Author: Amy Ross

Hospice Plan of Care Deficiency

Plan of Care, L-Tag 543, is one of the top cited deficiencies in hospice. This means the hospice failed to ensure all hospice care and services provided to patients and families followed an individualized written plan of care established by the interdisciplinary group.  Collaboration with the attending physician (as applicable), patient or patient representative, and…

Home Health Referral

The beginning of every home health services admission or resumption of care starts with a referral. It seems so simple. However, just what is required for a referral to be valid?  Home health agencies continue to struggle with this and are negatively affected by the process measure, timely initiation of care, when an invalid referral…

Hospice Governing Body

Hospices are required to have an organized governing body that has complete and ultimate responsibility for the organization, including legal and financial authority. This condition of participation—§418.100 and §418.58–requires the governing body to be informed of the hospice’s ongoing operations, including patient care delivery issues and QAPI activities. It’s imperative there is evidence of the…

Home Health Quality Reporting

In case you missed it, the 2023 Home Health Prospective Payment System Rate Update, Home Health Quality Reporting Program Requirements: Home Health Value-Based Purchasing Expanded Model Requirements; and Home Infusion Therapy Services Requirements Final Rule was released on October 31, 2022.  The published version is scheduled for release on 11/04/2022.  For the preview version, click on the…

Prediction of Terminal Illness

Prediction of terminal illness can be difficult for hospices.  Local Coverage Determinations (LCDs) are guidelines developed by Medicare Administrative Contractors (MACs)—CGS, NGS, and Palmetto GBA—to assist hospices determine hospice eligibility.  Although LCDs are not regulatory, the MACs use the LCD criteria in medical review.  Therefore, hospice organizations are wise to follow the LCDs as much…

OASIS-E – M0090 Date

The implementation of a new OASIS data set—OASIS-E—is set to begin in January for Medicare-certified home health providers.  However, the exact date of transition from OASIS-D1 to OASIS-E depends on the M0090 date.  As a reminder, the M0090 item captures the date the OASIS assessment is complete.  It’s defined as the last date the comprehensive…

Physician or Allowed Practitioner Signatures

Obtaining physician or allowed practitioner signatures on plans of care and/or verbal orders can be challenging at times for home health agencies.  This, in turn, can delay submission of claims and payment.  In the Medicare Benefit Policy Manual, Chapter 7, § 30.5.3, it states: “A physician or other allowed non-physician practitioner, other than the certifying physician…

ICD-10 Code Changes

A fairly large overhaul of the ICD-10 codes is set to begin on October 1st. In 2022, the update included 159 new codes while this year includes over 1,000 new codes.  Added to that, well over 200 codes were deleted.  It’s enough to make your head spin!  Significant changes were made to dementia codes to…

Hospice Final Rule Implementation

Just over the horizon, October and everything pumpkin is approaching.  This means the implementation of the hospice final rule for FY 2023–beginning on October 1st.  This year’s final rule includes a rate increase of 3.8% for those hospices who submit required quality data.  For those who don’t comply, a 2% payment penalty is assessed to…

OASIS-E New Items

Among the 27 new items slated for the new version of OASIS in January is O0110 – Special Treatments, Procedures, and Programs.  This very useful data collection item identifies special treatments, procedures, and programs that apply to the patient during the time period under consideration (on admission, at discharge, or within the last 7 days)…