Hospice POE AG
Hospice POE Advisory Meeting
February 8, 2010
10:00 a.m. PT, 12:00 p.m. CT, 1:00 p.m. ET
Attendees: Corrinne Ball, Cindy Cameron, Juliette Chenian, Dr. George Costantino, Nicole Curran, Patty Cutino, Andrea Dumat, Jim Elmore, Michele Fedderly, Emily Fox-Squairs, Paul Giles, Dan Grady, Ann Hablitzel, MaryAnn McGowan, Ann Koepsell, Carol Lawrence, Nancy Malovey, Kathy McMahon, Susan Negreen, Christa O’Neill, Don Pendley, Terri Peterson, Melanie Ramey, Mary Ann Rayrat, Sally Rosiello, Pamela Schaid, Lorraine Sciara, John Stoll, Jeff Towns, Margaret Wolters
Facilitator(s)/Recorder: Juliette Chenian, Emily Fox-Squairs/Christa O’Neill
|Type |Description |Responsible Person(s) |
|(IS/A/C) | | |
|IS |Welcome/Review of Agenda |Juliette Chenian |
| |The meeting was called to order at 10:00am PT, 12:00pm CT, 1:00pm ET. Juliette opened the meeting by welcoming the group and addressed | |
| |some housekeeping items. She then asked everyone present and on the phone to introduce themselves and reviewed the agenda items that | |
| |would be reviewed during the meeting. | |
|IS |Medicare Administrative Contractor (MAC) Update |Jim Elmore |
| |Jim Elmore is the Contract Director for National Government Services’ (NGS) Title XVII and Legacy contracts. Jim told the group that the| |
| |Home Health and Hospice workload is one that CMS recognizes as a high profile workload. He also explained that NGS frequently discusses | |
| |HHA issues/high level inquires with CMS. | |
| |Jim reviewed the scope of Legacy contracts at NGS, the MAC jurisdictions and the MACs that CMS has awarded. Some points from Jim’s | |
| |presentation: | |
| |NGS is one of the largest Title XVIII contractors | |
| |Even though all of the MACs have been awarded, they have not come in as planned due to the many protests | |
| |J14 has been awarded; NGS is subcontractor with NHIC, Corp. | |
| |J6, J8, J11 & J15 have all been awarded, but are currently under protest; J6 & J8 will be the last ones to be decided – possibly | |
| |announced this fall | |
| |Workload transitions will take some time (a year+) so once protests are finalized, NGS will continue to have Title XVIII workload for the| |
| |next couple years | |
| |Advisory Group Questions: | |
| |Question: How is CMS assessing/re-assessing the awards based on the appeal process? Is CMS looking at the letters and surveys from the | |
| |providers? Response: We don’t have access to that type of information from CMS. However, past performance is taken into account when | |
| |awarding the MACs. | |
| |Question: Is CMS looking at hospices that exceeded the cap or looking at any other trends/comparative data to verify whether NGS is | |
| |“tough enough” on its providers? Response: That information hasn’t been brought up as part of CMS’ concerns. CMS tells contractors that| |
| |their goal is to pay claims correctly the first time which will result in good provider satisfaction surveys. | |
| |Question: Are there other contractors interested in J6? Response: Yes – There were multiple contractors who bid J6 and subsequently | |
| |multiple protests. | |
| |Question: What’s the advantage of awarding Noridian the J6 workload if they have no experience to do the workload for that jurisdiction? | |
| |Response: We don’t know what Noridian bid – NGS was not a subcontractor on that bid – typically, subcontractors are named in the bid, so| |
| |if Noridian planned on subcontracting any of the workload, it would be in the proposal. | |
|IS |Audit and Reimbursement Updates |John Stoll |
| |John explained that the Hospice Cost Report Flow has been updated – John did not go through this material; however, he requested the | |
| |group review it and keep in mind it’s 100-level material geared for new providers. Any comments, suggestions or questions about the cost| |
| |report flow should be sent to John via email: John.Stoll@. | |
| |Advisory Group Questions: | |
| |Question: Is there something similar for hospital-based cost reports for the hospice section? Response: The forms are a little | |
| |different; however, the basic information is there for all provider types, but there currently isn’t anything specific to hospital-based | |
| |hospices. John said that he will update the cost report flow to include the forms for hospital-based hospices. | |
| |Question: Is MedPac using cost reports for both independent and hospital-based hospices to pull data, excluding payments for bereavement | |
| |services and volunteer service costs? Response: They have not worked directly with us. They gather cost report information under the | |
| |agreement they have with the state. | |
