MHPCA Monthly Quality and Compliance News - May 2017
Jane Moore
MHPCA Quality & Compliance News
Your
Monthly Hospice & Palliative Care Regulatory Resource
NATIONAL NEWS – CMS / MEDICARE / OIG / DEA / ETC.
May 2017
All Providers
US Government Accountability Office Report on Medicare Provider Education
Attention: All Billing & Finance Staff
In response to HHS reports of an estimated 11% improper payment rate and $41.1 billion in improper payments in the Medicare fee-for-service program in FY 2016, the GAO submitted a report to the Chair of the US Senate Finance Committee on Medicare Provider Education: Oversight of Efforts to Reduce Improper Billing Needs Improvement. GAO was asked to examine MACs’ provider education department efforts and the results of MACs’ probe and educate reviews. The full GAO report is available here.
Attention: Human Resource Staff of All Providers – OIG Exclusion List Updated
The OIG has posted the latest update to the list of excluded providers. All companies need to check this list against all employees, physicians and contract vendors to be sure that there is no relationship with any of the excluded entities. It is best practice to review the full list in case someone was added through activities in another state. Exclusion files are posted as Excel spreadsheets at https://oig.hhs.gov/exclusions/exclusions_list.asp, and the data can be sorted by name, state or other information as needed.
Hospice Providers
New Updated Hospice Medicare Benefits Published
CMS has just published its newly updated April 2017 issue of the Medicare Hospice Benefits.
Compliance Staff
Hospice Election Statements Lack Required Information or Have Other Vulnerabilities
After a stratified random sample review of hospice election statements and certifications of terminal illness, the Office of the Inspector General (OIG) reports that more than one-third of hospice General Inpatient (GIP) stays lack required information or had other vulnerabilities.
· Hospice election statements did not always mention – as required – that the beneficiary was waiving coverage of certain Medicare services by electing hospice care or that hospice care is palliative rather than curative
· In 14 percent of GIP stays, the physician did not meet requirements when certifying that the beneficiary was terminally ill and appeared to have limited involvement in determining that the beneficiary’s condition was appropriate for hospice care
Hospices should improve their election statements and ensure that physicians meet requirements when certifying beneficiaries for hospice care.
Resources:
·
Hospice Payment System Booklet: Includes a section on the hospice election statement
· Hospices Should Improve Their Election Statements and Certifications of Illness OIG Report
·
Documentation Requirements for the Hospice Physician Certification/ Recertification MLN Matters® Article
·
Sample Hospice Election Statement MLN Matters Special Edition Article
HCCA-OIG Compliance Effectiveness Roundtable Issues Measuring Compliance Program Effectiveness: A Resource Guide
On March 27, 2017, The HCCA-OIG issued “Measuring Compliance Program Effectiveness: A Resource Guide,” the result of the work of a roundtable meeting in Washington, DC, on January 17, 2017. On that date, a group of compliance professionals and staff from the Department of Health and Human Services, Office of Inspector General (OIG), met to discuss ways to measure the effectiveness of compliance programs. The intent of this exercise was to provide a large number of ideas for measuring the various elements of a compliance program. Measuring compliance program effectiveness is recommended by several authorities, including the United States Sentencing Commission (see, Chapter 8 of the United States Sentencing Guidelines). This list will provide measurement options to a wide range of organizations with diverse size, operational complexity, industry sectors, resources, and compliance programs.
Quality Staff
Presentation for Hospice Public Reporting Webinar Now Available
The presentation for the April 27, 2017 Hospice QRP Public Reporting Webinar is available in the downloads section of the Hospice QRP Training webpage.
Hospice Item Set (HIS) Questions and Answers (Q+As) and Quarterly Updates
This document is intended to provide guidance on HIS-related questions that were received by the Hospice Quality Help Desk during the first quarter (January-March) of 2017. This document also contains quarterly updates. Guidance contained in this document may be time-limited, and may be superseded by guidance published by CMS at a later date.
