Jurisdiction M (JM) Home Health and Hospice (HHH) POE Advisory Group (POE-AG) Minutes: July 18, 2024

Published 08/01/2024

Facilitators: Dan George and Charles Canaan

Attendees: 18

Welcome

Our Goals

  • Establishing and maintaining strong relationships with Palmetto GBA and our provider community 
  • Meeting with Palmetto GBA and the provider community on a quarterly basis 
  • Providing the communication tools to facilitate thorough and prompt transfer of information 
  • Coordinating issues within the provider community to adequately reflect the concerns of the majority

POE-AG Goals and Purpose — HHH POE-AG Charter.

Old Business: Prior POE-AG Suggestions/Recommendations: N/A

New Business: POE-AG Training Suggestions and Education Recommendations
Participating members have the opportunity to benefit the provider community by helping to guide Palmetto GBA educational strategy for the upcoming year.

Information to Share:

  • Palmetto GBA Interactive Voice Response System Has Been Updated
    In an effort to increase our customers' experience and efficiency, Palmetto GBA has reduced the number of options in our Interactive Voice Response (IVR) system. These minor changes to our IVR will impact providers from Jurisdictions J and M. When you call Palmetto GBA you will encounter the following four options.
    • Palmetto GBA Electronic Data Interchange (EDI)
    • Provider Enrollment
    •  Items like claims, financials, eligibility, appeals or other information
    • Providers who have not been assigned a Provider Transaction Access Number, or PTAN

An additional change we implemented is that Option “0” has also been removed from the main menu.

Home Health

Hospice

  • Pre-Payment Review Results for Hospice Provisional Period of Enhanced Oversight on New Hospices in Texas for January to March 2024
    Seven hospices completed Edit Effectiveness during this period and all seven were non-compliant and were progressed to a subsequent probe.
     
  • The Future of the Hospice Benefit Component of the Value-Based Insurance Design (VBID) Model
    Later this year, CMS will issue additional guidance to ensure that all obligations of any impacted organization may be met in a timely and reasonable manner so that hospice beneficiaries in the Hospice Benefit Component maintain a coordinated, seamless care experience.
     
  • Hospice Certifying Physician Medicare Enrollment Information
    This article was revised to strengthen the information that nonphysician practitioners cannot certify for the Hospice Benefit and update it to the delayed effective date.
     
  • Reason Code 17729 
    Revised to correct effective dates. This reason code will edit the claim’s attending physician’s NPI data against the PECOS Enrolled Physicians File for hospice claims, type of bill 81X and 82X (excluding 8XA, 8XB, 8XC, 8XD and 8XE) with a Statement "From" Date on or after June 3, 2024.
     
  • Hospice Quality Reporting Program (HQRP) Compliance 
    Notification of Non-Compliance to be Sent to Hospice Providers that Have Not Submitted Required Quality Reporting Program (QRP) Data. The initial notification letter outlined the process for reconsideration and include a reconsideration request deadline date of August 14, 2024. After the reconsideration process has occurred and prior to October 1, 2024, CMS will provide the MACs with a final list of Hospices that failed to comply with the data submission requirements.

    About 444 hospices in Palmetto GBA’s jurisdiction were issued non-compliance letters, with 295 of them in TX. The second largest state was GA, with 48 letters. AL and KY had zero letters. 

    Of the hospices that were non-compliant, 429 hospices did not meet Hospice Item Set (HIS) and 22 did not meet Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Hospice survey. Six did not meet both requirements. 

RCD News

  • Home Health Review Choice Demonstration Extended Five More Years
    Effective June 1, 2024, the Centers for Medicare & Medicaid Services (CMS) will extend the Review Choice Demonstration for Home Health Services for an additional five years. The demonstration will continue in the current demonstration states of Illinois, Ohio, Texas, North Carolina, Florida and Oklahoma.

    As part of the extension, CMS removed Choice 3: Minimal Review with 25% Payment Reduction from the initial choice selections. Palmetto GBA has proactively reached out to coordinate with the small number of affected providers to make a new review choice selection beginning July 1, 2024.
     
  • Submit Home Health RCD Pre-Claim Review Requests with your Correct PTAN (palmettogba.com) Palmetto GBA is seeing an increase of pre-claim review (PCR) submissions with incorrect Provider Transaction Access Numbers (PTANs), also known as CMS Certification Numbers (CCNs).
     
  • Monthly Home Health Review Choice Demonstration (HH RCD) Provider Webinar Schedule
    • Wednesday August 7, 2024
    • Wednesday, September 4, 2024
    • Wednesday, October 2, 2024

Coming Soon

  • With Palmetto GBA’s transition to Cvent for educational webinars, we are beginning to develop on-demand webinars. The first ones to be produced are:
    • Hospice Appeals
    • Home Health Physician Documentation 
       
  • Comparative Billing Reports (CBRs) for certain Hospices 
    • The CBR’s topic is Administrative Law Judge (ALJ) appeals
    • The CBRs will be sent via USPS mail starting in August
    • The goal of the CBR is that hospices ensure they have information needed in an AJL appeal available and possibly in prior appeals, to have successful outcomes at any level of appeal.
    • CBR information is one of the many tools used to assist individual providers to become proactive in addressing potential billing issues and performing internal audits to ensure compliance with Medicare guidelines.

Upcoming Education Events

eServices

eServices Displays Accountable Care Organization Model Information 
On January 2, 2024, eServices made an update to display information on the ACO models for Part A, Part B and HHH providers that are participating in an Accountable Care Organization. A new menu tab, ACO, will display to provider account administrators.

Open Discussion

Question: Is there an update to the Claims Payment Issues Log issue “Hospice Certifying Physician Claim Edit, Reason Code 17729?”

Answer: Our research found that physicians were missing from or had incorrect records in the Hospice PECOS Physician File, which is used for this edit. The file issues were corrected on July 16, 2024, and claims received since should not reject with reason code 17729 in error.

Within 30 days of this update on July 23, 2024, the Medicare Administrative Contractors (MACs) will begin the reprocessing of all claims with the following criteria:

  • Rejected with reason code 17729 
  • Types of Bill 081x or 082x 
  • Claims with 'FROM' dates on or after 6/03/2024

Claims that correctly rejected for 17729 should reject again. 

Question: Are there updates to the Targeted Probe and Educate (TPE) Active Medical Review topic “Hospice Services Bene Sharing”? There is concern that the postpay claims selected for this review do not match the review topic, meaning the patients never were on service with another hospice. 

Answer: Palmetto GBA suspended the post payment Hospice Services Bene Sharing TPE edit and released claims that were not reviewed during the audit. Hospices that have claims suspended for this edit do not need to respond to Additional Documentation Requests (ADRs). Any claims that we have received documentation for will be reviewed. Palmetto GBA has sent communication to each provider related to their release from the audit. Palmetto GBA will subsequently send notification letters to providers selected for the Hospice Services Bene Sharing edit that will occur in a prepayment manner.

The easiest way to know if a claim was released from review is to look for a change in the status in Direct Data Entry (DDE), as it will move out of SB6001 to a general processing status. The claims will still go through normal processing/eligibility edits. Additional notifications may also be issued.

Question: Anther home health MAC posted an article about documenting changes of a home health certifying physician or nonphysician practitioner (NPP) during an admission. Is Palmetto GBA posting an article like that?

Answer: Yes. Since the date of this POE-AG meeting. The article Home Health Certifying Provider Change has been posted. 

Next Meeting: Thursday, October 10, 2024


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