RESOURCES
by Year
Find Past Resources organized by year below.
December 2023
November 2023
November FYI
FYI 23.11: More Final Rules!
CMS finalized a new COP change, as well as program integrity changes through the Home Health and Physician’s Fee Final Rules
November TOT
TOT 23.11: Special Focus Program
CMS has finalized the Special Focus Program. This tool will help you decipher at a glance, the SFP quality considerations for this additional CMS oversight.
Subscriber Webinar
2023
Audits – Who, What, When, Where, and Why of Hospice Audits
This webinar will allow you to understand the complete audit process and why they keep coming.
Speakers:
Rachel Hold-Weiss, Esq
October 2023
October FYI
23.10 CMS Looks to Expand the Hospice Quality Reporting Program
CMS released on October 20, 2023 a plan to expand the hospice quality reporting program (HQRP). See this FYI for the details of the areas that may one day be included in the HQRP.
October TOT
23.10 CMS Acceptable Signatures
CMS will deny your payment if the signatures in the record by your hospice team and physicians are not legible, or authenticated. See this quick reference to ensure your signatures aren’t putting you at risk!
Subscriber Webinar
2023
A day in the Life of a Hospice Medical review Nurse
Ever wonder how an auditor reviews your records? In this session, a former Medical Review Nurse will describe, in detail, how your hospice records are reviewed when you have an ADR, or other payment audit. A checklist and hierarchy will be provided- so you can challenge yourself to the test of medical review, before the auditors do!
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C
September 2023
September FYI
FYI 23.9 – Hospice Final Rule- and More!
CMS published the Hospice payment rule with a 3.1% increase.
September TOT
TOT 23.9 – Technical Components of a Payment Audit
Use this checklist prior to billing to ensure your payment is secured.
Subscriber Webinar
2023
The Final Rule
CMS brings the final decisions on items proposed for hospices in the proposed rule from this spring, and Hospice Fundamentals brings the recommendations for the prudent hospice for implementation and compliance.
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C
August 2023
August FYI
FYI 23.8 – CMS Strategy to Curb Hospice Fraud
CMS explains new initiatives to curb fraud in blog post.
August TOT
TOT 23.8 – Knowing your Hospice Quality Reporting Program (HQRP) Timelines
CMS encourages providers to befamiliar with these important dates.
Subscriber Webinar
2023
Integrative Medicine in Hospice Care
Polypharmacy is a significant concern in the palliative care setting. Integrative Medicine uses science-based modalities to improve common symptoms with fewer side-effects and complications than prescription medications. This presentation will provide the latest evidence for yoga breathing, acupuncture, sound sleep, physical activity and nutritional approaches to improve quality of life in hospice care.
Speaker:
Ashwin Mehta, MD, MPH
July 2023
July FYI
FYI 23.7 – OIG Looks at Direct Admissions to GIP
from Hospital Stays
The OIG has announced a new focus for reviews that will impact your hospice agency. They are looking at the increase in GIP utilization upon direct admission from a hospital. See the FYI for all the details.
July TOT
TOT 23.7 – Long LOS Worksheet
Subscriber Webinar
July 2023
Review of the Complete Survey Process!
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C
June 2023
June FYI
FYI 23.6 – CMS Lifts COVID-19 Vaccine Mandate
CMS has rescinded the COVID-19 vaccine mandate regulations.
June TOT
TOT 23.6 – Hospice General Inpatient Audit
CMS has a long history of scrutiny of hospice use of the general inpatient unit. Utilize this checklist in real time as a self- audit to ensure that you have the documentation needed to support this higher level of care.
2023
Summer Conference
May 2023
May FYI
FYI 23.5 – To Mask- or Not to Mask? Updated CMS Guidance for End of PHE
CMS and the CDC have provided additional clarifications on masking and the impact to agencies now that the PHE has ended. CDC and CMS have provided agencies with some “final guidance”- and promises more to come.
May TOT
TOT 23.5 – How CMS Views SNF vs NF
CMS shines a light on our billing habits each year with the
release of our PEPPER reports. It has been noted that more
agencies are outliers in offering care in a “SNF”. After investigating, most agencies find that they simply didn’t have the correct “Q code” on the claim to describe the facility is receiving care. This tool will aide your agency in ensuring you have the right code being reported
to CMS, and keep you off the RADAR.
Subscriber Webinar
May 2023
Wage Index, PEPPER Data and Quality Reporting Updates
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C
April 2023
April FYI
FYI 23.4 – CMS Updated Hospice Payment Data in new PEPPER
The annual Hospice PEPPER for 2022 was released by CMS and the PEPPER contractor on April 6th, 2023, and is available for download.
April TOT
TOT 23.4 – Compliance Updates after End of PHE
TOT 23.4.a – Medicare Telehealth Post-Public Health Emergency (PHE)
Subscriber Webinar
April 2023
Gift Giving and Referral Sources
Is your sales team overwhelmed with CMS regulations? Do you provide annual education? This is a webinar that will simplify the rules and keep your organization compliant.
Speaker:
Timothy E. Monaghan Partner, Shutts & Bowen, LLP
March 2023
March FYI
FYI 23.3 – PAC Quality Exemptions when Discharging
to Hospice
Election of hospice by patients who utilized home health now provides home health an exemption from quality measures. CMS published an Update to the Home Health Quality Reporting Program Measure Calculations and Reporting User’s Manual, Version 2.0.
Subscriber Webinar
March 2023
Revisions to Hospice – Appendix M
We will provide you with a step-by-step of all the changes, plus a tool to ensure that you can “check off” that your agency is ready for the updated survey.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C
February 2023
February FYI
FYI 23.2 – End to the Hospice PHE Waivers
The administration has stated that they anticipate only extending the Public Health Emergency (PHE) one more month, ending the three-year-long PHE on April 11th, 2023.
Subscriber Webinar
February 2023
Identifying the Attending Physician
Is it clear to your team who the attending Physician is? This webinar will assist you on how your Hospice designates the attending Physician and documents it accurately.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
January 2023
January FYI
FYI 23.1 – CMS Quality Updates for Hospices!
CMS has updated their Hospice Quality Reporting Program (HQRP) tools and website. CMS has established a multi-faceted quality reporting program. These measures come from the Hospice Item Set, claims measures and the Hospice CAHPS survey feedback.
Subscriber Webinar
January 2023
ELIGIBILITY – The First Steps to a Successful Hospice
Does everyone on your team understand the Eligibility process? In this webinar, we will help you stay compliant by providing you with tools and guidelines for determining Hospice Eligibility.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
December 2022
December FYI
FYI 22.12 – FILE NOW for Your Hospice CAHPS Exemption!
Each year, CMS allows hospices to request an exemption from the Hospice CAHPS survey program. The window for requesting this exemption will close on 12/31/22.
November 2022
November FYI
FYI 22.11 – CMS Takes First step Towards Billing of Chaplain Visits
CMS has taken the first steps towards billing of chaplain visits on the Medicare claim. Historically, the mandated discipline of a chaplain was not able to be included on the Medicare claim. This provides for an incomplete picture of the services that are being provided to hospice patients.
Subscriber Webinar
Friday, November 11, 2022
Hospice and Palliative Care Legal Considerations and Updates
The Hospice OIG reports issued over the past few years as well as concerns regarding patient care and fraud have led to statutory and regulatory changes and increased governmental scrutiny of hospice and palliative programs. This session will address some of the changes that have been made, the current state of governmental auditing and oversight, and what hospices can expect in the future.
Speakers:
Rachel Hold-Weiss, RPA-C, JD
ArentFox Schiff LLP
October 2022
October FYI
FYI 22.10: The Hospice PHE Continues
The Public Health Emergency (PHE) has been renewed on
October 13th, for another 90 days. This renewal will maintain the PHE waivers until at least January 11th, 2023.
