MHPCA Quality and Compliance Update - March 2017
Jane Moore
MHPCA Quality & Compliance News
Your
Monthly Hospice & Palliative Care Regulatory Resource
Keeping you up-to-date on the ever-changing world of hospice and palliative care. Please share this summary with your staff to ensure they are aware of items pertinent to their areas of responsibility.
NATIONAL NEWS – CMS / MEDICARE / OIG / DEA / ETC.
March 2017
All Providers
NHPCO Posts Emergency Preparedness Resource
Attention: Compliance & Safety Staff for All Providers
Providers are reminded that the CMS final rule, Emergency Preparedness Requirements for Medicare and Medicaid Participating Providers and Suppliers, will be effective November 15, 2017. To assist providers, NHPCO has created a member resource that provides comprehensive information on what you need to know to be compliant. Annette Kiser, The Carolinas Center’s Director of Quality & Compliance, contributed to the development of this resource. The document includes links to many other resources. Go to the NHPCO Emergency Preparedness webpage to access the document either in full, or in sections.
U.S. Department of Justice Posts Corporate Compliance Tool
Attention: All Providers
The Fraud Section of the Criminal Division of the Department of Justice has posted a document, Evaluation of Corporate Compliance Programs, to guide providers in evaluating their compliance programs. Prosecutors will consider several factors when investigating a corporate entity, determining whether to bring charges, and negotiating plea or other agreements. This document provides some important topics and sample questions that the Fraud Section has frequently found relevant in evaluating a corporate compliance program. In any particular case, the topics and questions may not all be relevant to each company. This tool looks at business processes to integrate compliance into daily operations.
New Forms for ALJ Appeals Posted
Attention: All Providers
The Office of Medicare Hearings & Appeals (OMHA) has developed a new unified Request for ALJ Hearing or Review of Dismissal form (OMHA-100) to replace the current Request for ALJ Hearing form (CMS-20034A/B) and Request for Review of Dismissal form (HHS-725). An accompanying Multiple Claim Attachment (OMHA-100A) can be used to identify multiple beneficiaries or enrollees associated with a single request.
The OMHA-100 form can be used to request an ALJ hearing or a review of dismissal for all actions that are appealable to OMHA. Providers are encouraged to use these forms when filing a request for an ALJ hearing or review of a dismissal to help ensure the request includes all information necessary to docket the appeal. However, OMHA will continue to accept requests that are filed in other formats, so long as they include all required information. More information is available on OMHA’s website.
OIG Exclusion List Updated
Attention: Human Resource Staff of All Providers
The OIG has posted the latest update to the list of excluded providers. Be sure to check this list against all employees, physicians and contract vendors to be sure that there is no relationship with any of the excluded individuals or companies. It is best practice to review the full list in case someone was added to the list through activities in another state. MHPCA has downloaded January’s list of added individuals. All exclusion files are posted at https://oig.hhs.gov/exclusions/exclusions_list.asp.
Quality Staff
CMS Posts Quick Reference Guide for Hospice Quality Reporting Program (HQRP)
A Quick Reference Guide for the Hospice QRP is now available on the HQRP Requirements and Best Practices webpage. The guide includes FAQs on data submission, information on the Help Desks, and helpful links.
CMS Updates CAHPS Hospice Survey Information
CMS has posted several updates to the CAHPS Hospice Survey website. Go to the What’s New page for more information and links to these items.
• CAHPS Hospice Survey Quality Assurance Guidelines V3.0 Technical Corrections and Clarifications – CMS has added guidance to the survey vendor related to analysis of data and telephone administration of the survey.
• Survey Administration Changes – CMS has revised text for the “Consent to Share Responses” question on the telephone administration version of the survey.
CMS Posts Updated Hospice Quality Reporting Program (HQRP) Materials
CMS has posted the updated training materials used during the Hospice Quality Reporting Program training on January 18. This set of documents includes the answers to the case scenarios and the FAQs. Access a zip file of the materials in the Downloads section of the Hospice QRP Training webpage.
Since public reporting of quality measures is planned for later this year, it is imperative that hospices ensure that staff are completing the HIS forms correctly. Note that several of the documents indicate via the file name that they include answers. Hospices can utilize the files without answers and the case study materials in staff education to have staff practice completing the Hospice Item Set questions. The educator can utilize the answers to guide the discussion to ensure understanding of CMS guidance.
CMS Issues Notice on Qualified Medicare Beneficiary
Attention: Palliative Care Billing Staff
CMS has posted Change Request (CR) 9911, Qualified Medicare Beneficiary Indicator in the Medicare Fee-For-Service Claims Processing System, to give information on modifications to the Medicare claims processing systems. The changes will help providers more easily identify the Qualified Medicare Beneficiary (QMB) status of each patient and to support providers’ ability to follow QMB billing requirements. It is important to note that beneficiaries enrolled in the QMB program are not liable to pay Medicare cost-sharing for all Medicare A/B claims. Review the Change Request and MLN Matters article to be sure that your agency is properly billing beneficiaries.
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
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