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CMS Issues Clarifications for Implementation of Hospice change Request (CR) 8358

On January 31, 2014, CMS published transmittal 2864 which replaced transmittal 2747 from July 26, 2013, and aimed to provide clarifying language, additional information, and examples to CMS Change Request (CR) 8358 -“Additional Data Reporting Requirements for Hospice Claims”. 

As compiled by Mark Romano, Manager at Simione, highlights of the clarifications and additional information are as follows:  

  • CMS confirmed that the mandatory implementation date for these additional data requirements is April 1, 2014. Voluntary reporting has been initiated since January 1, 2014.
  • General Inpatient (GIP) Visits- New language clarifies that this change imposes the same line-item requirements as currently applied under routine home care and continuous home care:
    • "This includes visits by hospice nurses, aides, social workers, physical therapists, occupational therapists, and speech-language pathologists, on a line-item basis, with visit and visit length reported as is done for routine home care and continuous home care."
  • Injectable/Non-injectable Drugs - Greater clarification is provided regarding the reporting on injectable and non-injectable drugs under certain situations such as: facility medication systems, multi-ingredient compound prescription drugs, comfort kit medications and infusion pumps. 

Facility Medication Systems

  • When a facility (hospital, SNF, NF, or hospice inpatient facility) uses a medication management system where each administration of a hospice medication is considered a fill for hospice patients receiving care, the hospice shall report a monthly total for each drug (i.e., report a total for the period covered by the claim), along with the total dispensed.

Multi-ingredient Compound Prescription Drugs:

  • Multi-ingredient compound prescription drugs should be reported using revenue code 0250.
  • The hospice should provide the same prescription number for each ingredient of the compound drug according to the 837i guidelines, in loop 2410 of the electronic claim.
  • The NDC (National Drug Code) should also be provided for each ingredient in the compound; the NDC qualifier represents the quantity of the drug filled (amount dispensed) and should be reported as the unit of measure.

Comfort Kit Medications:

  • When reporting prescription drugs in a comfort kit/pack, the hospice should report the NDC of each prescription drug within the package, in accordance with the procedures for non-injectable prescriptions. 

Infusion Pumps:

  • Infusion pumps (a type of DME) are to be reported on a line-item basis for each pump and for each medication fill and refill.
  • The hospice claim should reflect the total charge for the infusion pump for the period covered by the claim, whether the hospice is billed for it daily, weekly, biweekly, with each medication refill, or in some other fashion.
  • Included on the claim should be the infusion pump charges on whatever basis is easiest for the hospice's billing systems, so long as in total, the claim reflects the charges for the pump for the time period of that claim. 
  • Post-Mortem Visits- More detail on post-mortem visits is given:
    • Hospices should report visits and length of visits (rounded to the nearest 15-minute increment), for nurses, aides, social workers, and therapists who are employed by the hospice, that occur on the date of death, after the patient has passed away.
    • Post-mortem visits occurring on a date subsequent to the date of death should not be reported.
    • Post-mortem visits are to be reported regardless of the patient's level of care or site of service.
    • The date of death is defined as the date of death reported on the death certificate.
    • Visits that occur before death should be reported on a separate line from those which occur after death.

There are many more outstanding questions related to this requirement with even more clarifications coming.  The MACs and the state/national associations will continue to provide hospices with updated information as it becomes available.

It is anticipated that these processes will have a significant impact on daily hospice operations especially with the mandatory reporting date of April 1, 2014. Providers will need to evaluate the impact of these requirements and find ways to streamline operations to maintain compliance with not only these requirements, but also the multitude of upcoming changes that will affect reimbursement, financial and clinical operations.

In anticipation of these changes, Simione Healthcare Consultants continues to recommend the following strategies for hospice organizations:

  1. Continue to stay informed through your MAC, state and national associations regarding any additional clarifications or changes to the CR8358 requirements.
  2. Contact and work with your software vendor to determine its state of readiness for these changes, as well as its contingency plans to meet the new requirements.  Keep in mind that many outstanding issues/questions involving the Change Request pertain to process details that software vendors will need to have in order to initiate some of the changes.  This will undoubtedly affect the timeframe for implementation of the requirements.
  3. Work with your pharmacy vendor to ensure it is aware of the changes and is prepared to provide the needed codes and detailed information to your organization.  The pharmacy vendor will need to be able to provide this information quickly to avoid delays in hospice billing and cash flow.  Internally, your organization should begin to develop a process for online look up of HCPCS and NDC codes to facilitate receipt of this information.
  4. Provide ongoing education to staff and managers regarding the additional reporting requirements, as well as the other changes which impact the hospice agency and staff.
  5. Conduct an evaluation of your current hospice operations (policies, procedures, documentation, work flow and personnel) to identify what changes will need to be made to meet the new requirements. