09/27/2010 and Hospice POE Advisory Group Meeting



09/27/2010 Hospice POE Advisory Group Meeting[pic]

Meeting Minutes

Attendees: Emily Fox-Squairs, Corrinne Ball, Becke Harmon, Christa O’Neill, Cindy Cameron, Dan Grady, Mary Ann Rayrat, Andrea Dumat, Lorraine Sciara, Kathy McMahon, Michele Fedderly, Pam Schaid, Margaret Wolters, Connie Raffa, Karen Noll, Sherl Brand, Judi Lund Person, Don Pendley, Susan Phillips, Nicole Curran, Melanie Ramey, Shelly Elliott, Jean Roberts, John Stoll, Tricia Downey, Jeff Townes, Nancy Malovey, Steve Johnson, Dee Thorpe, Sandra Torres, Maryann McGowan, Cindy Hutchinson

Agenda

1. Welcome and Introductions/Agenda Review

2. Audit and Reimbursement Updates

3. NGSMedicare Web site Updates

4. Medicare University

5. Education

6. Advisory Recommendations

7. CERT

8. Clinical Education Material Review

9. Hospice Data Review

10. Pre-submitted Questions and Answers

11. Connex

12. NGS Updates/Reminders

13. FY2011 POE Advisory Meeting Schedule

I. Welcome and Introductions/Agenda Review

(Emily Fox-Squairs, National Government Services)

The meeting opened at 10:00 a.m. Emily welcomed everyone to the meeting and introduced Becke Harmon to the group. Becke Harmon, manager of Provider Outreach and Clinical Education, said some words of welcome and introduction and explained she is attending on behalf of Juliette Chenian. Emily also thanked Dan Grady for arranging an amazing space for the group to have this meeting. Emily then reviewed the agenda with the group.

No additional items were requested to add to the agenda.

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II. Audit and Reimbursement Updates

(John Stoll, National Government Services)

John Stoll reviewed the handout on electronic submission of cost reports and supporting documentation. Audit is encouraging providers to submit as much information as possible electronically. John stated this would speed up processing cost reports.

Hospice rates have been loaded to the Web site under Audit & Reimbursement (Review > Audit and Reimbursement > Hospice Rates):

Hospice cap information has not yet been finalized for 2008. John will share this information with the group at the next meeting. The 2009 cap reviews are projected to be done by the end of April.

A&R is working with CMS to develop an avenue for providers to check on their cap information throughout the year via the PS&R system. This upcoming release will allow providers to access a summary of the beneficiary count and revenue information to help them monitor the cap.

Comments/Questions

1. Question: Will the information that will be made available to Hospice providers in this system be a Comparative Billing Report?

Answer: What we’re working on with CMS is part of the PS&R system which providers can get access to now. As part of that, providers will have access to a report that has Hospice cap information – this is not the same as the comparative billing report made available on the CMS Web site.

2. Question: Can the 2008 cap stats be sent to the group prior to the next meeting?

Answer: Yes. John will send the information to Emily once completed and she will cascade to the group.

3. Question: Can you provide any information on recoupment efforts for Hospices that are exceeding the cap, including successes other intermediaries are having in recouping monies from providers?

Answer: John said detailed information would have to be gleaned from the Overpayment Recovery Unit; however, in working closely with ORU, John can report that some of the hospices went on an extended repayment plan to pay us back. Any repayment plan greater than 12 months has to be approved by CMS. We have not had any major issues recouping. In fact, some providers have sent us money in advance for 2010 cap. In regards to information about other intermediaries, we do not have access to the data for other contractors and the providers in their jurisdictions. Judy Lund Person from the National Hospice and Palliative Care Organization (NHPCO) stated that NHPCO has been tracking the cap since 1999 and looking at the number of states, the number of providers in each state, and the amount of recoupment. The 2008 data indicates that Palmetto had the largest number of providers over the cap. Palmetto’s recoupment was almost $200,000,000.

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III. NGSMedicare Web site Updates

(Shelly Elliott, National Government Services)

Shelly reviewed the enhancements that will be implemented this fall on the NGSMedicare Web site, such as: a way for the Web site to remember what you’ve previously searched;, enhanced navigational cues; and the ability to change line of business from any page. Some of the new enhancements include: Hot Topics;, production alerts;, tTop five requested pages;, variable text sizing; and broadened content filtering capabilities.

