When is the last time you entered a complaint in your grievance log? One of the core standards of focus for hospice surveyors is §418.52(b)-Exercise of rights and respect for property and person. The interpretive guidelines for this standard state that a “grievance is a formal or informal written or verbal complaint made to any…
Tag: CMS
HHVBP
Home health agencies are living in the midst of CMS’ expansion of Home Health Value-Based Purchasing (HHVBP) Model. There are quite a few intricacies to grasp regarding this program; however, CMS has published a self-assessment tool to help agencies get on track. An added bonus of this tool is the QAPI aspect. Don’t forget that MAC Legacy…
CMS Quarterly Q&As
CMS released the January 2023 Quarterly Q&As on Tuesday and among many topics, there is continued confusion surrounding the transition period. The Q&A guidance reiterates that the M0090 Date determines which version of the OASIS to complete and not necessarily the beginning date of the episode of care. The quarterly Q&As address questions that arise from real-life…
Claim Denial
Nothing can be quite as deflating to hospice leadership and staff as these words. Whether hospices are in the midst of TPE or other medical review, a common denial reason is failure to support the six-month terminal prognosis. Diagnosis alone may not suffice in establishing the physician’s prediction of the patient’s life expectancy. Hospices with…
CMS Waivers
In a webinar presented by the National Association of Home and Hospice Care last week, Katie Wehri Director of Home Care & Hospice Regulatory Affairs at NAHC, warned hospices to examine their need to continue the use of the Public Health Emergency for COVID-19 waivers. As you know, the CMS waivers were established to assist…
OASIS-E
The OASIS -E is set to be implemented in January, and the CY 2023 Home Health Prospective Payment System Rate Update includes CMS’ estimated time spent for the data entry of various OASIS collection time points. This estimation is based on reported CY 2020 assessment totals per assessment type. Using this CY 2020 data, CMS…
Home Health Value-Based Purchasing
The Home Health Proposed PPS Rule for CY 2023 contains some proposals for the Expanded HH Value-Based Purchasing program. The program officially begins January 1, 2023. The term “baseline year” has now been replaced with the terms “HHA baseline year” and “Model baseline year”. The HHA baseline year is now proposed to be the calendar year used…
Hospice Transfers
The new CMS rule regarding hospice transfers is set for implementation on Tuesday, July 5th. In case you missed it, the MLN Matters MM12619 was released in February. The Common Working File will no longer accept gaps of care to occur during a transfer. This means the claim will be rejected if there is a gap in…
CY 2023 Home Health Payment Proposed Rule
Last week, CMS released the CY 2023 Home Health Payment Proposed Rule. The news is not cheery. In fact, as Bill Dombi, President & CEO of the National Association for Home Care & Hospice stated, “CMS has declared war on home health care”. During the 60-day comment period which will end on August 16, 2022,…
Allowed Practitioners
In June, CMS made a clarification to a previous transmittal which allows clinical nurse specialists, physician assistants, and nurse practitioners to certify eligibility and order services under the Medicare home health benefit. These individuals, of course, are defined as allowed practitioners. The CMS Transmittal 11447 replaced Transmittal 11386 (previously released in April 2022) and stated…