National Quality Forum Offers Comment Period on Palliative and End-of-Life Care Meeting Measures
NQF has posted its draft report (PDF) containing the measure summaries and the Standing Committee’s recommendations for endorsement on the measures submitted for review. The Public and Member Comment period is now open through May 10 at 6:00pm ET. NQF members and the public are able to submit comments on the report as a whole and the measures being reviewed. You will need to log in to the NQF website to submit comments.
Finance, Billing and/or IT Staff
Attention Physicians & Nurse Practitioners: Quarterly Update to the National Correct Coding Initiative (NCCI) Procedure to Procedure (PTP) Edits
The Centers for Medicare & Medicaid Services (CMS) developed the NCCI to promote national correct coding methodologies and to control improper coding that leads to inappropriate payment in Part B claims. Version 23.2 will include all previous versions and updates from January 1, 1996, to the present, and will be effective on July 1, 2017. This MLN Matters® Article is intended for physicians, other providers, and suppliers submitting claims to Medicare Administrative Contractors (MACs) for services provided to Medicare beneficiaries.
CMS Issues Proposed Rules On Electronic Signatures for Cost Reports
The proposed rule would allow cost reports to be signed electronically for cost reporting periods beginning on or after October 1, 2017, for those providers required to submit the cost report electronically. Providers would continue to have the option to continue to send a hard copy certification and settlement page with a signature or the provider could elect the electronic signature filing. The cost report will provide a separate identification that the signature is being submitted electronically.
Currently hospitals, skilled nursing facilities, home health agencies, hospices, end-stage renal disease facilities, organ procurement organizations, histocompatibility laboratories, rural health clinics, Federally qualified health centers, and community mental health facilities are required to file Medicare cost reports electronically with a mailed-in separate signed hard-copy certification and settlement summary.
The proposed rule, primarily focused on hospital related issues, also clarifies reporting gains and losses on asset disposals for cost reporting purposes, changes requirements relating to publishing self-termination notices, and makes proposed changes on a variety of other issues. More details will be discussed based on a further review of the proposed rule. The entire text can be found here.
Attention: Billing Staff - CGS’s New Hospice NOE Quick Resource Tool Available on TCC Member Site
CGS worked in collaboration with the home health and hospice Medicare Administrative Contractors (MACs) Palmetto GBA and National Government Services (NGS) to develop the “Notice of Election (NOE) Timely Filing and Exceptional Circumstance Guidelines” (PDF) quick resource tool.
Palliative Care Providers
The Joint Commission Offers Complimentary Webinar on Community-based Palliative Care Certification
TJC invites all palliative care providers to join a Complimentary Webinar: Community-based Palliative Care Certification on June 27, 2017 1:00 PM - 2:00 PM ET.
ACHC Releases Final Palliative Care Standards
The first week of April, the Accreditation Commission for Health Care released its final palliative care standards. This distinction will complement home health, hospice, and private duty accreditation.
New Program from CAPC
The Center to Advance Palliative Care is accepting applications for the CAPC Payment Accelerator, an innovative new program to help community-based palliative care programs secure sustainable financing. The Accelerator kicks off with a two-day workshop in Phoenix, AZ, followed by a full year of support from legal, contracting, and financial experts. Applications are due May 19. Learn more about the CAPC Accelerator.
Home Health Providers
CMS Posts Additional Information in MLN Matters on Home Health Payments
CMS has posted additional information to MLN Matters Article Number SE17009, “Denial of Home Health Payments When Required Patient Assessment Is Not Received.” As previously reported in Hospice Report, the effective date was April 1, and implementation date was April 3.
Jane Moore
CEO
Missouri Hospice & Palliative Care Assn.
600 Monroe Street
Suite 300
Jefferson City, MO 65101
Phone 573-634-5514
Fax 573-635-0659
Please save the date for the Midwest Conference October 22- 24, 2017 at Hilton Frontenac!
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