3/2/2023 Hospice POE Advisory Group Meeting
Meeting Minutes
Meeting Time: 2:00 p.m. ET
Member Attendees: Kenneth Allen, Gina Balkus, Dawn Beck, Joan Berger, Vickie Brand, Dean Chalios, Jeanne Chirico, Sheila Clark, Patrick Conole, Kim Dallaire, Craig DeVoe, Linda Emmons, Linda Emmons, Theresa Forster, Marie Fredette, Sharon Fries, Kristine Green, Barb Hansen, Jessica Hausauer, Sara Heatlie, Leigh Ann Howard, Tina Krajnikovich, Brianna Lindell, Judi Lund Person, Karen Madrid, Edward Martin, Christine McMichael, Christine Meny, Nicholas Oliver, Nick Paquette, Andrea Patrick-Baudet, Colleen Pierro, Mary Jane Ruppert, Francisco Otero Santiago, Lisa Schweitzer, Charlotte Sloan, Jennifer Stark, Kerry Stevenson, Jamie Thompson, Cindy Vanyi, Katie Wehri, Beth Werner, Tracy Wodatch, Lori Young
National Government Services Associates: Erin Musumeci, Andrea Freibauer, Christa Shipman, Nancy Krupka, John Stoll, Kim Hitzemann, Jessica Channell, Rachel Caron, Laura Brown
Agenda
- Welcome
- Hospice Cap Update
- Medical Review
- End of the Public Health Emergency
- FY 2023 Education
- Education Material Review
- Hospice TPE and ADR [PPT]
- Orientation to Hospice Medicare [PPT]
- Hospice Documentation Checklist [PDF]
- Education Topic Requests
- Updates/Reminders
I. Welcome
Erin Musumeci and Andrea Freibauer, NGS
Erin and Andrea welcomed everyone to the meeting and extended a special welcome to the new members. Members reminded that Emily Fox-Squairs is our new HH+H POE Manager however; she is out of the office and will not be on the call today. Andrea did a formal introduction of herself explaining that she has moved over from the Part A POE team to join the HH+H as the Hospice Billing SME, as well as providing a brief background of her 25+ years of various Medicare work experience. Erin expressed excitement on behalf of the HH+H POE team for the new educational offerings and opportunities to come. The team is looking forward to a productive year ahead with a lot of positive change with this group. Erin reviewed the meeting agenda items, the intended flow of the meeting, housekeeping items, as well as the mission and purpose of the meeting.
II. Hospice Cap Update
John Stoll, NGS
John reviewed the Hospice Cap information:
- Hospice Cap self-reporting deadline was 2/28/2023 via Pro-Forma
- NGS does allow for mailing time, but if the report is not received by 3/7/2023 providers will be placed on payment withholding
- 2022 Hospice Cap; finalized by end of CY 2023 (November/December)
- Cursory review of self-reporting pro-forma, will be completed by end of first quarter 2023, during that time:
- Providers reporting money owed due to cap will be issued a demand letter
- Providers reporting nothing owed will get an acknowledgement letter
- Cursory review of self-reporting pro-forma, will be completed by end of first quarter 2023, during that time:
- Look backs for 2021, 2020, and 2019 will take place once the cursory review for the 2022 hospice cap is complete
- Look backs will continue into the 3rd and 4th quarters 2023
- 2022 Hospice Cap calculation is impacted by the change in sequestration
- 0% sequestration in place from 10/1/2021-3/31/2022
- 1% sequestration in place from 4/1/2022-6/30/2022
- 2% sequestration in place from 7/1/2022 – 9/30/2022
- 2021 Hospice Cap has been fully calculated/completed
III. Medical Review
Nancy Krupka, NGS
Nancy reviewed the following pre-pay edits for hospice:
JK has four hospice edits:
- 5ANK: Hospice for LOS > 365 days. Round 1 is post pay. Round 2 and 3 are pre-pay.
- 5ANL: Hospice with IP stay of 7 days or greater. Pre-pay edit
- 5ANP: Q-code pre-pay edit
- 5ANQ: Hospice with Alzheimer’s dx. Round 1 is post-pay edit. Round 2 and 3 is pre-pay
POE AG Member Feedback/Questions with NGS response:
Member Feedback: There is some confusion from Connecticut providers regarding denials they are getting for the QIO information not being listed on the election statement. Are you seeing that trend or is there anything you can speak to on that?
NGS Response: MR is discussing this internally; there is no information to share at this time. NGS continues to encourage providers to use the Model Example of Hospice Election Statement (PDF) and the Model Hospice Election Statement Addendum - July 2021 (PDF) which are available on the CMS website, and include all the required fields.
Member Feedback: Are you referring to the updated version that includes the QIO; are there two? Is it possible for NGS to re-send the most updated forms out to providers so they would have it? Having two different forms out there is confusing.
NGS Response: The most up-to-date model forms are available on the CMS website. Providers should only be using those forms and not obtaining any hospice forms via Google search.
Member Feedback: Rhode Island hospice providers have concerns due to some of the more fraudulent-looking cases that keep ending up in the newspaper for long LOS. Will MR start looking closer at Long LOS edits?
