CMS Provides Home Health and Hospice Updates in February 2022 Open Door Forum

On February 24, CMS hosted an Open Door Forum for Home Health, Hospice and Durable Medical Equipment (DME) providers. Below are some of the key announcements made during the call.

DME Update on the Master List and Prior Authorization

Home health agencies who work closely with DME providers for Power Mobility Devices (PMD) or orthoses (braces) may experience some lag time in orders over the next six month due to updated CMS guidance in response to OIG reports and integrity efforts for improper payment. Starting on April 13, 2022, certain PMD and orthoses DME items will require a face-to-face encounter and written order prior to delivery as a condition of payment. The update will be implemented in 3 phases to reduce unforeseen claims issues:

• Phase 1: April 13, 2022: New York, Illinois, Florida and California
• Phase 2: July 12, 2022: Maryland, Pennsylvania, New Jersey, Michigan, Ohio, Kentucky, Texas, North Carolina, Georgia, Missouri, Arizona, and Washington
• Phase 3: October 10, 2022: All remaining state and territories

Home Health NOA Error U537F Update.

CMS shared a new edit will be installed next Monday to fix the issues with Notice of Admission (NOA) Error Code U537F which was caused by the Common Working File to not correctly recognize discharges. CMS said after Monday, February 28^th home health agencies can resubmit the NOAs and they will qualify for NOA timeliness exceptions. Before submitting the NOA again, make sure a NOA is not already in the system pending processing or finalized before submitting a new NOA for that patient. Agencies should not be submitting multiple NOAs for same admission. If your agency is not the provider on prior home health episodes posted on the CWF, you will need to bill with condition code 47 on the new NOA to avoid the U537F error. For more information on the current rejection issues and find additional resources you can view an article here.

New Home Health Grouper Program

On February 10, CMS released updated home health PPS Grouper software with updated ICD-10 diagnosis codes which will go into effect April 1, 2022. The update adds three new diagnosis codes, deleted one diagnosis code, and updated a clinical group assignment for one diagnosis code.

This Month New Web-Based Pricer Program

In March, CMS will launch a new web-based PC Pricer tool used to estimate Home Health and Hospice Medicare payments for the Perspective Payment System. CMS has been working over the last year to convert all the downloadable Personal Computer Pricers to web-based applications meaning providers will not need to download software as it will always be available and updated automatically online. Agencies should continue to check in on the tools availability and save the online location.

Home Health CAHPS Survey Update

RTI, the contractor for the Home Health CAHPS survey, provided their annual training to vendors in late January and have offered to share the training with any interested home health agencies. Interested agencies can reach out for a recording by emailing hhcahps@rti.org. The HHCAHPS team issued a reminder to all Medicare-certified home health agencies (HHAs) that the deadline for submitting an exemption from participating in the HHCAHPS Survey for the CY 2023 is Thursday, March 31, 2022. Medicare-certified HHAs that served 59 or fewer unduplicated patients between April 1, 2020 and March 31, 2021 who met survey eligibility criteria can request a Participate Exemption Request for the CY 2023 APU. HHAs can access the online PER form on HHCAHPS website. The next submission deadline for HHCAPS is Thursday, April 21 and home health agencies can view and confirm survey data has been successfully submitted by their contracted vendor via the HHCAPS website.

OASIS-E Updates

The Office of Management & Budget (OMB) issued a Notice of request for comments for the Outcome and Assessment Information Set (OASIS)-E as part of their review for implementation of the new items January 1, 2023. The Notice includes three attachments and the supporting statement document outlining the burden estimate for both home health agencies (HHAs) and the federal government. Comments on this Notice are due April 11, 2022. LeadingAge staff are preparing comments on this Notice and encourage members to share feedback on the item changes and CMS’ burden estimates with kbarnett@leadingage.org.

OASIS Point Score Change for PDGM

CMS also shared a change in the OASIS point score around functional impairment from the CY2022 Proposed Rule to the CY2022 Final Rule. Table 2 of the CY2022 final rule the OASIS Item M1860: Ambulation/Locomotion has an updated point score from what was initially proposed.

Home Health Public Reporting Refresh Coming in April

In April 2022, publicly reported OASIS data will be released with two new measures to align with cross-setting measures from the Improving Medicare Post-Acute Care Transformation (IMPACT) Act:

1) Percent of Residents Experiencing One or More Falls with Major Injury; and

2) Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan that Addresses Function.

While these two new OASIS measures will be publicly reported, CMS made the decision to delay the resumption of claims-based quality measures in order to analyze the impact of the exclusion of Q1 and Q2 2020 claims data on risk adjustment and reporting. CMS is targeting July 2022 refresh of Care Compare for the claims-based measure updates. CMS updated the Home Health Quality Reporting Program COVID-19 Public Reporting Tip Sheet.

Hospice Quality Reporting Program TEP Update

CMS released a Summary Report from the Hospice Quality Reported Program Technical Expert Panel (TEP), the experts helping define the next iteration of quality reporting for hospice agencies. The report provides insights into how the Hospice Outcome & Patient Evaluation tool (HOPE), which will eventually replace the current Hospice Item Set (HIS), is being considered and developed by CMS contractor Abt Associates. Key takeaways from the report include:

• Focus on timely reassessment of symptoms as an important priority when considering future HOPE process measures;
• Interest in a medication management process measures, though the TEP felt individuals in inpatients facilities should be excluded from that measure; and
• Reservations about the usefulness of data from deficiencies and complaint surveys to determine hospice quality.

Hospice Care Compare Refresh Now Available.

The February 2022 quarterly Hospice Quality Reporting Program has gone live on Care Compare. Data submission requirements were temporarily put on hold after the November 2020 refresh. The Hospice CAHPS Survey measure scores continue to exclude Q1 and Q2 of calendar year 2020. As a reminder, in CY 2022, all hospices must meet the threshold requirements for Hospice Item Set (HIS) submission of 90% and participate in Hospice CAHPS to avoid a 4% reduction in their FY 2024 Annual Payment Update. As a result of the Consolidated Appropriations Bill of 2021, this will be the first year of increased penalties from 2% to 4%.