Jurisdiction M (JM) Home Health and Hospice (HHH) POE Advisory Group (POE-AG) Minutes: April 11, 2024
Facilitator: Dan George
Attendees: 20
Welcome
Our Goals
- Establishing and maintaining strong relationships with Palmetto GBA and our provider community
- Meeting with Palmetto GBA and the provider community on a quarterly basis
- Providing the communication tools to facilitate thorough and prompt transfer of information
- Coordinating issues within the provider community to adequately reflect the concerns of the majority
POE-AG Goals and Purpose — HHH POE-AG Charter.
Old Business: : Prior POE-AG Suggestions/Recommendations
- Palmetto GBA published the article Hospice Benefit Policy Manual Updates Related to the Addition of Marriage and Family Therapists or Mental Health Counselors to the Hospice Interdisciplinary Team and linked the CMS questions and answers document in the article
- Could a one page face-to-face checklist be created by Palmetto GBA just for physicians/practitioners?
- Home Health Face-to-Face Checklist (PDF) Palmetto GBA created this checklist, and it was approved by the association, who wanted all the information included and added to it. Would the group like to review and determine what can be removed.
New Business: POE-AG Training Suggestions and Education Recommendations
Participating members have the opportunity to benefit the provider community by helping to guide Palmetto GBA educational strategy for the upcoming year.
Information to Share
- MLN6922507 Medicare Payment Systems — Multiple Medicare benefits and payment system overview that includes home health and hospice
- Change Healthcare Security Incident
Home Health
- Expanded Home Health Value-Based Purchasing Model
- Email Updates: Subscribe to the HHVBP Model Expansion listserv
- Have questions about the expanded HHVBP Model?
Please send questions to HHVBPquestions@cms.hhs.gov. Be sure to include your name and the home health agency’s name and CCN.
- Separate Payment for Disposable Negative Pressure Wound Therapy Devices on Home Health Claims
Effective on January 1, 2024, period of care claims with "through" dates on or after this date, the billing and separate payment of an applicable disposable negative pressure wound therapy (NPWT) device shall be billed/paid on the period of care claim, Type of Bill (TOB) 032x.
Hospice
- Fiscal Year (FY) 2025 Hospice Payment Rate Update Proposed Rule (CMS-1810-P)
- Medicare Hospice Payment Policies
- The FY 2025 hospice payment update percentage is 2.6 percent
- Hospice Quality Reporting Program (HQRP)
- Hospice Conditions of Participation Technical Update
- Medicare Advantage Value-Based Insurance Design Model — March 4, 2024, Announcement: Hospice benefit component ending December 31, 2024
- Hospice Certifying Physician Medicare Enrollment Information — This article discusses the three enrollment options for hospice certifying physicians.
- Reason Code 17729 — This reason code will edit the claim’s attending physician’s NPI data against the PECOS Enrolled Physicians File for hospice claims, type of bill 81X and 82X (excluding 8XA, 8XB, 8XC, 8XD and 8XE) with a statement "from" date on or after June 3, 2024 (on April 25 CMS delayed the effective date from May 1, 2024, to June 3, 2024)
- Hospice Benefit Policy Manual Updates Related to the Addition of Marriage and Family Therapists or Mental Health Counselors to the Hospice Interdisciplinary Team — On November 29, 2023, CMS hosted a Hospice Open Door Forum call. On that call, several questions were asked regarding the new requirements for MFTs and MHCs that became effective January 1, 2024. Due to the number of questions, CMS developed and posted the linked Questions and Answers Document. Please share this with your staff.
- Hospice Caps Job Aid — This updated job aid explains the two caps that affect Medicare payments under the hospice benefit
- Hospice Caps — To ensure that the cost of hospice care does not exceed the cost of conventional care, CMS established two annual caps (or limits) on hospice payments
RCD News
- Submit Home Health RCD Pre-Claim Review Requests with your Correct PTAN — Palmetto GBA is seeing an increase of pre-claim review (PCR) submissions with incorrect Provider Transaction Access Numbers (PTANs), also known as CMS Certification Numbers (CCNs)
- Monthly Home Health Review Choice Demonstration (HH RCD) Provider Webinar Schedule — Wednesday May 1, 2024
New Articles
- The Hospice Face-To-Face Encounter and Telehealth Technology — This short article will state “Section 3706 of The CARES Act allowed for face-to-face encounters for purposes of patient recertification for the Medicare hospice benefit can now be conducted via telehealth (i.e., two-way audio-video telecommunications technology that allows for real-time interaction between the hospice physician/hospice nurse practitioner and the patient). An encounter done by audio only is not acceptable. This statutory change will expire on December 31, 2024.”
- New Hospice Certifying Physician Claim Edit Effective May 1, 2024 — A short article of reminders to prevent denials
Upcoming Education Events
- Save the date: 2024 HHH Summit — The 2024 HHH MAC Collaborative Summit is scheduled from October 2 to October 4, 2024. More information to come later this year.
- Palmetto GBA Educational Webinars will be Transitioning to the Cvent Platform
eServices
- eServices Displays Accountable Care Organization Model Information — On January 2, 2024, eServices made an update to display information on the ACO models for Part A, Part B and HHH providers that are participating in an Accountable Care Organization. A new menu tab, ACO, will display to provider account administrators.
Open Discussion
Question: For the New Hospice Certifying Physician Claim Edit originally announced effective May 1, 2024 (on April 24 CMS delayed the effective date to June 3, 2024), will the claim be returned to the provider of reject?
Answer: The claim will be denied with reason code 17729. See the “Reason Code 17729”, linked previously in this article for how to adjust a denial, if applicable.
Question: For the New Hospice Certifying Physician Claim Edit, some physicians are trying to enroll with the Part B MAC in their state, but are waiting for weeks or months applications to process. What can they do to expedite their enrollments?
Answer: They will have to contact the Part B MAC processing their application with any questions. In general, Part B applications process faster than Part A institutional applications.
Question: If a physician is awaiting approval of their Part B enrollment, should the hospice wait to submit the claim with that physician listed as the attending.
Answer: That is the hospice’s decision. But remember, the claim will deny if the physician does not have a PECOS enrollment at the time the claim is processed.
Question: CMS’ billing direction in MLN6922507 for subsequent benefit periods states the hospice certifying physician should be listed in the claim form’s Attending Physician field. Leave the Other field blank. Would that prevent the non-hospice attending physician from being able to bill Part B for their services?
Answer: No, it would not. The non-hospice attending physician would still be able to bill Part B and receive reimbursement.
Question: Some EMRs place NPs or PAs in the Attending Physician field on the claims. Will that be an issue?
Answer: Yes, the claim will deny. The billing direct since NPs and PAs could act as the hospice attending has always stated they are not to be entered in the Attending Physician field. They are to be entered in the Other Physician field.
Next Meeting: July 18, 2024
