Home Health and Hospice Coalition Questions and Answers February 5, 2024

Published 03/20/2024

Meeting Date: February 5, 2024

Meeting Time: 10 a.m. – 12 p.m. ET

Meeting Location: Virtual

Meeting Hosts: Tim Rogers, President and CEO; Shannon Pointer, DNP, RN, CHPN, Senior VP, Hospice & Palliative Care and Shannon Mintz, RN, MBA, COS-C, VP of Home Health and Regulatory Affairs, AHHC of NC and SCHCHA

Meeting Agenda

Review Choice Demonstration (RCD) Questions Submitted for Response

Question: Providers are experiencing non-affirmations specific to ICD 10 CM I-codes (cardiac and circulatory) and have been told by Palmetto GBA that this is new. Specifically, all the conditions in the I-code are being required, however, CMS does not require that patients have all DX codes listed in the I-code. CMS has not posted any information indicating a change in requirements or interpretation. Has CMS provided any new guidance to Palmetto GBA?

Answer: Palmetto GBA has no new guidance from CMS on any changes in requirements.

Question: Has Palmetto GBA changed its position related to affirming/non-affirming claims where the secondary diagnosis is not contained within the face-to-face? If so, what is the underlying statutory/regulatory support for this change in position?

Answer: Palmetto GBA has no new guidance from CMS on any changes in requirements.

Question: Can Palmetto GBA provide any additional clarification on RCD as the demonstration ends May 2024? This was a question in our October 2023 meeting, and we would like to ask for any additional updates you may have at this time for the coalition.

Answer: We have no further instructions at this time. The Home Health Review Choice Demonstration is set to end on May 31, 2024.

EDI

EDI recertification article: JM Part A Annual DDE Recertification.

Provider Enrollment

Physician Enrollment for Hospice: The edit will start on May 1 on the Attending Physician field, we are awaiting information for the editing of other attending fields.

Question: Please provide any updates on the new stay of enrollment process from CMS.

Answer: The change request is not final; we will provide updates when information is available.

Question: What is the actual effective date this will begin?

Answer: A start date has not been determined due to the change request is not finalized.

Question: How will providers know they are put into a stay of enrollment?

Answer: The revalidation process triggers the stay of enrollment if the provider has not completed the required actions.

Question: What is the process for removing the stay if it's due to ownership issues?

Answer: When the revalidation process is completed, the provider is removed from the stay of enrollment.

Question: Provider enrollment/cost reports — We would like to understand what circumstances Palmetto GBA allows a buyer in a CHOW situation to elect to forego the CHOW cost reports and will accept the cost report as filed.

Answer: if there is a CHOW (change of ownership), for cost report purposes, the seller is responsible for the first part of the year and the buyer is responsible for the rest of the year.

Home Health

Please review requirements for homebound status on the face-to-face and the plan of care.


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