NGS Response: We are looking at LOS and we do look for any type fraudulent activity when we do these edits. Overall, we are not finding anything suspicious. At least not in JK. Our denial rate for the LOS edit was very low. We try to work as best we can, as long as the documentation can support the need we are more lenient.
Member Feedback: Maybe review activity can be focused on some of the fraudulent providers whose live discharge rates are greater than 50%. No one could defend a discharge rate that high.
NGS Response: There may have been an edit like this several years ago and we can look into this for the future. Overall, I believe the majority of hospices are doing the right thing.
Member Feedback: Is there anywhere in NGSConnex to check an entire NPI for open medical reviews, TPE notices, ADRs, etc.? We have had issues and inconsistencies in receiving notices in the mail and are seeking a more reliable way to check for these notices.
NGS Response: The notices are mailed to the address that shows in PECOS. If your address is not current or updated there, then you need to get it updated. NGS MR will do our best to mail the letters to the right people. We address all of our letters to the compliance officer. In addition, you can find any claims that had an ADR sent in the NGSConnex portal.
IV. End of the Public Health Emergency
Andrea Freibauer, NGS
Andrea shared and reviewed the most current 10 page Hospice- CMS Flexibilities to Fight COVID-19 fact sheet with details specific to the end of the PHE. Information was provided regarding flexibilities and/or waivers that were put in place during that time that will soon be expiring as well as how that could potentially affect hospice providers in the next coming months up to the scheduled end date of 5/11/2023. It was encouraged providers utilize this tool and look through it carefully as the expiration dates are not the same for all items and some things have already expired, those will be listed in in red font. Members were given instruction on where and how to locate the fact sheet through the NGSMedicare website as well as through the CMS website.
POE AG Member Feedback/Questions with NGS response:
Member Feedback: Clarification offered from POE AG members regarding specific statements included in the PHE fact sheet and how the national associations are in communication with CMS to gain clarity on the changes coming with the end of PHE also, how these changes will affect hospice providers. There is mention that this is not the last hospice list of flexibilities and CMS is preparing yet another one with no idea when it will be out. Even the answer to that question about when that calculation starts again is not clear. The 5% volunteer requirement for hospices is a concern for hospices and the documentation requirements that come with it; how will hospices remain compliant, how will this calculated once the PHE ends? This is an annual number and this will be impact hospices for an entire year after the PHE ends. There has been no clarification yet, and this needs monitoring.
NGS Response: CMS and our entire POE team here at NGS, Part A, B along with the HH+H team have been preparing for the end of the PHE since it started. We will continue to monitor these changes closely, and as mentioned earlier, we encourage providers to stay tuned. Will be preparing materials based on new information as it comes to us to be able to educate our providers. In addition, we will keep all of your feedback and recommendations from these meetings recorded for possible training topics.
Member Feedback: Will telehealth go away for the FTF?
NGS Response: Yes, this is located on page 4 within the Hospice- CMS Flexibilities to Fight COVID-19 document. This statutory change will expire on 12/31/2024.
V. FY 2023 Education
Erin Musumeci/Andrea Freibauer, NGS
Erin opened up discussion regarding upcoming education plans and advised the group that she and Andrea have been very busy developing new education as well as working on updating the existing hospice clinical and billing content that is posted on the NGSMedicare website’s education page. Members were encouraged to speak up and make suggestions of what they would like to see for provider education in the coming months as well as provide feedback on the draft material we plan to share during this meeting by using the chat or question boxes in the GTW toolbar. Andrea added that the team has plans to focus on a series of New Hospice Provider Orientation, concept to start at the beginning or with the basics so that we can build on those basics throughout the year. Andrea provided an overview of possibilities for future hospice education that providers have already brought to her attention. Andrea also mentioned her interest in analyzing data and that she intends to look at cost reports and payment structure and encouraged members to let her know if they feel this would be something providers would take an interest in.
Member Feedback: Multiple POE AG members voice concerns about the lack of understanding in hospitals regarding GIP and seeing this trend; GIP is a quick lever to reduce mortality rates. Requests for education directed to hospitals to clarify what qualifies for hospice GIP and how it interrelates with the providing hospitals.
NGS Response: We do not currently have any Hospice GIP education directed to the hospital staff/setting. POE will add this to the AG recommendation log. Erin suggested a Hospice LOC webinar series with a GIP focus, combining billing and documentation for a GIP 2-part webinar series.
Member Feedback: Knowing that we want to get the message to the hospital setting is primarily what has been talked about but it certainly exists in other settings as well. Do not know if a series of webinars would be effective because providers will not have the time and they will not listen. Would like to hear from others on this as well, but thinking it would be more beneficial if it were in some sort of a Job Aid, article, or something we can share with them to support appropriate LOC and what the criteria are for each hospice LOC.
Member Feedback: Suggestion to request MLN article with education about GIP LOC, listing what is appropriate and what is not. Can we request an MLN for hospice GIP?
NGS Response: NGS does not produce the MLNs; however, in the meantime, we can develop a job aid. We can start working on one for hospice GIP. Would providers prefer to have all LOC listed on one job aid or would they rather have the job aid focus on one LOC, for example right now just hospice GIP?
