPI” field. If the patient doesn’t have an attending physician, you should report the hospice certifying/recertifying physician in the “Attending Physician NPI” field.

Question: Is there a list of Granular Error Codes in Targeted Probe Educate (TPE) letters? I know the denial codes but can’t find what the granular error codes reflect/indicate and providers need this list. When a provider receives the letter, there is no definition of what the granular error means. For example, a provider waited until the post probe call to find out what the specific reason for denial was.

Answer: Providers do not need to wait until the post probe call to get an explanation of denials. Page 4 in DDE will give an explanation and the Medical Review Denial Reason Code Tool can give you an explanation of the reason code along with tips to prevent that denial. Providers can call the PCC or do an education request.to get an educational session arranged.


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