Hospice and Home Health Regulations Blog

Starting in July, hospices will be required to discontinue use of occurrence code 42 when a provider initiates the termination of hospice care and for hospices to only use occurrence code 42 to indicate a discharge due to a patient revocation. Hospices must also begin to use the new condition code to indicate a discharge due to the patient’s unavailability/inability to receive hospice services from the hospice which has been responsible for the patient.

Medicare will begin returning hospice claims that meet the following criteria with dates of service on or after July 1, 2012:

• Both condition code 52 and condition code H2 are present;
• Condition code 52 is present and the patient status code is 30;
• Condition code H2 is present and the patient status code is 30;
• Condition code H2 is present with occurrence code 42; or
• Condition code 52 is present with occurrence code 42.

THE HEAT IS ON

The Health Care Fraud Prevention and Enforcement Action Team (HEAT) has created free videos and audio podcasts (averaging about four minutes each) that cover major health care fraud and abuse laws, the basics of health care compliance programs, and what to do when a compliance issue arises. The first educational presentation was posted on the OIG website the week of December 5; 8 videos are currently accessible and the remaining 3 will be posted in the next few weeks: http://oig.hhs.gov/newsroom/video/2011/heat_modules.asp

The Office of Inspector General (OIG) identified 7 fundamental elements to an effective compliance program:

Important HH CAHPS Reminders

• Agencies who served 59 or fewer eligible patients between 4/1/10 and 3/31/11 must submit their exemption request forms by 1/21/2012 for 2013 CY HH CAHPS.
• All CAHPS vendors must submit 3^rd quarter 2011 data by 1/23/12 by 11:59PM. Home Health Agencies that have not already done so, should submit data to their CAHPS vendor to guarantee data is submitted to CMS before the deadline. Agencies using HEALTHCAREfirst can use the HH CAHPS data export feature and reporting tools to generate and review submission files.  HEALTHCAREfirst’s approved vendor list can be accessed here.

CMS reminded agencies in the recent Open Door Forum, that they should be checking their Data Submission Report on a regular basis to ensure their CAHPS vendor is submitting survey data before the submission deadline.  HHAs can access the Data Submission Report using these instructions:

CMS has published an update to the Claims Processing manual to include billing instructions to assist providers in preparing demand bills when the dates of requests by the State Medicaid program do not correspond to dates of existing episodes of care. It also resolves a discrepancy between Medicare instructions for reporting charges and the requirements of the HIPAA transaction standard.

The 837 requires that the Total Charges field always be reported (and zero is an acceptable value,) while Medicare’s instructions since 2000 stated the field may be zero or blank. The recently published transmittal corrects this discrepancy by stating that HHAs must report zero charges on the 0023 revenue code line.

Hospice agencies can Click here for a copy of the handout for today’s Free Hospice Webinar, “Preparing for 2012: Is Your Hospice Ready?”

Today, we will be presenting a free webinar for hospices titled, “Preparing for 2012: Is Your Hospice Ready?”  We will be summarizing the changes that will affect hospice in 2012 and how you should prepare.

Topics include:

• Quality reporting
• Hospice Wage Index for 2012
• Hospice aggregate cap calculation & methodology
• Face-to-Face
• Update on HIPAA 5010 and ICD-10
• Medicaid Program rules

You are invited to join us for a FREE webinar summarizing the changes that will affect hospice in 2012 and how you should prepare.  Topics include: 

- Quality reporting

- Hospice Wage Index for 2012 

- Hospice aggregate cap calculation & methodology

- Face-to-Face

- Update on HIPAA 5010 and ICD-10

- Medicaid Program rules

Stay cozy and warm this winter with HEALTHCAREfirst's December Webinar Series. Registrations for these webinars are at an all time high.  We hope that you will gain valuable knowledge about the PPS changes that are coming in 2012

Topics include:

• HIPAA 5010 and ICD-10 Updates  
• Increased scrutiny on home care providers, ZPIC and other audits 
• Medicaid Program Rules
• Medicare enrollment validation

Click here to view webinar handout*

Also, the recording link is NOW AVAILABLE!  Click here to view the webinar recording.

*Slides 30, 32 and 35 have been revised with minor corrections related to:

Don’t forget that CMS will require use of its revised Advanced Beneficiary Notice of Non coverage (ABN) (form CMS-R-131) on January 1, 2012. This will replace the 2008 form.

The ABN is used by all providers, practitioners, and suppliers paid under Medicare Part B, as well as hospice providers and religious non-medical healthcare institutions (RNHCIs) paid exclusively under Part A.

Providers and suppliers are allowed to use either the 2008 or 2011 version of the ABN through the end of this year; beginning Sun Jan 1, 2012, they must begin using the 2011 version.  ABNs issued after Sun Jan 1 that are prepared using the 2008 version of the notice will be considered invalid by Medicare contractors.  2008 versions of the ABN that were issued prior to Sun Jan 1 as long-term notification for repetitive services delivered for up to one year will remain effective for the length of time specified on the notice.

ICD-10 migration could be a challenge for home care and hospice organizations working to achieve compliance by the October 1, 2013 deadline. On that date the ICD-9 code sets used to report medical diagnoses and inpatient procedures will be replaced by ICD-10 code sets.

To accommodate the ICD-10 code structure, the transaction standards used for electronic health care claims, Version 4010/4010A, must be upgraded to Version 5010 by January 1, 2012. Unlike Version 4010, Version 5010 accommodates the ICD-10 code structure. This change occurs before the ICD-10 implementation date to allow adequate testing and implementation time.

While the transition to ICD-10 may seem like it's far off in the distance, we have already assessed all products for development changes that will be needed to meet this requirement.

Make Sure You Know How to Meet Version 5010 Level II Compliance
The Version 5010 compliance deadline is less than 90 days away. All entities covered under the Health Insurance Portability and Accountability Act (HIPAA) must be ready to implement the Version 5010 transaction standards by December 31, 2011. In order to meet this compliance deadline, you need to conduct both Level I Internal Testing and Level II External Testing of transactions.

Level I Internal Testing
Level I Internal Testing allows you to identify and address any potential issues that may arise in advance of testing with external business partners. If you have not yet done so, take action now to complete your internal testing as soon as possible. By now, you should have completed Level I Internal Testing, and begun Level II External Testing.

Level II External Testing
For Level II External Testing, you should identify the business partners you currently conduct transactions with, and create a schedule and timeline for external testing with each partner. If you trade with a large number of business partners, identify priority partners to conduct testing with first.