Subscriber Webinar
Friday, October 14, 2022
Hospice Discharge Doors
CMS brings the final decisions on items proposed for hospices in the proposed rule from this spring, and Hospice Fundamentals brings the recommendations for the prudent hospice for implementation and compliance.
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C
September 2022
September FYI
FYI 22.9: FY 2023 Hospice Wage Index FINAL Rule
The FY 2023 Hospice Wage Index Final Rule was published in the Federal Register on July 29, 2022. Recognizing the intense demands and delays that the COVID-19 pandemic is having on hospices, this
year’s proposed rule is much briefer than in previous years. The great news in this brief rule was that CMS was increasing rates by 3.8% for FY2023. This was 1.19% more than the proposal.
September TOT
TOT 22.9: CARE COMPARE: Where Are Our Updated Measures?
CMS’s website, Care Compare, provides consumers a direct way of reviewing quality data about a hospice before election. Unfortunately, due to the pandemic, there has been a disruption to the quality data reporting- and some will remain “off schedule” until August of 2023! This tool will allow you to track at a glance the timeframes for your public data, and when that data gets updated.
Subscriber Webinar
Friday, September 9, 2022
Final Wage Index Follow Up
CMS brings the final decisions on items proposed for hospices in the proposed rule from this spring, and Hospice Fundamentals brings the recommendations for the prudent hospice for implementation and compliance.
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C
August 2022
August FYI
August TOT
TOT 22.8: CMS HOSPICE WAIVERS & EXPECTED END DATES
CMS has provided multiple posibilities through the federal waivers allowed during the Public Health Emergency. Currently the PHE is set to expire on October 13th, but CMS has also promised providers that they would give us a 60-day warning prior to ending the PHE and its waivers. The current waivers, and their end dates are provided below.
Subscriber Webinar
August 12, 2022
When the LCDs Don’t Do the Trick
There is certainly an art and a science to prognostication. The MACs have provided some guidelines to all hospices with their Local Coverage Determinations (LCDs). Using these LCDs, whenever it is applicable, to aid in decision making can ensure defensible documentation for terminal prognosis. This session will cover the guidelines, as well as recommendations for creating a culture of compliance, based on the LCDs.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C
July 2022
July FYI
FYI 22.8: Election Denials Are Increasing – Does YOUR Form Pass CMS’ Test?
The Medicare Administrative Contractors (MACs) are denying hospice medical review audits due to the lack of specifics on the election statement form. CMS has continued to provide guidance and regulatory changes over the last decade on what MUST be in the Election Statement when the patient or representative elect hospice.
Every year for the last several years, hospices and EMRs have been trying to keep up with CMS and the changes while trying to discern what was a mandated change, and what was a CMS “best practice” to provide additional information to patients.
July TOT
TOT 22.8: ELECTION STATEMENT COMPLIANCE
Due to the recent increase in denials related to a missing component in the election statement, use this tool as a checklist to ensure your Prudent Hospice has all of the items on the Election Statement. These items must be on the election form itself, and not just in the patient handbook, or part of another form. The MACs are denying in medical review if a component is missing from the Election Statement itself.
Subscriber Webinar
July 8, 2022
Tapping Into the Talents of Your Music Therapist
Hospice teams often operate as multi-disciplinary, with each team member contributing their expertise to help achieve an optimal end of life experience. This month, we’ll be exploring ways that music therapists can apply their unique skillsets to enhance the patient experience and interdisciplinary collaboration. Music therapists can support the documentation of eligibility, support roles of other disciplines, improve patient quality of life, and increase overall family satisfaction . We will be discussing strategies for integrating hospice music therapists for the benefit of the patient and family, the hospice team, and the hospice as an organization.
Speakers:
Rebecca Perez, Music Therapist & Chris Acevedo, CHC, Principal, Hospice Fundamentals
June 2022
June FYI
FYI 22.6: CMS HOPE Testing
Attention- CMS Needs YOU! Hospices are being asked to volunteer to be a part of the development of our next data collection and assessment tool. Hurry- the door closes after June 30th. Please see this FYI for details!
You can get all of the details by clicking on the link below.
June TOT
TOT 22.6: Plan of Care Tool
This TOT is just in time after a great Summer Conference where we talked at length on assessment and care planning. This tool will provide a guide to walk through the care planning process- and how to assess if your process is working– and not just “checkboxes”.
You can download the tool by clicking on the links below.
May 2022
May FYI
FYI 22.5: Know Your CMS Data
It is imperative in today’s climate to know your agency’s risks. CMS has provided several ways in order to see your hospice agency’s data. This gives your agency a way of knowing how CMS views you—both from a quality perspective- and if you are an “outlier”- at risk for audit- due to billing information. This FYI will provide you with the tools to review your own data.
You can get all of the details by clicking on the link below.
May TOT
TOT 22.5: The Four Paths to Elligibility
Below is one of our most popular tools, The Four Paths To Eligibility. All four paths lead to the same destination: identification and support of a six-month prognosis. Given how long it’s been since we released it, we wanted new subscribers to be aware of it and we wanted to remind veteran subscribers that it is still a valuable resource.
You can download the tool by clicking on the links below.
Subscriber Webinar
May 13th, 2022
Wage Index, PEPPER Data and Quality Reporting Updates
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C
April 2022
April FYI
FYI 22.4: FY 2023 Hospice Wage Index Proposed Rule
The FY 2023 Hospice Wage Index Proposed Rule was published in the Federal Register on April 4, 2022. Recognizing the intense demands and delays that the COVID-19 pandemic is having on hospices, this year’s proposed rule is much briefer than in previous years. It includes a 2.7% rate increase for hospices on October 1, 2022.
You can get all of the details by clicking on the link below.
April TOT
TOT 22.4: Social Determinates of Health (SDoH) REFERENCE TOOL
In this year’s proposed wage index rule, CMS requested information from hospices about how they are addressing health equity. CMS’ intention is clear that they are addressing inequities throughout the healthcare system. It’s difficult to really understand the different things that can affect care within our agencies, without the data to show it. One way we can track data is by the ICD-10 codes that look at the social determinants of health. Many of these determinants can certainly make care more difficult or less accessible, and it’s important to see at your agency, and across the hospice industry, what are the most common barriers amongst our populations. This tool will get you started on how to code for these issues.
Download the tool by clicking on the link below.
Subscriber Webinar
April 8th, 2022
ICD-10 Coding: The Implications of Social Determinants of Health
Whether hospice or palliative care, diagnosis coding helps to support the medical necessity of your services. As diagnosis coding becomes more important than ever, the code set now includes a growing number of codes describing Social Determinants of Health. We’ll start with a short refresher on proper ICD-10 coding and review the expanding list of SDoH ‘Z’ codes. At the end of this webinar attendees should have an understanding of how diagnosis codes “paint a picture of the patient” to the payer, and the impact SDoH codes play in supporting complexity.
Speaker:
Jean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow, President, Acevedo Consulting, Inc
March 2022
March FYI
FYI 22.3: SNF 5 Star Measures
SNF Five Star Measure specifications have been updated in 2022. The technical specifications show that when a resident in the facility is receiving hospice, the SNF is protected from a negative outcome on their fivestar measures.
Get all of the details by clicking on the link below.
March TOT
TOT 22.3: The Path Of The Prudent Hospice
This tool will be used by the prudent hospices to marry together the real world at their hospice, in the context of regulation and government expectations. This tool helps the hospice align their culture, values and mission with the regulations, and provide vision on how to ensure alignment. This is especially necessary in today’s world of additional upcoming scrutiny of our compliance by CMS.
Download the tool by clicking on the link below.