| |John also reviewed the Hospice cap update and the PS&R redesign system update included in the Audit & Reimbursement Updates PPT. | |
| |Advisory Group Questions/Recommendations: Hospice Cap Update | |
| |Question on Slide 22: Can you divide the providers who exceeded the cap between profit and not-for-profit (NFP) hospices? Of the 36, | |
| |what percentages are profit/NFP? Of the $22M, what are profit/NFP and if you can, what are hospital-based and not hospital-based broken | |
| |down by state? Response: | |
| |Question: Is there more than one way to calculate the cap? Response: CMS has instructed on only one way to calculate the cap; however, | |
| |other methodologies are being explored. For example, one methodology is to take a beneficiary that has had services over multiple cap | |
| |periods and prorate that from the beginning to the end so there would be a portion applied to each cap period. | |
| |Question: Have you had any problems collecting overpayments? Response: Not so far. | |
| |Question: Is it correct for the hospital Fiscal Intermediary (FI) to send the letters about cap overpayments to hospital-based hospices | |
| |that exceed the cap? Response: Yes – the hospital FI would collect cap overpayments in situations where there is a hospital-based | |
| |hospice. | |
| |Question: When will 2008 cap letters be sent? Response: The 2008 letters should be sent in early April. | |
| |Recommendation: Develop education materials on how Hospices can keep track of caps on an on-going basis. | |
| |Advisory Group Questions/Recommendations: PS&R Redesign System | |
| |Question: Is there a step-by-step process anywhere on the website? Response: Yes – there are step-by-step processes for getting set up | |
| |for IACS and the PS&R redesign portion. If providers need assistance with the PS&R redesign set-up process, they can contact either Lisa| |
| |Beatty at 414-459-2972 or Chalanda Wright at 414-459-5581. | |
| |Question: Do you look at more current PS&R information to update hospice stats in finalizing a cost report? Response: We used to do | |
| |that, but based on current instructions, that information is not updated. What gets filed gets in the database for all reports. | |
| |Recommendation: Develop a Computer Based Training (CBT) session on the cost report. | |
| |Juliette asked what more NGS could do to encourage providers to use the PS&R system as well as other tools available to them. The | |
| |members agreed that an article bulleting the advantages of using online systems like PECOS and the PS&R system would be helpful to send | |
| |to the state associations to distribute to their members. Juliette said there are articles about PECOS and the PS&R system that we can | |
| |attach to the minutes for associations to send to their members. | |
| |Recommendation: Define specific groups for NGS communications – identify specific states and provider types affected or specific areas | |
| |within the agency (billing department, business office, etc.) | |
|IS |Education |Emily Fox-Squairs |
| |Emily reviewed the completed and upcoming education sessions for FY2010. The sessions focusing on CR 6440 were very well attended; | |
| |however, Juliette commented that the Hospice Job Aids session was not well attended during the Virtual Convention and stated that the POE| |
| |team has been working diligently to develop job aids based on suggestions and requests from the advisory group and the provider | |
| |community. Juliette expressed her disappointment in the attendance for the job aids session because it seems to reflect that the | |
| |providers did not appreciate its value. The members mirrored the disappointment in attendance and stated that the feedback they’ve had | |
| |from providers is gratitude and appreciation for the job aids that have so far been developed. They also feel it is worthwhile to | |
| |continue developing job aids. | |
| |Advisory Group Questions/Recommendations: | |
| |Recommendation: Offer pre-recorded audio or webinar education sessions for the providers to access at their convenience. Juliette stated| |
| |that NGS is currently assessing different options with several vendors that will enable us to offer a variety of training opportunities | |
| |for the provider community. There is currently a playback feature available for the sessions offered during the Virtual Convention. | |
| |Emily added that a 100-level Hospice session has been added to the CBT courses available in Medicare University. The CBT can be accessed| |
| |at any time. | |
| |Recommendation: Offer a running Q&A a week or so after a webinar or teleconference closes. | |