Shelly also talked about the Web site survey. She explained the providers are really encouraged to complete the ForeSee Survey when it comes up on the Web site. National Government Services looks at all of the results and every comment.

Comments/Questions

1. What is the target date to implement this new Web site platform?

Answer: We’re hoping to implement this during the month of October. We are currently in the user acceptance testing phase, which means Corporate Communications is in the process of reviewing the site for functionality and usability issues. Once that phase is complete, we check to ensure all content is still available.

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IV. Medicare University

(Jean Roberts, National Government Services)

Jean reviewed the Medicare University PPT that was made available to the members prior to the meeting. Jean stated if anyone has any questions or suggestions for CBTs, email Jean at: Jean.Roberts-IL@.

Comments/Questions

Recommendation: Convert some of the hospice job aids into CBTs.

1. Question: How many Hospice providers have utilized the Medicare University CBTs? Can we find this information by state?

Answer: We will look into this and provide an update to the group.

Corrinne asked if we would be able work with the national organization that provides CEUs and provider them through Medicare University. She asked if there are any organizations for Hospice to which we can submit education to obtain CEUs? Judy Lund Person said NHPCO would be very interested in talking about how to convert some education to CEUs that could be used by various specialists.

Emily stated some suggestions she’s received for 2011 CBT education include: Use of occurrence span code 77 and how to bill using it including scenarios. Another topic for scenario-based CBT is location and how to bill location codes. Emily asked if these types of education including scenarios would be helpful. Consensus from the group was that a scenario-based CBT would be very helpful.

Recommendations:

1. Create a CBT on how to use the LCDs and where to find them. Becke stated there is already something in the works to create a CBT with this information.

2. Scenario-based CBT on how to document – give examples of documentation notes. It would be helpful if the CBT be expanded to include information on how a nurse should chart information.

3. Create a CBT dedicated to new Hospice providers.

4. Include directions on billing for attending physicians that are not part of the Hospice.

5. Create a CBT on how to locate all of the different job aids.

6. Provide a more direct link to Medicare University based on provider type.

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V. Education

(Emily Fox-Squairs, National Government Services)

Emily reviewed the completed education sessions for FY2010 and the sessions planned for FY2011. Emily explained that for some sessions she only had the registrant count. Any number with an ‘A’ next to it indicates the number of attendees; any number with an ‘R’ indicates the number of registrants. Emily stated that many times the number of registrants is greatly different than the number of actual attendees. She asked that members relate to providers that if they register for event, please attend; if they do not plan to attend after registering, please cancel the registration to allow other providers to attend but that could not originally register based on the cap on attendees (current cap is 125 attendees/lines). Emily explained there are a lot of general courses hospice providers can attend at the face-to-face live education in Michigan (10/18/10) and Wisconsin (11/1/2010). The courses available can be found here: .

Comments/Questions

1. Question: Any news or updates about the MAC transition?

Answer: CMS has not yet released any further information about the J6 award. There is no new information or news from CMS about the outstanding protests.

2. Question: Could you include a column on the Completed and Upcoming Training document that includes “Intended Audience” and bold that the upcoming sessions are tentative dates?

Answer: Yes. Emily will update the document including intended audience information and send to the members.

Recommendation: Michigan and California associations would like billing and clinical representatives to present at their meetings. Emily asked that you please let us know as soon as possible after dates have been set so we can determine whether we can attend.

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VI. Advisory Recommendations

(Emily Fox-Squairs, National Government Services)

Emily reviewed the Advisory Recommendations from the previous meeting. There were no further comments from the members.

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VII. CERT

(Corrinne Ball, National Government Services)

Corrinne reviewed the CERT PPT made available to the members before the meeting. There were no comments from the members.

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VIII. Clinical Education Material Review

(Corrinne Ball, National Government Services)

Corrine reviewed the PPT entitled “How to Respond to a Hospice ADR” and asked for comments/recommendations from members. Corrinne states a lot of questions she gets from providers that involve explaining/understanding the types of probes -: service-specific probes and provider-specific probes - so she included this information in the PPT.

Comments/Questions

1. Question: Can we take this PPT to our members even though it says Not for Publication?

Answer: Information from the PPT can be shared but the actual PPT should not be used.