Subscriber Webinar
March 11h, 2022
Medical Necessity of Physician Visits
While physician services are indeed separately billable above and beyond the daily hospice care rates, the rules governing these payments are often misunderstood. This in-depth webinar will navigate the underlying requirements of medical necessity when providing these services in hospice. In addition to discussing routine medical services we will explore coupling these services with the Medicare required face-to-face encounter and cover the relevance of Advance Care Planning and other non-traditional coding and billing opportunities.
Speaker:
Chris Acevedo, Principal, Hospice Fundamentals
February 2022
February FYI
FYI 22.2: Changes in the Hospice Transfer Process
CMS is introducing new billing instructions when a hospice is involved in a patient transfer. This change will no longer allow there to be a gap in time between two hospices who are transferring care from one to the next. In the future, the date of the end of the prior hospice claim must end on the same date as the beginning of the new hospice’s initial claim.
Get all of the details by clicking on the link below.
February TOT
TOT 22.2: All Aboard the Transfer Train
Transfers have been a tricky area and can put compliance at risk. Adding to this complexity is a new billing requirement, which will be initiated on July 5, 2022. This tool provides clarity regarding CMS’ expectations for transfers in hospice in operations and billing.
Download the tool by clicking on the links below.
Subscriber Webinar
February 11th, 2022
Daily Operations that Reduce Risk!
This session takes a deeper dive, using the platform we started on last month regarding medical review audits. This month, we will take those standards, and look at how our day-to-day operations can increase your risks in audit, or support your compliance and secure your payment! We will look at everything from intake, to assessments, IDG processes and the discharge plan, and how quality of care and operations will overlap survey and payment. This is a “can’t miss session” as we provide the “real world” takeaways that you can start applying at your agency today!
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
January 2022
January FYI
FYI 22.1: Nationwide Hospice Review by OIG
January TOT
TOT 22.1: Top 10 Audit Mistakes
Since the OIG announced that there will be a national hospice audit, most of us are beginning to plan our own internal audit strategy for the year. This tool will help Prudent Hospices to be mindful of their internal goals when doing audits, and to avoid the pitfalls that make audits lose their effectiveness.
Download the tool by clicking on the links below.
Subscriber Webinar
January 14th, 2022
A Day in the Life of a Hospice Medical Review Nurse
Ever wonder how an auditor reviews your records? In this session, a former Medical Review Nurse will describe, in detail, how your hospice records are reviewed when you have an ADR, or other payment audit. A checklist and hierarchy will be provided. So, you can challenge yourself to the test of medical review, before the auditors do!
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
January 2021
January FYI
FYI 21.1: Survey Changes
Congress has enacted several regulatory changes regarding the hospice survey process. Many of these changes will be effective Oct 2021 and others will follow in 2022.
The FYI below goes into more detail regarding these changes.
January TOT
TOT 21.1: OIG Risk Areas
This new tool includes a set of worksheets to support and guide an annual evaluation of a hospice’s readiness and performance in each of the 28 risk areas as identified by the Office of the Inspector General (OIG).
You can download the checklist by clicking on the link below.
Subscriber Webinar
January 2021
A Day in the Life of a Hospice Medical Review Nurse
Ever wonder how an auditor reviews your records? In this session a former Medical Review Nurse described, in detail, how your hospice records are reviewed when you have an ADR, or other payment audit. A checklist and hierarchy was provided- so you can challenge yourself to the test of medical review, before the auditors do!
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
February 2021
February FYI
FYI 21.2: Updates to HIS and the New Claims-based Hospice Measure
A new Hospice Item Set (HIS) is being initiated, taking the Hospice industry from HIS 2.0 to HIS 3.0. And, a new claims-based measure has been initiated looking at visits at end of life. CMS has intended to transition from the reporting of visits in the HIS to a claims-based measure, for better accuracy, and to sync up with the Service Intensity Add-on (SIA). The Office of Management and Budget (OMB) is currently still reviewing the CMS HIS 3.0 Instruction manual. CMS will provide further details, once the manual is approved by OMB.
Download the FYI for more information.
February TOT
TOT 21.2: Three Basic Auditing Principles
This new tool includes a set of questions, considerations, and a tool sheet to help you understand the three basic auditing principles. Moreover, we’ve included an example of a care planning audit so you can see how these principles are applied.
Download the tool by clicking on the links below.
Subscriber Webinar
February 2021
More to an “H” in Hospice
This session will highlight all of the acronyms we have to work with in the Hospice industry–including HQRP, HCAHPS, HIS, and HOPE. We will discuss and uncover all of these and more- and what they mean to the Prudent Hospice!
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
March 2021
March FYI
FYI 21.3: The Signature Debate
The Hospice Fundamentals team discussed and felt this mandate for two signatures by the hospice physician was not required in the regulations. Hospice Fundamentals’ consultant, Annette Lee, reached out to CMS Central Office in an attempt to gain clarity.
Download the FYI below to read the email response provided by CMS and which was shared with all MACs.
March TOT
21.3 Physician CTI Checklist
This tool serves as a guide to the Initial Certification of Terminal Illness (CTI) to ensure compliance. The hospice should use this tool to assess their current process compliance, and guide any changes needed to their processes for their documentation of the initial CTI.
Download the tool by clicking on the links below
Subscriber Webinar
March 2021
Pharma Talk
In this session, Dr. Mary-Lynn McPherson, PharmD, BCPS, CPE, professor of advanced post -graduate education in the Department of Pharmacy Practice and Science at the University of Maryland, will discuss pharma issues. We will ensure you are using palliative pharmacology and your formulary to help prepare for a better end.
Speaker:
Dr. Mary-Lynn McPherson, PharmD, BCPS, CPE
April 2021
April FYI
FYI 21.4: Hospice Care Index
The Hospice Fundamentals team discussed and felt this mandate for two signatures by the hospice physician was not required in the regulations. Hospice Fundamentals’ consultant, Annette Lee, reached out to CMS Central Office in an attempt to gain clarity. The FYI below contains the email response provided by CMS and which was shared with all MACs:CMS is planning on using claims-based data (for Medicare patients) to provide a new publicly displayed report card for hospices in 2022. This new composite measure will be called the Hospice Care Index (HCI) and consists of 10 claims-based measures.
Click on the link below to download the FYI and get more details.
April TOT
21.4 How to Measure the HVLDL & Track HCI
CMS is currently gathering claims-based information to create publicly reported measures in 2022. All hospices should be requesting tools of their EMRs, or self- auditing for these measures to obtain a pulse on the hospice’s current standing in these areas. As the OIG continues to publish concerns with the quality of care of the hospice industry, self-checks continue to be top of mind for the Prudent Hospice.
Download the tool by clicking on the links below.
Subscriber Webinar
April 2021
Palliative Care Programs: A Primer
This presentation is an excellent introduction to palliative care. The speakers discuss the basics of setting up the business and legal aspects, core services, internal planning, staffing considerations and productivity targets. The session also includes an important discussion on potential partners, customers, and patients.
Speakers:
Rachel Hold-Weiss, RPA-C, J.D, Arent Fox
Christopher Acevedo, COO, Hospice Fundamentals
May 2021
May FYI
FYI 21.5: Terminal Scrutiny
Historically, most medical review was completed on a pre-pay basis, by the Medicare Administrative Contractor (MAC). Today, the MACs, along with a number of other CMS contractors are requesting records post-pay. Hospice Fundamentals is seeing increased reviews on longer lengths of stays, sometimes resulting in over a million dollars at stake.
Get all of the details by clicking on the link below.