| |Juliette asked the group if any more CR 6440 sessions need to be offered to the providers. The group said they would ask the provider | |
| |community and let Juliette know if there’s any interest in future sessions on this topic. Emily added that she’s had several | |
| |communications from providers stating they’re receiving an up-front edit for exceeding 450 claim (revenue) lines in FISS when billing | |
| |electronically. The group affirmed that this is an issue. Emily stated that she’s working with the Claims department to figure out how | |
| |this issue can be resolved and will let the group know when she has a final answer. | |
| |Question: Can providers bill 10 days at a time or two weeks at a time to avoid the edit for exceeding the maximum amount of claim lines? | |
| |Response: CMS’ manual states providers shall bill on a monthly basis. There is not currently a claim edit in place to check for monthly | |
| |billing; however, the manual states the CMS requirement is to bill monthly. | |
| |Question: How can the family and beneficiary be educated regarding the Medicare Summary Notice (MSN) for hospice claims? Response: Emily| |
| |stated the MSN will show all the bundled services as covered with an explanation that the beneficiary will not be charged, but does not | |
| |explain that the provider isn’t receiving separate payment for the bundled services. However, the MSN shows the provider’s actual | |
| |payment amount. The provider community needs to be aware of how the MSNs will be formatted for the hospice claims and explain | |
| |reimbursement to the beneficiaries so they’ll understand how it appears on the MSN. | |
|IS |Advisory Recommendations |Emily Fox-Squairs |
| |Emily reviewed the Hospice Advisory Recommendations from the 9/15/2009 meeting. The group did not have any further comments regarding | |
| |the recommendations from the previous advisory meeting. | |
|IS |Educational Job Aid Review |Emily Fox-Squairs |
| |Emily stated that both the Revised Required Billing Job Aid and Revised Change Request (CR) 6440 Job Aid are published on the NGS | |
| |website. The purpose of including them with the materials for this session was for the group to see the changes made. The billing job | |
| |aid was updated to include the CR 6440 requirements. The CR 6440 billing requirements did not become mandatory until January, so they | |
| |were not included when this job aid was originally developed. The CR 6440 job aid has a time reporting chart that was revised and also | |
| |includes a bolded reminder about time reporting. | |
| |The group stated that these job aids are a couple of the best that have been developed for hospice providers and they really appreciate | |
| |the detailed information included in them to help the providers. | |
| |Emily added that the Hospice Subject Matter Expert (SME) team suggested creating a job aid for change of ownership that would include | |
| |links to CMS’ website and asked the group if they felt this type of job aid would be beneficial. The group asked if the same form used | |
| |for change of ownership is also used for change of address and name change, etc. Juliette verified that it is – with that clarification,| |
| |the group felt it would be worthwhile to create the job aid. Emily added that the transactions needed prior to claim will be included. | |
| |Emily addressed another suggestion from the SME team, which was to develop job aids that would include screen shots and descriptions of | |
| |valid values for different types of transactions, such as notice of election, claims, notice of transfer, notice of revocation and notice| |
| |of void/cancel. There would be separate job aids for each type of transaction. The group agreed these would also be worthwhile to | |
| |create. | |
|IS |Pre-submitted Questions and Answers |Emily Fox-Squairs |
| |The group was given time to review the Pre-submitted Question and Answer Summary and the CMS CR 6440 FAQs. Emily did not review each Q&A| |
| |separately as the intention is to allow the group time to examine the questions and answers to determine what comments or follow-up | |
| |questions they had. | |
| |Advisory Group Questions: | |
| |Question (re: Q2 in the CR 6440 FAQs): Is it correct to say that if we have a patient living with a fiancée (meaning there’s no legal | |
| |relationship between them) calls to that person, even though she’s the caregiver, do not qualify? One group member added that CMS | |
| |encourages providers to talk to the caregiver and asked that when we seek clarification from CMS if we could ask CMS to go back to the | |
| |original verbiage and add caregiver communication as appropriate and accountable. Response: Emily found that CMS updated FAQ ID 9970 and| |