Recommendations:

1. Send an announcement to providers when a service-specific probe is happening. Corrine said we will take this suggestion to Medical Review. This can possibly be included in a Listserv and Web site article.

2. Slide 9 – Types of Medical Review Audits: Members commented it is important for providers to understand the difference in the two types of probes.

3. Slide 22 – Physician Certification Statement: Members commented to add to the last bullet point-Subsequent Certification. Add only 1 one physician signature, hospice physician.

4. Slide 23 – Physician Certification Narrative: Members commented that there are regulations coming out soon to address the face- to- face encounter every 180 days. Members suggested that this be added to the education once it is finalized.

5. Slide 24 – Revocation: Delete first bullet point (Hospice coverage may be revoked at any time). Members are afraid providers will take this as they can revoke the benefit for the beneficiary. Instead add: The patient/representative may revoke the hospice benefit at any time.

6. Slide 25 – Hospice Discharge: Members would like a new slide added after this slide to address discharging for cause. Corrinne will review 42 CFR 418.24 for exact wording of discharge for cause. Members suggested that we stress they can not discharge because the patient goes outside the plan of care, unless there is repeated abuse and very good documentation to support this. Also, very good documentation if the patient is violent and abusive to staff.

7. POEAG members suggested that when talking about Medical Review process to add education on Denial Reason codes. Corrinne is developing a one-page document that gives the denial reason codes, the MSN message, and the narrative. Members stated this would be helpful to put out on the websiteWeb site so providers can look up what the denial reason code means. Also, we will plan to tailor the education to give examples of why the claims would deny with specific reason codes and add to this presentation.

Corrinne next reviewed the PPT entitled Hospice Services – Medical Review and Documentation.

Comments/Questions

Recommendations:

1. Slide 17 – Plan of Care Documentation: First bullet point reads “Must be established on the same day as the individual’s assessment if the day of the assessment is to be a covered day of hospice care.” This statement brought about a lot of discussion. Members stated that we should discuss integrated plan of care. Discussion between this statement and the Code of Participation (COPs) gives a different time line for initiating the plan of care. One member gave an example of a patient being brought on service and has pain control issues. The initial plan of care would be to address the patient’s pain, and then as the assessment is performed the POC would be developed in detail. Corrinne plans on expanding the education in this area and using the scenario to help give providers a clear idea of developing the plan of care.

2. Slide 19 – Hospice Discharge: Remove first bullet (Beneficiary decides to revoke the hospice benefit)

3. Slide 20 – Be prepared for Discharge: Remove the first bullet point. Bullet point 2: add “safety” to this statement. Bullet point 3: add “or attending physician” to this statement. Members also suggested that another bullet point be added to address the discharge summary goes to the attending physician and the attending physician.

4. Slide 23 – Discharge planning: members suggested adding a comment that documentation is key for Family Counseling/Support – what services are being implemented and any education provided to the patient/family. Move this slide to position 21.

5. Members suggested moving slides 19-23 to the end of the presentation. These slides all discuss the discharge planning. Members also suggested adding new slides to address notices and ABN, and this will be put at the end of the presentation.

6. Slide 24 – Levels of Care: Members suggested for this section that clinical does not review coverage criteria for these levels of services; instead give education as to the documentation requirements.

7. Slide 25 – Routine Home Care: Members suggested that we give statistical data on how many claims are billed at this level of service. Give information about what types of documentation would be expected at this level of service.

8. Slide 27 gives an example of some charting that shows documentation that is very vague and would not support terminal prognosis. Slide 28 gives an example of better qualitative documentation that may help support terminal prognosis. The members liked the contrast between the two types of charting and recommended that this theme be carried out through the other levels of service.

9. Slide 29 – Inpatient Respite Care: Members suggested removing this slide and do not discuss Respite Care.

10. Slide 30 – Inpatient Respite Care: Members stated to remove this slide and do not discuss Respite Care. Members stated to give scenarios only for charting respite care and what is considered an “occasional” basis.

11. Slide 31 – Continuous Home Care: Members suggested to remove the first bullet point.

12. Slide 32 – Continuous Home Care: Members suggested reviewing the language used on this slide. The term suggested was SN (skilled nursing) to mean an RN, LVN or LPN. Change the terminology in bullet point #2 from home health aide (HHA) to a HA-Hospice Aide.