May TOT
21.5 When Eligibility Is Not So Clear
CMS is auditing hospices to ensure they have the “right patient” at the “right time” for the “right service.” Sometimes patients do not follow the road we originally predicted and the IDG will need to reassess. As CMS continues to increase oversight of care in the hospice industry, self-checks continue to be top of mind for the Prudent Hospice. This TOT provides a guide, and a decision tree to the IDG, when eligibility is not so clear.
Download the tool by clicking on the links below.
Subscriber Webinar
May 2021
The Updated PEPPER- Including Number of Part D Claims While on Your Hospice
CMS provides free benchmarking payment data in the PEPPER report. This year the report features some new metrics. Review the trends in the established data benchmarks, as well as the new data being provided to the industry. It should be noted that this data is used by auditors, including the Medicare Administrative Contractor (MAC) and certainly should be used by all prudent hospices.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
June 2021
June FYI
FYI: 21.6 OSHA Establishes an Emergency Temporary Standard
On June 24, 2021, the OSHA Emergency Temporary Standard (ETS) effective June 21, 2021, was published in the Federal Register. The new ETS applies to home health and hospice, with additional requirements for inpatient hospice.
Get the details by clicking on the link below.
June TOT
TOT 21.6 Levels of Care Primer
CMS is auditing hospices to ensure they have the “right patient” at the “right time” for the “right service”. A focus for CMS and it’s contractors currently are different levels of care. Hospice agencies are sometimes voicing confusion, as CMS is monitoring those agencies who do not provide GIP or CHC, but they also are scrutinizing those who are providing these levels of care. Multiple questions have come into the Here to Help mailbox re the need for a quick reference to share with staff and stakeholders.
Download the tool by clicking on the link below.
Subscriber Webinar
June 2021
The FY 2022 Wage Index Proposed Rule
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
July 2021
July TOT
TOT 21.7 A Key to Hospice Aid Supervision
The OIG has published reports with concerns about hospice aide supervision in recent years. CMS released a new MLN Matters article on the importance of meeting timelines for hospice aide supervision, and will undoubtedly be a focus of surveyors.
https://oig.hhs.gov/oas/reports/region9/91803022.pdf
Download the tool by clicking on the link below.
Subscriber Webinar
July 2021
Tapping Into the Talents of Your Social Workers
Hospice Teams can sometimes operate as multi-disciplinary; with nurses doing the lion’s share of the team’s work, with other team members functioning on a parallel track. This month, we’ll be looking at ways that social workers can perform in a truly interdisciplinary manner. Social workers can support the documentation of eligibility, prevent emergency department visits, improve overall family satisfaction and support their team nurses in their roles. We will be identifying strategies for engaging hospice social workers for the benefit of the patient and family, the hospice team, and the hospice as an organization.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
August 2021
August FYI
FYI 21.8: Targeted Probe and Educate Returns!
On August 12th, 2021, CMS announced the return of the Targeted Probe and Educate (TPE) program, by all three Medicare Administrative Contractors (MACs) that handle hospice billing.
CMS paused the TPE programs for hospice claims at all MACs in March of 2020 due to the Public Health Emergency. The MACs pivoted to a “post-pay review” model when medical review resumed in fall of 2020, based on a smaller, topic driven sample,
rather than a provider specific model. On August 12th, 2021, CMS announced that the MACs will be resuming to the Targeted Probe and Educate model of medical review.
Get the details by clicking on the link below.
August TOT
TOT 21.8: Targeted Probe and Educate Checklist
CMS has called for the resumption of TPE, for the first time since halting due to the Public Health Emergency. WHEN: Use this tool when your agency has had a request for medical records for one of these audits, or as a self- assessment tool to ensure compliance.
Download the tool by clicking on the link below.
Subscriber Webinar
August 2021
Documenting Terminal Prognosis with Roadmap of LCDs
While physician services are indeed separately billable above and beyond the daily hospice care rates, the rules governing these payments are often misunderstood. This in-depth webinar will navigate the underlying requirements of medical necessity when providing these services in hospice. In addition to discussing routine medical services we will explore coupling these services with the Medicare required face-to-face encounter and cover the relevance of Advance Care Planning and other non-traditional coding and billing opportunities.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
September 2021
September FYI
FYI: 21.8 You’ve Got Mail!
Did you check your mail? CMS sent you each a report of your own data for the claims based measures.
Get the details by clicking on the link below.
September TOT
TOT 21. 9 The Prudent Hospice’s Roadmap to their New Quality Data Measures
CMS has provided a “sneak preview” for hospices to see their claims-based quality measures prior to the public display, planned for February, 2022. This allows the Prudent Hospice to review their data and make operational changes, if needed, to improve their scores
Hospices should use the tool to gain access to their data ASAP. CMS provided these in CASPER in the end of September, 2021.
Download the tool by clicking on the link below.
Subscriber Webinar
September 2021
Final Wage Index Follow-up
October brings the final decisions on items proposed for hospices in the proposed rule of spring, and recommendations for the prudent hospice for implementation and compliance.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
October 2021
October FYI
FYI 21.10 CMS Updates HQRP Manual & Resources
CMS has published an update for the Hospice Quality Reporting Manual, as well as a number of additional tools and resources to support hospices with quality reporting. CMS recently updated the quality measures for hospice, which now include measures based on HIS, CAHPS, as well as two claims-based measures. Hospice Fundamentals recently provided a Tool of the Trade to assist agencies in finding their updated Quality Measure reports in iQIES. These resources will aid in analyzing these reports.
Get the details by clicking on the link below.
October TOT
TOT 21.10 Survey Preparation Binder Table of Contents
Surveyors will ask for specific reports and policies within the first hour of a survey. Knowing what these items are, and being able to be have them readily available sets the tone for an organized, smooth survey process!
The items listed in black should be obtained and inserted in a Survey binder immediately. The reports, listed in red, will change routinely, so we suggest you start running these reports and updating on a weekly basis when survey expected in the near future!
Download the tool by clicking on the link below.
Subscriber Webinar
October 2021
Hospice Survey Trends and Preparednes
CMS is looking to update the survey process in 2021. Currently they’ve only provided a proposed process. However, based on their announcements throughout the year, we know there are several changes on the horizon. For example, there will be a tweak the COP’s guidelines for surveyors. In this webinar we’ll discuss what the four areas of focus are and how hospices should prepare for the updates.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
November 2021
November FYI
FYI 21.11 Vaccination Mandate Guidance Summary
On November 4, 2021, the Centers for Medicare and Medicaid Services (CMS) issued an Interim Final Rule establishing COVID-19 vaccination requirements for employees of Medicare and Medicaid-certified providers. In addition, the Occupational Safety and Health Administration (OSHA) released an Emergency Temporary Standard, effective November 5, 2021, outlining COVID-19 vaccination requirements for employers of greater than 100 employees.
First, it is important to establish which rule applies to each type of organization. The table in the FYI will help you do just that.
Get the details by clicking on the link below.
November TOT
TOT 21.11: Vaccination Mandate Policy and Exemption Examples
CMS has issued an update to the COPS mandating COVID-19 vaccination for all employees in healthcare entities that receive Medicare or Medicaid payments. All prudent hospice agencies must be compliant with this mandate, or may face penalty.
All agencies are mandated to have a policy on the vaccination mandate, exemptions, and accommodations that may be made for those exempt. Use these tools to aide in the draft of this policy and to provide a guide for exemption forms.
Download the tool by clicking on the link below.
Subscriber Webinar
November 2021
Lessons Learned From A Corporate Integrity Agreement
Speaker:
Jean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow President, Acevedo Consulting, Inc.
January 2020
January FYI
Not Published This Month
January TOT
TOT 20.1 Patient Notification of Hospice Non-Covered Items, Services, and Drugs (Tool 6)
Example of what your form might include for Patient Notification of Non-Covered Items to meet FY2021 Compliance.
Download the tool by clicking on the link below.