| |will update our published material with the updates. The following information is the revised Q&A: | |
| |Q. In CR6440 CMS wrote that: "Report only social worker phone calls related to providing and or coordinating care to the patient and | |
| |family, and documented as such in the clinical records." Does this sentence mean that only calls to the patient and family are to be | |
| |considered for reporting? | |
| | | |
| |A. Because of the nature of a social worker's job, social workers perform a portion of their work without face-to face contact with | |
| |either the patient or their family, which is why CMS allowed social workers to record their phone calls as visits. For instance, off | |
| |hours counseling of the patient and/or counseling of family members who live out of town, would be considered appropriate and necessary | |
| |when provided via a phone conversation. However, it would be inappropriate to record every phone call that a social worker makes on | |
| |behalf of a patient. | |
| |As stated in CR#6440, only social worker phone calls that are necessary for the palliation and management of the terminal illness and | |
| |related conditions as described in the patient's plan of care (such as counseling or speaking with a patient's family or arranging for a | |
| |placement) should be reported. Given the nature of a social worker's job responsibilities, we would expect that almost all social worker | |
| |phone calls reported would be between the social worker and either the patient or the patient's family. It is feasible, however, that | |
| |care coordination phone calls by a social worker to other than family members could be reportable. For example, if a SW facilitates | |
| |alternate care arrangements for the patient in a scenario where the patient's primary caregiver suddenly becomes unavailable to provide | |
| |care, those calls should be recorded. Clinical judgment should be applied to determine if a particular social worker phone call is | |
| |reportable. In essence, report only social worker phone calls related to providing care to and/or coordinating care of the patient for | |
| |the palliation and management of the terminal illness and related conditions, as well as for the counseling of a patient's family, and | |
| |document those phone calls as such in the clinical records (Resource: CMS FAQ ID 9970) | |
| |Follow-up question: If a hospice can count time a social worker spends talking to the family on the phone, why can that kind of time also| |
| |not be counted for the nurse? Response: Because of the nature of a social worker's job, social workers perform a portion of their work | |
| |without face-to face contact with either the patient or their family, which is why CMS allows social workers to record their phone calls | |
| |as visits. | |
| |Follow-up question for CMS clarification (re: Q1 on Pre-submitted Q&A summary): If a patient saw an urologist as a consult and the NP saw| |
| |the patient for the neurologist (acting in place of the physician), why can’t the nurse bill those services as the consultant, since the | |
| |NP isn’t actually performing nursing duties? Follow-up question: Why would the rule for “incident-to” billing apply to a community | |
| |physician but not a hospice physician? Response: We will send the clarification to the group via email once we get a response from CMS. | |
|IS |NGS Updates |Shelly Elliott/Rob Floyd |
| |Shelly and Rob reviewed several changes made to the website in January. A webinar covering these changes was | |
| |originally scheduled in January; however, the webinar was canceled due to lack of interest. Some of the January changes included: | |
| |Business type dropdown added to search function | |
| |Keyword search enhancement | |
| |Search results page includes category breakdown; ability to reduce and filter search results | |
| |Pagination added to top of page so it is now available at the top and bottom of page | |
| |Synonyms added to search, meaning when keywords are entered in the search tool, KeyMatch suggestions are returned with the search results| |
| |As more enhancements are added to the website more educational sessions will be offered as long as there is provider interest in | |
| |attending. | |
|IS |Clinical Education Material |Corrinne Ball |
| |Corrinne reviewed two PPTs with the group in order to solicit feedback on the education materials. | |
| |The General Inpatient (GIP) Level of Care PPT covers information on Medial Review (MR) audits on GIP claims, what GIP is, what MR is | |