13. Slide 33 was left blank and Corrinne asked for suggestions for developing a scenario for continuous care. We have developed a small work group that will examine the scenarios and re-work them for this presentation.

14. Slide 35 – General Inpatient Care: A member suggested that we do not discuss what GIP is, but what is wrong with the documentation and how to improve the documentation. This theme really needs to be developed with each level of service. Members stated that anyone in hospice that would be attending this session knows what the level of services are, but needs instruction on what types of situations and documentation is needed to meet this level of service. Members suggested removing bullet point and also remove slide 42. Members stated that the providers will get confused by these statements and assume that if they have a beneficiary who has suffered from care giver breakdown, they can admit the patient to a GIP level.

15. Slide 39 – Documentation that may support GIP level of care: Members suggested adding a scenario to help explain bullet point number 2 that states “frequent evaluation by physician/nurse.”

16. Slide 40 – Documentation that may support GIP level of care: Members agreed to work up some short examples for each bullet point to demonstrate what type of care and documentation would be expected at this level of care.

17. Slide 42 – Caregiver Breakdown: Remove this slide

18. Slide 45 – Documentation that could support non-payment of services: Members suggested to expand on bullet point #2: “Checklists without narrative”- Some check off lists are very good and give an accurate description, other check off lists are very vague and may require additional documentation to help “paint the picture” of the terminal prognosis or level of service being billed. Bullet point #3: Members suggested that the statement “weight without height” be clarified. Last bullet point: remove the word “support” and change to “results in.”

19. Slide 46 – Documentation that could support non-payment of services: Change wording in the title from “could support” to “results in.”

20. Slide 47 – Know what is important to chart: Remove bullet point #3

This presentation is 94 slides, so we did not finish reviewing all the material. A small workgroup has been developed to re-work this presentation and scenarios.

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IX. Hospice Data Review

(Corrinne Ball, National Government Services)

Corrinne asked that the group review the Hospice Data PPT and send any questions to Emily (Emily.Fox-Squairs@) or Dr. Costantino (George.Costantino@).

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X. Pre-submitted Questions and Answers

(Emily Fox-Squairs, National Government Services)

Emily reviewed the pre-submitted Q&A document. The question (see below) was asked at the last meeting and Emily just wanted to make sure everyone had the response. There were no questions asked prior to this meeting.

We are wondering how to handle billing for patient's who seek care outside of the hospice plan of care (they've gone back to a hospital setting for care that was not authorized by the hospice IDG) and are discharged for that reason.

Answer: First, the hospice cannot discharge a patient for seeking care outside of the plan of care, unless it’s a discharge for cause (this other care would have to be interfering with the hospice’s ability to provide care, etc), and all the procedures related to discharge for cause must be followed. Those procedures are spelled out in 42 CFR 418.26(a)(3).

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XI. Connex

(Emily Fox-Squairs, National Government Services)

Emily reviewed all the Connex information provided to the group prior to the meeting. Connex is being rolled out by provider type. The WI and MI FTF sessions will include a presentation on Connex.

Comments/Questions

1. Question: Will Connex have Hospice history?

Answer: All information in Connex is the same information that providers can see in CWF and hear on the IVR. “Application Date” field (when accessing) in HIQA gives the opportunity to pull up past data.

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XII. NGS Updates/Reminders

(Emily Fox-Squairs, National Government Services)

Emily encouraged members to share ICD-10-CM information with providers. Also, as a reminder, Version 5010 comes out before ICD-10-CM.

Emily stated that reason code U5172 is hitting several providers’ claims. The date of earliest billing is not hitting the CWF. The Systems area has submitted a request for a fix on this reason code. The problem with U5172 will be brought up at the October 21st meeting – the fix will be included in next available release, which is in January.

There has been an issue with providers downloading PC-ACE from other intermediaries/Medicare contractors. NGS PROVIDERS SHOULD ONLY BE DOWNLOADING PC-ACE FROM THE WEBSITE.

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XIII. FY2011 POE Advisory Meeting Schedule

(Emily Fox-Squairs, National Government Services)

Emily discussed the tentative dates for the POE AG meeting in 2011:

February 9 (San Diego, California – Home Health on February 8)

June 21 (Chicago, Illinois – Home Health on June 22)

September 7 or 8 (New York, New York – Home Health on September 8 or 9)

Meeting adjourned 3:07pm.

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