Subscriber Webinar
January 2020
GIP Audits – SMRC and the Audit Review Process
CMS is asking hospices to send in documentation for claims that contained GIP days. The OIG has published concerns about “too much” GIP, and “not enough” use of levels of care. So, we as hospices seem to be caught in the middle. Learn what these audits are consisting of, the denials occurring, and how to avoid them, as well as the documentation we provide to support the patient’s need for GIP!
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
February 2020
February FYI
Not published this month.
February TOT
TOT 20.2 Hospice Physician Billing (Tool 7)
This is a quick reference tool for determining pathways to billing for various physician provider types. Use it to ensure compliant and appropriate billing practices for physician care provided outside the hospice per diem rate.
Download the tool by clicking on the link below.
Subscriber Webinar
February 2020
The Plan of Care and Comprehensive Assesment
The Hospice Plan of Care is the foundation for evidence-based, quality care. Yet, this vital component remains on the list of top survey deficiencies year after year, and was featured prominently in the 2019 OIG reports. This offering broke down the Plan of Care into manageable components and provided case examples to bring them to life.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
March 2020
March FYI
FYI 20.1: Value-Based Insurance Design Model: Incorporation of the Medicare Hospice Benefit into Medicare Advantage
CMS is accepting applications, due March 16th, from Medicare Advantage Organizations (MAOs) to participate in a project that will “carve-in” the Medicare hospice benefit to Medicare Advantage (MA) programs. This is part of the Value-Based Insurance Design (VBID) Model for calendar year 2021. By year three of the VBID Model, a hospice will have to be “in-network” with participating MAOs to continue to care for that MAO’s patients.
Get the details by clicking on the link below.
March Special FYI
FYI 20.2: Hospice Guidance Regarding COVID-19
In response to the COVID-19 pandemic, guidance has been issued regarding safe hospice operations and waivers of certain requirements via a section 1135 Waiver.
Get the details by clicking on the link below.
March TOT
TOT 20.3 1135 Waiver (Tool 8)
When the President declares a national emergency, the Health and Human Services (HHS) Secretary is authorized to waive or modify certain Medicare requirements to ensure that services are available to meet the needs patients and families.
Download the tool by clicking on the link below.
Subscriber Webinar
March 2020
Getting the Most Out of Your Physicians – From IDG to Bedside Care and Everything Inbetween
As the end of life nears, every dying individual will have symptoms. There is no need to wait for symptoms to occur emergently – most issues can be anticipated by thinking of the likely disease progression. In this session, we will review how your physician can see around corners and help to build a solid, proactive care plan for every patient served by the IDG.
Speaker:
Balu Natarajan, M.D.
Subscriber Webinar
March Special 2020
Working Through an 1135 Waiver – the Impact on Hospice & Palliative Care
Patients and families need us more than ever, yet providing care has become challenging as a result of the highly contagious virus. Members of the Hospice Fundamentals Team will provide you with the latest guidance from CMS and Department of Health and Human Services, answer your questions about regulations and care delivery, and provide links to the latest information so you can remain informed.
- How are your physician visits affected by the expansion of telehealth?
- What tools has CMS provided for hospices
- The relief CMS provided regarding HIS and Hospice CAHPS
- What we still don’t know
- How to use ethical decision making to handle the grey areas of our everyday lives in hospice
- “How do we do IDG in social distancing?”
- “What if the facility won’t let us see our patients?”
Speakers:
Barbara Ivanko, LCSW Hospice Fundamentals
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
Chris Acevedo, Principal, Hospice Fundamentals
April 2020
April FYI
FYI 20.3: More COVID-19 Flexibilities for Hospice
New changes made possible by the President’s recent emergency declaration were announced on March 30, 2020. These temporary changes will apply immediately across the entire U.S. healthcare system for the duration of the emergency declaration.
Get the details by clicking on the link below.
April Special FYI
FYI 20.4: Accelerated and Advance Payments Program for Hospice During COVID-19 Emergency
In order to increase cash flow to hospices and other providers during the COVID-19 emergency, the Centers for Medicare & Medicaid Services (CMS) is authorized to provide accelerated or advance payments during the period of the emergency to Medicare hospices. Each hospice must submit a request to the appropriate Medicare Administrative Contractor (MAC) and be eligible for the payment.
Get the details by clicking on the link below.
Subscriber Webinar
April Special 2020
CMS Updates to COVID19 Related Topics for Hospice & Palliative Care
The mandatory Hospice Election Addendum that was included in the July 2019 Final Rule goes into effect on October 1 of this year. Our April webinar broke down the requirements hospices have to meet in order to remain compliant with this new regulation.
During our live webinar, we also shared a sample election addendum. However, a few hours after the presentation, CMS released their own example of an election addendum. Consequently, their form supersedes the document we used during the discussion. Below, we have included links to the CMS example addendum, the webinar handouts, and the video recording.
NOTE: Within the audio portion of the webinar, there is an error regarding the time frame for the Election Addendum. However, the slides in the video portion of the presentation (and in the handout links below) are accurate.
To Clarify: There are two mandated time frames for the Patient Notification Addendum. If requested at time of election, the hospice has five days to provide the written addendum. If requested after election, during the course of care, the hospice has 72 hours to provide the written addendum
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
Subscriber Webinar
April Special 2020
CMS Updates to COVID19 Related Topics for Hospice & Palliative Care
Patients and families need us more than ever, yet providing care has become challenging as a result of the highly contagious virus. Members of the Hospice Fundamentals Team will provide you with the latest guidance from CMS and Department of Health and Human Services, answer your questions about regulations and care delivery, and provide links to the latest information so you can remain informed.
- What guidance/tools has CMS provided for hospices
- The impact on visits & use of telehealth/technology
- What we know/still don’t know
- How to use ethical decision making to handle the grey areas of our everyday lives in hospice
- How are your physician service visits affected by the expansion of telehealth
Speakers:
Barbara Ivanko, LCSW Hospice Fundamentals
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
Chris Acevedo, Principal, Hospice Fundamentals
Subscriber Webinar
April Home Health
Applying Home Health Waivers
Hospice Fundamentals and Acevedo Consulting offered a free webinar last Friday, April 24th for home health care providers. This presentation featured Annette Lee, who answered frequently asked questions by home health providers related to COVID-19. This webinar was a critical opportunity to get the latest updates, answers to your questions, and important information on what you need to do as a home care provider to ensure patient and staff safety.
As a public health service, Hospice Fundamentals and Acevedo Consulting is providing all home health providers, regardless of member status, access to this webinar recording.
Agenda:During the presentation, Annette Lee answered frequently asked questions, such as “How do we apply the information changes to our ‘real lives’ at our home health agency?” and “How do we keep up when CMS has released new guidance at lightning speed?” Moreover, she fielded questions from live webinar participants as well.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
May 2020
May FYI
FYI 20.5: FY 2021 Hospice Wage Index Proposed Rule
The FY 2021 Hospice Wage Index Proposed Rule was published in the Federal Register on April 15. Recognizing the intense demands that the COVID-19 pandemic is having on hospices, this year’s proposed rule is much briefer than in previous years. It includes a 2.6% rate increase for hospices on October 1, 2020. Also included are a few changes to the Core-based Statistical Area (CBSA)/Rural designations for some counties.
Get the details by clicking on the link below.
May TOT
TOT 20.4 Plan of Care Integrity Audit Tool (Tool 9)
Simple tool to audit or spot check individualized care planning and follow the Plan of Care, as care planning remains one of the top ten survey deficiencies for hospices.
Download the tool by clicking on the link below.
