July 1, 2014 is the effective date for several policies from the Centers for Medicare & Medicaid Services (CMS). See below to review a checklist of new requirements every hospice and home health provider must start following.
√ 5 Day Payment Limit for Respite Care
This item eliminates the use of occurrence code M2 on claims when there is more than one respite period in a billing period. The language states any claims submitted with more than five consecutive days billed for respite care will be returned to the provider. The change is not in the policy itself, but in the commitment by CMS to enforce the practice with the threat of potential penalties.
√ Direct Submission of HIS Admission and Discharge Records
For each patient admitted after July 1, 2014, a Medicare-certified hospice must collect Hospice Item Set (HIS) electronic records. Failure to meet the reporting requirement will result in a 2 percent reduction in hospice payments for FY 2016. Click to read the proposed rule by CMS on hospice payment rates.
√ Medicare Advantage Requires HIPPS Coding
After being delayed twice to allow home health agencies to make systems and operational adjustments, after July 1, 2014, CMS will require Health Insurance Prospective Payment System (HIPPS) codes on Medicare Advantage (MA) plan claims. This directive also applies to contracted providers of MA plans.
√ Certifying and Attending Physicians Subject to Enrollment
For episodes that begin on or after July 1, 2014, certifying and attending physicians must be enrolled in the Provider Enrollment, Chain and Ownership System (PECOS). Home health agencies are now required to report the name and the National Provider Identifier of the physician who certifies/re-certifies the patient’s eligibility to receive services under the Medicare home health benefit. The same reporting must be done if there is a separate attending physician who signs the patient’s plan of care.
√ Agencies Subject to Alternative Sanctions
Home health agencies not complying with the July 1, 2014 conditions can have sanctions placed on their participation. CMS has the authority to impose civil money penalties, suspension of payment for new admissions, temporary management of the HHA, a directed plan of correction and in-service training. Click to read the survey and enforcement process outlined by CMS for home health agencies.