Member Feedback: California is seeing an issue with continuous care in assisted living facilities. The hospice is going in and actually taking care of the patient 24/7, not necessarily a continuous care patient and they are going to refer the patient to a hospice that can do the continuous care.
Member Feedback: Hospices are feeling increased pressure from hospitals to backdate a revocation form. The challenge becomes particularly for the hospice providers, if we were not involved in that change in location and LOC we are certainly not obliged to cover that but it makes hospices providers uncomfortable because they know that the patient and family are going to be stuck with a large financial responsibility to the hospital. Hospices are trying to do the right thing, but this is where some of that pressure comes from. As some of the other feedback has suggested, there is just a mismatch of expectations and understanding of what the regulations say.
NGS Response: As stated in the CMS IOM, Publication 100-02, Medicare Benefit Policy Manual, Chapter 9, Section 20.2.2, it is never ok to backdate a revocation form. Request from GTW chat regarding education for Hospice Transfers; member advised that there should be an updated Hospice Transfers and Revocation webinar in our HH+H On-Demand Video Library.
Member Feedback: Hospices are struggling with all things related to physician billing in hospice. For example, the billing of having a contract with a cardiologist, some hospices do not understand how that works, it kind of like a pass through billing, and you know there is always issues that bubble up about attending physicians and what do you do if you can’t get a hold of the attending physicians. All the billing outside of the hospice benefit, what do we consider related, what is not related. Providers are looking for some consistency and guidance with that.
NGS Response: Todays feedback and suggestions for education will be logged and tracked in the 2023 Hospice Advisory Recommendation log.
VI. Education Material Review
Erin Musumeci/Andrea Freibauer, NGS
Members were reminded that all material reviewed during today’s meeting is either in draft form or is being presented for feedback and comment and cannot be shared outside the meeting. In addition, members were encouraged to give ideas for educational topics as well as different methods to deliver education to providers. There are so many different types of learners out there, so our goal is to capture all types of learners and provide them with the materials they need to succeed. There is no need to wait for a POE AG meeting; suggestions are welcome any time throughout the year if there is a need for education. We will continue to keep track of all of this in the Hospice Advisory Recommendations Log during the course of the year. You should all have our new dedicated shared NGSHHHPOE@elevancehealth.com mailbox, which is where you can send your feedback, suggestions and inquiries related to HH+H education.
Erin and Andrea reviewed the following material:
Hospice TPE and ADR [PPT]
Feedback:
- In reference to the information regarding Denial 55H1R starting on slide #21, was the QIO information included?
- YES, the content making up this presentation was collected from current Medicare regulations at the time the PPT was created. There are hyperlinks that will take the reader to the most current model election form straight from the CMS website.
- Is there anything in here that speaks to sending a cover letter along with the ADR and what that should look like? Suggestion to create a “cover letter example” in the future if possible.
- YES, there is information in the last section of the presentation titled, Submitting Documentation in Response to the Hospice TPE ADR, slide 33 that addresses cover letters.
- We currently do not have an example but will make note that this would be helpful.
- Providers in CT (JK) are struggling with whom to contact for education throughout the TPE process and asking for the education? Do they contact the same person throughout the entire TPE process from start to finish so that they can be pro-active?
- Per MR, if you are you referring to intra-probe education, Clinical Reviewers and the CMT, or nurse educators that do post-pay education will also provide intra-probe education.
- Does it warrant any additional clarification on these slides to help these providers understand how they can utilize that person?
- YES, and we can add intra-probe education info to the TPE ADR PPT slides
- Suggestion to add information in reference to requesting to overturn a determination vs. go through appeals.
- POE will add that information to the Hospice TPE ADR PPT
Orientation to Hospice Medicare [PPT]
Feedback:
- Suggestion for future meetings to share the outline of the PPT prior to the meeting to be able to provide thoughts and feedback on the draft material.
- Comment that this will be a great resource to have readily available for new providers
- Suggestion to include an emphasis on where to go to find the regulatory resources that were used to create the content of this and other education presented by NGS. There is a significant lack of awareness and understanding from hospice providers in general of where to find them.
- Yes, POE will emphasize the reference and resources used when creating the materials presented.
- Suggestion to add a Quality Reporting piece to this PPT
- Suggestion to add info in reference to the survey process and Appendix M, to give providers some initial familiarity with it, as many do not know what those are.
Hospice Documentation Checklist [PDF]
No feedback offered in reference to Hospice Documentation Checklist. Members were encouraged to send feedback to the HH+H POE shared mailbox following this meeting.
VII. Education Topic Requests
Members were reminded to send any suggestions for future hospice education topics, articles, YouTube videos, webinars, etc. to Erin Musumeci and/or Andrea Freibauer via our new HH+H POE mailbox, NGSHHHPOE@elevancehealth.com.
VIII. Updates/Reminders
Erin and Andrea advised members that the next POE AG meeting would be in-person; date, time, and location are TBD. Once final details are complete, information will be emailed to all members.
Meeting Adjourned