Subscriber Webinar
May 2020
Live Discharges, The PEPPER, and the HIS-CMS Benchmarks
This year’s round of the PEPPER – Program for Evaluating Payment Patterns Electronic Report – has been temporarily delayed. This report, based on your hospice agency’s claims data, is typically published each April. This is the data that the MAC and other Medicare contractors use when making determinations about medical review. Is your hospice taking full advantage of this report? Do you understand its importance? Do you know how to interpret then use the information? In this informative webinar we prepared subscribers for this important report.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
June 2020
June FYI
Not Published This Month
June TOT
TOT 20.6 Compliant Use of the Patient Notification (Tool 11)
A simple tool to walk hospice clinicians through the steps for compliance with new Patient Notification. CMS has mandated that patients must be notified, upon patient/caregiver’s request, of any medications or treatments that the hospice will not be providing. This notification has very specific instructions regarding timing of the notice, which are a condition of payment. This regulation goes into effect on October 1st, 2020. This affects all SOC, on/after 10/1/2020, and anytime existing patients / representatives request this notification on/after 10/1/2020.
Download the tool by clicking on the link below.
Subscriber Webinar
June 2020
Proposed Wage Index Proposed Rule 2020
Hospices across the nation eagerly await the Proposed Rule for information on changes to regulatory requirements and reimbursement, and the opportunity to provide comments to CMS. In this webinar, we review and discuss the provisions of the proposed rule and, from the musings in the narrative, try to discern what is on the mind of CMS. We also discussed tips on the Election Addendum, approved in 2019 and effective October 1 of 2020.
Speakers:
Barbara Ivanko, LCSW Hospice Fundamentals
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
July 2020
July FYI
FYI 20.6: HIS and CAHPS: Submissions “Count” Again!
Starting with all hospice patient deaths on or after July 1st, 2020, the Hospice Item Set and Hospice CAHPS must both be submitted timely to avoid a two percent reduction in payment in 2022.
Get the details by clicking on the link below.
July TOT
FYI 20.7 Sample Policy for Election and Election Addendum (Patient Notification) (Tool 12)
A sample policy for a hospice agency to use for the election and patient notification process, with the 2021 updates. Beginning October 1, 2020, hospice agencies must have updated policies and forms to reflect the regulatory changes going into effect regarding the election as well as the patient notification, upon request. Implement by October 1, 2020
Download the tool by clicking on the link below.
Subscriber Webinar
July 2020
Legal Aspects of Hospice
Government and 3rd party scrutiny continues to rise in our industry. During this webinar, we discussed topics that are most relevant to hospices regardless of size. We also reviewed the recent enforcement trends to help ensure your agency is prepared to mitigate as much risk as possible.
Speakers:
Lester Perling, Partner, Board Certified in Health Law, from Nelson Mullins
Jamie Gelfman, Of Counsel, from Nelson Mullins
August 2020
August FYI
FYI 20.7 FY2021 Final Rule
The FY 2021 Hospice Wage Index Final Rule was published in the Federal Register on August 4th, 2020. Due to the Public Health Emergency and its impact on hospicesthis year’s Hospice Wage Index Rule is much briefer than in previous years. It includes a 2.4% rate increase for hospices for FY 2021, beginning on October 1, 2020. Also finalized are a few changes to the Core-based Statistical Area (CBSA)/Rural designations for some counties.
Get the details by clicking on the link below.
August TOT
TOT 20.8 Payment Audit Checklist (Tool 13)
This checklist lists the conditions for payment under the Medicare Hospice benefit. CMS audits have now resumed, after a brief pause due to the Public Health Emergency. Hospice agencies may receive a request for documentation for payment purposes from their MAC, the CERT, UPIC, RAC or SMRC. Use this tool when your agency has had a request for medical records for one of these audits, or as a self- assessment tool to ensure compliance.
Download the tool by clicking on the link below.
Subscriber Webinar
August 2020
The LCD Roadmap to Avoid the MAC’s Top Denial
CMS has announced that medical review will resume August 3rd, 2020. The number one denial across all Medicare administrative contractors for ADRs is, “Documentation does not support terminal prognosis.” The Medicare Administrative Contractor (MAC) provides additional guidance to hospices on how to ensure you are taking care of the right patients, at the right times- and in the right place/level of care. The LCDs ensure that when we have a referral, or are considering recertification, that we have a guide to show us the types of signs and symptoms that should be present, if the disease has progressed to a terminal status. Learn creative ways to integrate the LCD into your intake, evaluations, IDT, marketing and documentation. This key will also reinforce your “audit proof” documentation.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
September 2020
September FYI
FYI 20.8: Implementing the Changes to the Election
The changes to the Election, mandated in the FY 2020/2021 Hospice Wage Index Final Rules, must be implemented by all certified hospices by October 1st, 2020. These changes include both additional information within the election statement, and a new “Election Addendum”, entitled the “Patient Notification of Hospice Non-Covered Items, Services and Drugs”. (hereby referred to as the “Patient Notification”)
Get the details by clicking on the link below.
September TOT
TOT 20.9 Assessment to Prepare for How Your Hospice Compares (Tool 14)
A self-assessment and training tool for the hospice agency to identify their own answers to the questions that CMS provides potential patients and families to ask when selecting a hospice. CMS has moved Hospice Compare to “Care Compare” and incorporates educational resources for the public to understand the hospice benefit and to ensure the highest quality of care when selecting a hospice provider. This self-assessment gives your hospice a chance to review processes and messaging as we approach the new year!
Download the tool by clicking on the link below.
Subscriber Webinar
September 2020
Palliative Care Programs: A Primer
This presentation is an excellent introduction to palliative care. The speakers discuss the basics of setting up the business and legal aspects, core services, internal planning, staffing considerations and productivity targets. The session also includes an important discussion on potential partners, customers, and patients.
Speakers:
Rachel Hold-Weiss, RPA-C, JD, Partner, Arent Fox LLP
Chris Acevedo, Principal, Hospice Fundamentals
October 2020
October FYI
FYI 20.9: What Does VBID Mean to Our Hospice?
CMS is piloting a “Value Based Insurance Design” to begin with some Medicare Advantage Programs in 2021. Historically, when a Medicare beneficiary elects the hospice benefit, the patient’s hospice care is shifted back to traditional Medicare coverage. CMS will be testing this model with MA plans who will maintain responsibility for their members care, even when hospice is elected. CMS is hoping to see cost savings, as well as innovation for hospice services.
Get the details by clicking on the link below.
October TOT
Not Published This Month
Subscriber Webinar
October 2020
Final Wage Index Follow Up
October brings the final decisions on items proposed for hospices in the proposed rule of spring, and recommendations for the prudent hospice for implementation and compliance. In this webinar we’ll discuss what to expect.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
November 2020
November FYI
FYI 20.10 CMS Audits
CMS entities have resumed audits for hospice agencies, after a pause during the PHE. CMS has historically performed prepay and post pay reviews to ensure proper payment and billing of hospice claims. These reviews are done by a variety of CMS contractors, who have resumed audits once again.
Get the details by clicking on the link below.
November TOT
Not Published This Month.
Subscriber Webinar
November 2020
The Hospice Quality Reporting Program: The 2020 Updates
As anticipated, the program continues to expand with new information on Hospice Compare and new quality measures in the works. This month we’ll do a quick review of where we’ve been and where we might be going, discuss common problem areas and provide ideas for helping hospices use the HRQP data to improve care.
Speaker:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
December 2020
December FYI
FYI 20.11 Care Compare Update
CMS recently discontinued the Hospice Compare website. Hospice data and information are now found on a more holistic website, “Care Compare.” Since 2017, CMS has provided publicly reported data about hospice agencies across the nation, allowing the consumer to compare and contrast information and data about hospices.
Get the details by clicking on the link below.
December TOT
Not Published This Month.