| |looking for during review of claims and what kind of documentation hospice providers should have and subsequently include with records | |
| |requested for review. | |
| |Advisory Questions/Recommendations: | |
| |Question: Does NGS have a percentage breakdown of GIP done in hospice inpatient units, skilled nursing facilities, nursing facilities or | |
| |hospitals? Can there also be a similar breakdown for respite care/respite days? Response: That data is currently not available. | |
| |Juliette will check to see if this information can be included in the data for the next meeting. | |
| |Discussion on imminent death bullet on slide 17: One member stated that if a patient is imminently dying (i.e., they survive 24-72 hours)| |
| |and they stabilize the patient, they keep the patient in the inpatient unit where they were sent for GIP but their status is switched to | |
| |general hospice care, which causes a great financial burden on the hospice. Corrine explained that if a patient is truly only surviving | |
| |for 1-2 days, the MR perspective is the patient is still at a GIP level. Another member commented that if CMS does not expect the | |
| |hospice to kick the patient out of the inpatient facility where they were sent for GIP when a patient is imminently dying, and be allowed| |
| |to keep them and bill at a GIP level of care, it would be helpful to have that in writing. Corrinne said she will work with MR and Dr. | |
| |Costantino to get further guidance from CMS to see if we can get clarification in writing. | |
| |Recommendation: Allow the group members to supply some scenarios to include in the PPT. Corrinne said she would welcome any scenarios | |
| |the group could provide that would enhance the PPT to assist the providers. | |
| |The Hospice Services Medical Review and Documentation PPT covers Comprehensive Error Rate Testing (CERT), the MR process and explains top| |
| |hospice denials with documentation tips. It then goes over hospice coverage with scenarios. | |
| |Advisory Questions/Recommendations: | |
| |Question: If a patient revokes hospice, can they re-elect with the same provider on the same day? Response: As far as billing this | |
| |situation, CWF cannot recognize a revocation and re-election on the same day – the final claim and re-election will reject for | |
| |overlapping dates. The records should document that the patient revoked and re-elected on the same day, but a benefit election period | |
| |start date cannot match benefit election period end date. | |
| |Recommendation: Include more scenarios in this PPT as well. | |
| |Question: Where are the psych/social support services handled in review? Response: This is not something we have looked at; however, it | |
| |is something we can investigate see if there’s any type of education needed in this area. | |
| |Emily covered a couple of upcoming CRs that will affect billing. CR 6791 requires providers to split out every time the level of care | |
| |changes. CR 6540 changed the date for mandatory billing for attending physician services to April 1st. | |
| |Recommendation: Create a job aid on CR 6791 and send a draft to the group via email for comments/suggestions. Send a ListServ specific | |
| |to hospice providers once the job aid is finalized and posted to the website. | |
|IS |Clinical Data Review |Juliette Chenian |
| |As the meeting was running over the time allotted, Juliette did not review the clinical data PPT; however, she requested that the group | |
| |review the information and send her any questions about the data provided. | |
|IS |The meeting was adjourned at 3:21pm PT, 5:21pm CT, 6:21pm ET. The next meeting will be on June 8, 2010 in Chicago, IL. | |
Disclaimer
National Government Services, Inc. has produced this material as an informational reference for providers furnishing services in our contract jurisdiction. National Government Services employees, agents, and staff make no representation, warranty, or guarantee that this compilation of Medicare information is error-free and will bear no responsibility or liability for the results or consequences of the use of this material. Although every reasonable effort has been made to assure the accuracy of the information within these pages at the time of publication, the Medicare program is constantly changing, and it is the responsibility of each provider to remain abreast of the Medicare program requirements. Any regulations, policies and/or guidelines cited in this publication are subject to change without further notice. Current Medicare regulations can be found on the Centers for Medicare & Medicaid Services (CMS) Web site at .
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