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Home Health and Hospice (HHH) Provider Outreach and Education (POE) Advisory Group Meeting Minutes: April 9, 2020


Facilitators
Dan George, MaKisha P. Callaham, Cara Mia Wilkins, Elizabeth L. Brogdon and Charles Canaan

Attendees: 20

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

  • Can Palmetto GBA create tools to its website related to the frequent billing codes home health and hospice use?
  • Currently working on Home Health and Hospice Coding Guides

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

Upcoming Education Events

eServices

  • eServices Extends Administrator Unlock Feature Beyond 30 Days
    • Palmetto GBA has implemented new “Disable User” functionality in eServices that will disable a user that has been inactive for 30 days instead of terminating the User ID. Administrators will now be able to enable the user up to 120 days after 30 days of inactivity.
  • eRCD
    • eRCD is a new feature on the Provider Dashboard within eServices that provides you with the ability to monitor your Review Choice Demonstration (RCD) results
  • New eServices Appeals Feature
    • Palmetto GBA is pleased to announce that eServices has been enhanced with the addition of new appeals features. Part A and HHH providers that are actively using eServices and have access to the Claims Inquiry tab can get up-to-date appeals status, view and download decision letters, and more.

Open Discussion

Question: With the Medical Review Administrative Relief Related to the Novel Coronavirus (COVID-19) Pandemic pausing the Targeted Probe and Education (TPE) audits, will providers resume TPE where they left off?

Answer: Yes, it would restart where they stopped. For example, if a provider had 15 reviews completed prior to pause, the contractor will issue ADRs to get to the TPE threshold of 20–40 reviews per round.

Question: With the pausing of the Home Health Review Choice Demonstration (RCD), providers may continue to submit pre-claim review (PCR) requests during the pause. If they don’t continue PCR request submissions and submit claims without unique tracking numbers (UTNs), will the claims be reviewed when RCD is resumed?

Answer: According to the Coronavirus Disease 2019 (COVID-19) Provider Burden Relief Frequently Asked Questions (FAQ) (PDF, 26.35 KB), following the end of the PHE for the COVID-19 pandemic, the MAC will conduct postpayment review on claims subject to the demonstration that were submitted and paid during the pause. There have not been additional updates to state if would be 100 percent reviews, or only a certain percentage number of claims to be postpayment reviewed.

Question: About the accelerated/advance payments, are the maximum amounts based on a defined period?

Answer: Accelerated payment amounts are calculated based on the provider’s three- or six-month reimbursement history (October 2019 through December 2019, or July 2019 through December 2019). The claim reimbursement history is utilizing dates when claims were fully adjudicated and were in an approved-to-pay location. For Part A providers, this calculation will vary from the PS&R claims date of service (DOS) and Paid Date calculations.

Question: With CMS providing relief to HHAs on the timeframes related to OASIS Transmission, will the OASIS need to be submitted prior to the claim?

Answer: Yes, the OASIS will need to be submitted prior to the final claim being submitted. If not, the claim will edit for the missing OASIS.

Question: For hospice physician services completed via telehealth, is the 95 modifier required?

Answer: The 95 modifier is not required on the claims; however, for reporting and review purposes, having that modifier on there would probably be best.

Question: Can hospices submit a principal diagnosis code of U07.1 for COVID-19 on a Notice of Election (NOE) or claim?

Answer: The COVID-19 diagnosis code U07.1 became effective April 1, 2020. The Medicare Administrative Contractors have confirmed it may be used as the principal hospice diagnosis. However, it was not implemented into the processing systems until April 6, 2020. Claims and Notice of Elections (NOEs) submissions that were received prior to the implementation date, were returned for an invalid diagnosis code with reason code 19508 (an invalid diagnosis code). Claims and NOEs with the U07.1 diagnosis code, received on or after April 7, 2020, are processing without the edit.

Hospice providers who may have had a late NOE due to the diagnosis code implementation date, with election dates of April 1 through April 6, 2020, may request an exception. The exception remarks should state “NOE Exception Request: NOE submitted timely with DX code U07.1 for COVID-19 between 4/1/20 and 4/6/20, was returned because the code was not implemented at that time.”

Hospice providers should note that the principal diagnosis reported on the claim is the diagnosis most contributory to the terminal prognosis. Hospice providers may not report diagnosis codes that cannot be used as the principal diagnosis according to ICD-10-CM Coding Guidelines and require further compliance with various ICD-10-CM coding conventions, such as those that have principal diagnosis code sequencing or etiology/manifestation guidelines.

Question: Can you elaborate on the extended timeframe from the auto cancel of Requests for Anticipated Payment (RAPs)?

Answer: Palmetto GBA has extended the auto-cancel timeframe of RAPs by 90 days from the paid date of the RAP, retroactive to March 1, 2020.

Question: Did all the Medicare Administrative Contractors (MACs) extend the RAP cancellations by the same amount?

Answer: Palmetto GBA does not know if the other MACs have extended the timeframes or by how long.

Question: A stipulation for qualifying for the accelerated/advance payments was that the provider could not be under medical review. Does that mean if a provider is currently under review for TPE, they could not be approved for accelerated/advance payments?

Answer: No, if a provider is on TPE, they are still eligible for accelerated/advance payments. If a provider is on medical review by the Unified Program Integrity Contractors (UPIC), they would not be eligible for accelerated/advance payments.

Question: Does the Medical Review Administrative Relief Related to the Novel Coronavirus (COVID-19) Pandemic apply to all providers?

Answer: The relief applies to most contactors, including the Comprehensive Error Rate Testing (CERT) program. However, fraud and abuse contractors, such as the UPIC, will continue reviews.

Closing
The next POE-AG Meeting date is scheduled for July 9, 2020.





Last Updated: 04/29/2020