Subscriber Webinar
December 2020
What the VBID Hospice Carve-In for 2021 Means to the Prudent Hospice
Value Based Insurance Design has been hard at work trying to innovate the Medicare Program for years. Hospice has been insulated from these changes because, traditionally, when a patient with a Medicare Advantage plan elects hospice, the patient’s plan reverts back to traditional Medicare during that time. Starting in 2021, a new initiative is being trialed: Looking at how the hospice benefit works under a Medicare Advantage Plan. This will be a whole new world for hospice providers. In this presentation we covered the facts from CMS, as well as additional insights to help the Prudent Hospice prepare for these changes–whether you are in these model areas or not!
Speakers:
Annette Lee, RN, MS, HCS-D, COS-C, Hospice Fundamentals
Chris Acevedo, Principal, Hospice Fundamentals
January 2019
January FYI
FYI 19.1 PAs, Hospice & Medication Ordering
As of January 1st, PAs (physician assistants) may serve as attendings for hospice patients. This FYI provides a brief summary of the functions that they may and may not serve and addresses the recent communication from CMS stating that, as the regulations currently read, PAs may not order drugs.
Get the details by clicking on the link below.
January TOT
TOT 19.1 Live Discharge Doors (Tool 1)
A visual reference tool of the five allowable reasons for live discharges from the hospice Medicare benefit.
Get the details by clicking on the link below.
Subscriber Webinar
January 2019
Opening the Door to the Hospice Medicare Benefit: The Certification and the EOB
We’re opening the year with a webinar devoted to unlocking the door to the hospice Medicare benefit. It’s a two-key system – the physician certification of terminal illness and the election of benefit – and a misstep with either will leave you out in the cold for payment.
Speaker:
Roseanne Berry, MSN, RN
February 2019
February FYI
FYI 19.2: Hospice Election Statements Lack Required Information or Have Other Vulnerabilities
CMS recently reminded hospices of the OIG Report from September 2016 leading us to believe election statements should be top on hospice compliance initiatives. Hospices should improve their election statements and ensure that physicians meet requirements when certifying benefi ciaries for hospice care.
Get the details by clicking on the link below.
February TOT
TOT 19.2 Hospice Compliance Risk Areas (Tool 2)
The following is a list of specific hospice compliance risk areas identified by the Office of the Inspector General in the Compliance Guidance for Hospices published in the Federal Register in October 1999. For a full understanding of their view of the areas and of their illustrative examples read the entire Federal Register document, including the footnotes.
Get the details by clicking on the link below.
Subscriber Webinar
February 2019
You Survived the Survey – Now What?
Whew! The survey is done, the report is back and now it’s time to write the plan of correction. Where to start? This webinar discusses the key steps in creating a pragmatic plan that truly corrects the deficiency but does not leave you with unwieldy undertaking that far overshoots the actual need. And, to wrap up we’ll cover establishment and implantation of a monitoring process that keeps an eye on the area until you know that it’s truly corrected.
Speaker:
Chris Acevedo, Principal, Hospice Fundamentals
March 2019
March TOT
TOT 19.3 Hospice Compliance Risk Areas (Tool 3)
A visual reference tool to assist with when to bill for physician services or when to have the community physician submit their bill directly to Part-B.
Get the details by clicking on the link below.
Subscriber Webinar
March 2019
Clinician Connection: Alzheimer’s and Other Dementias: Eligibility and Care Planning
How well do you understand assessing for and documenting to eligibility and supporting it all with effective care planning for patients with: Alzheimer’s and Other Dementias? In this latest installment of the Clinician Connection series, we’ll dig into care planning, IDG function, and eligibility.
April 2019
April FYI
FYI 19.3: HEART: Hospice Evaluation Assessment and Reporting Tool
The Centers for Medicare and Medicaid Services is developing and testing a mandatory standardized patient assessment tool for hospices called the Hospice Evaluation Assessment and Reporting Tool (HEART)
Get the details by clicking on the link below.
April FYI
FYI 19.4: MedPac Annual Report to Congress: Medicare Payment Policy
Every March the Medicare Payment Advisory Commission (MedPAC) releases the report of its analyses of payment adequacy of hospice and other Medicare programs. This FYI briefl y reviews the hospice chapter of the 2019 report and also provides some information about MedPac.
Get the details by clicking on the link below.
April FYI
FYI 19.5: Medicare Advantage “Carve in” for Hospice: Value-Based Insurance Design
Medicare Advantage (MA) plans have always “carved out” hospice care. This means MA beneficiaries receive hospice care under Medicare Part A, while leaving their MA benefits intact for unrelated care. Beginning January 1, 2021, the Centers for Medicare & Medicaid Services (CMS) will be testing a Value-Based Insurance Design (VBID) model for including hospice care in Medicare Advantage plans; “carving” it back in.
Get the details by clicking on the link below.
April TOT
TOT 19.4 Public Reporting and Availability of Hospice Data and Metrics (Tool 4)
A visual reference tool to assist with understanding the key categories of hospice information, and who can see it.
Get the details by clicking on the link below.
Subscriber Webinar
April 2019
Cutting to the Chase: What Matters Right Now and What to Do About It
(1) Multi-Million Dollar Extrapolated Overpayments Are Back in Hospice;
(2) Certification Denials Related to Attending Physicians What Are They;
(3) When You Need to Get CMS Approval (multiple locations, 855 updates etc.)
Guest Speakers:
Meg S. L. Pekarske, JD
Karla H. Pinkerton
Reinhart Boerner Van Deuren, S.C.
May 2019
May FYI
FYI 19.6 The Q4 FY18 Hospice PEPPER
The Q4 FY18 PEPPERs were released and made available for download in mid April. No new target areas or information tables this year. This FYI reviews the history of the hospice PEPPER and includes a full listing of target areas with guidance for suggested actions.
Get the details by clicking on the link below.
May FYI
FYI 19.7 FY 2020 Hospice Wage Index Proposed Rule (Part 1)
The FY 2020 Hospice Wage Index Proposed Rule was published in the Federal Register on April 25. In addition to the proposed FY2020 rates and changes to the HQRP program, the rule proposes changes to the base rates for Continuous Home Care (CHC), General Inpatient Care (GIP) and Inpatient Respite Care (IRC), and a reduction of the rate for Routine Home Care (RHC). It also proposes the addition of an addendum to the election statement to provide greater transparency and more information to patients at the start of care, with a heavy emphasis on “Virtually All” care being the responsibility of the hospice. The Centers for Medicare & Medicaid Services (CMS) is also soliciting information on the role of the hospice and coordination of care at the end of life.
Get the details by clicking on the link below.
Subscriber Webinar
May 2019
Live Discharges and The PEPPER
The 6th round of hospice PEPPERs – Program for Evaluating Payment Patterns Electronic Report – will be released in April 2019. Is your hospice taking full advantage of this report? Do you understand its important and how to interpret and to use the information? Join this informative audioconference and you will!
Speaker:
Roseanne Berry, MSN, RN
June 2019
June FYI
FYI 19.8 FY 2020 Hospice Wage Index Proposed Rule (Part 2)
The FY 2020 Hospice Wage Index Proposed Rule suggests the addition of an addendum to the election statement to provide greater transparency and more information to patients at the start of care, and better coordination of care with non-hospice providers. This would have to be available at the patient and family’s request within the fi rst 48 hours of care, and immediately upon request thereafter. Further, it proposes that this addendum be a new condition for payment.
Get the details by clicking on the link below.
June FYI
FYI 19.9 FY 2020 Hospice Wage Index Proposed Rule (Part 3)
Each year’s proposed rule includes an in-depth update of the Hospice Quality Reporting Program (HQRP). This FYI reviews the most recent off ering and includes a list of the HQRP proposals for which CMS is soliciting comments. There are no new proposed claims -based or outcome measures at this time.
Get the details by clicking on the link below.
June FYI
FYI 19.10 FY 2020 Hospice Wage Index Proposed Rule (Part 4)
The Centers for Medicare and Medicaid Services (CMS) is seeking information on the interaction between hospice and other models of care delivery.
Get the details by clicking on the link below.
Subscriber Webinar
June 2019
2020 Proposed Wage Index Rule
Speaker:
Jean Acevedo, LHRM, CPC, CHC, CENTC, AAPC Fellow President, Acevedo Consulting, Inc.
July 2019
July FYI
FYI 19.11 Part One: The Office of the Inspector General (OIG) Report: Hospice Deficiencies Pose Risks to Medicare Beneficiaries
This month, the OIG released a report stating that survey deficiencies indicate that a large number of hospices are performing in a manner that poses risk to patients and families. The OIG again calls upon the Centers for Medicare & Medicaid Services (CMS) to strengthen the survey process. They make additional recommendations pertaining to increased transparency and oversight. This report is the first of a two-part series; information on the second part, “Safeguards Must Be Taken to Protect Medicare Hospice Beneficiaries from Harm”, is coming in the next Hospice Fundamentals FYI.
Get the details by clicking on the link below.
July TOT
TOT 19.5 Quick Reference Guide to Hospice Physicians (Tool 5)
Fast guide to the regulations and function of physician providers to ensure appropriate physician and advanced practice practitioner involvement in the care and oversight of hospice patients.
Get the details by clicking on the link below.
Subscriber Webinar
July 2019
2020 Proposed Wage Index Rule
In today’s environment, hospices are accountable for higher for quality, while we are supported by lower reimbursement! It is essential that every team member contributes measurably to excellent outcomes that are directly linked to the hospice assessment and plan of care. They also must also be more productive and efficient than ever. When it comes to social workers and chaplains, the competencies, regulations, practice expectations, visit and caseload parameters and the ability to contribute to Compare and HQRP are poorly understood by many nurses and nurse leaders– and even by social workers and chaplains themselves. This offering busts some regulatory myths, outlines models of caseload and visit frequency expectation, directly links discipline-specific interventions to outcomes, and invites these essential team members to provide and document services with a high degree of professional accountability.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
August 2019
August FYI
FYI 19.12 OIG Report Part 2: Safeguards Must Be Strengthened to Protect Medicare Hospice Beneficiaries from Harm
This report describes 12 specific instances of harm to hospice beneficiaries, which the OIG says reveal vulnerabilities in CMS’s efforts to prevent and address harm to hospice patients. The OIG makes five recommendations to strengthen safeguards that would better protect patients and families. This is the second part of a two-part series released this month by the OIG. See Hospice Fundamentals FYI 19.11 for a summary of Part 1, which focuses on quality of care and widespread survey deficiencies.
Get the details by clicking on the link below.
August TOT
Not Published This Month.
Subscriber Webinar
August 2019
Assisted Living Facilities: Doing it Right and Doing It Well
Many frail elderly people that are in need of hospice services reside in Assisted Living Facilities. This rapidly growing market for hospice holds both opportunity and risk for hospices and ALF residents. This webinar explores the unique needs of this population, potential risks and strategies to maintain quality.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
September 2019
September FYI
FYI 19.13 NEW OIG Report: Medicare Part D is Still Paying Millions for Drugs Already Paid for Under the Part A Hospice Benefit
The OIG released a report with the results of an audit of 2016 hospice claims. The audit sought to determine the extent to which Medicare Part D paid for medications for hospice patients that the hospice should have paid for. This was a follow up to a 2012 report that found that Part D and patients were paying for drugs that the hospice was responsible for. As the title of the report makes clear, Part D is still paying millions. The OIG, which aims to fight waste in Medicare and Medicaid, views this as CMS paying twice for the drugs—once by the hospice as part of their daily rate, and then again when Part D is billed. The OIG makes strong recommendations for CMS to do more to address this issue.
Get the details by clicking on the link below.
September TOT
Not Published This Month.
Subscriber Webinar
September 2019
The OIG Report Part 1
The OIG’s recent report painted a picture of poor quality of care provided to hospice beneficiaries; so much so that it has become more important than ever for each of us to project the high quality of care that the vast majority of hospices provide every day. Our September webinar will review the report in detail, but more importantly we will provide the information you need, and suggest actions that you should take, to maintain your hospice’s integrity and reputation during these times of scrutiny and accountability for hospice programs.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
October 2019
October FYI
FYI 19.14 84 FR 51836: Medicare and Medicaid Programs; Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies; and Hospital and Critical Access Hospital Changes to Promote Innovation, Flexibility, and Improvement in Patient Care
At the end of September, CMS issued a final rule outside the hospice realm. This has potential positive impact for hospices because the language of this rule specifically mentions hospice care as a required consideration for discharge planners to better meet patient and family goals and prevent rehospitalization.
Get the details by clicking on the link below.
October TOT
Not Published This Month.
Subscriber Webinar
October 2019
The OIG Report (Part 2)
This was a continuation of September’s webinar regarding the OIG Report. Last July, the OIG released a scathing 2-part report, in which it found that hospice deficiencies pose a risk to patients. Furthermore, they called for safeguards to protect hospice patients from harm. This presentation reviewed the report in detail. We provided critical information you’ll need, and suggested actions that you should take in order to maintain your hospice’s integrity and reputation during these times of high accountability for hospice programs. Furthermore, we gave a short follow-up to the Wage Index webinar from June.
Speaker:
Barbara Ivanko, LCSW Hospice Fundamentals
November 2019
November FYI
FYI 19.15 Physician Assistants Serving as Hospice Attending Physician
Effective January 1, 2020, Physician Assistants (PAs) serving as Attending Physician for hospice patients may prescribe medications related to the terminal diagnosis.
Get the details by clicking on the link below.
November FYI
FYI 19.16 The Hospice Care Improvement Act of 2019
To address concerns raised by the OIG this summer in its two reports on hospice, Senators Rob Portman (ROH) and Ben Cardin (D-MD) introduced S.2807, a bill entitled the Hospice Care Improvement Act of 2019.
Get the details by clicking on the link below.
Subscriber Webinar
November 2019
Hospice Quality Reporting Program: 2019 Updates
As anticipated, the program continues to expand with new information on Hospice Compare and new quality measures in the works. In this month’s webinar we did a quick review of where we’ve been and where we might be going, discussed common problem areas, and provided ideas for helping hospices use the HRQP data to improve care.
Speaker:
Chris Acevedo, Principal, Hospice Fundamentals
December 2019
December FYI
FYI 19.17: Registered Nurses Did Not Always Visit Medicare Beneficiaries Homes at Least Once Every 14 days To Assess Quality of Care and Services Provided by Hospice Aides
This report is the fourth released from the OIG this year regarding concerns with the quality of hospice care. The OIG found that registered nurses (RNs) did not always visit the patient’s home every 14 days to assess the quality of care provided by the hospice aide (HHA), or document them in the medical record. The deficiencies occurred because of lack of oversight by the hospice, scheduling errors, employee turnover and ignorance of the regulation by the RN. This suggests to the OIG that there was no assurance that hospice patients received appropriate care from hospices.
Get the details by clicking on the link below.
December TOT
Not Published This Month.
Subscriber Webinar
December 2019
Clinician Connection–Cardiac Disease and COPD Eligibility and Care Planning
How well do you understand assessing and documenting eligibility for patients with cardiac / COPD diagnoses? Can you support it all with effective care planning? In this second, disease-specific installment of the Clinician Connection series, we took a look at care planning, IDG function, and eligibility.
Speaker:
Chris Acevedo, Principal, Hospice Fundamentals
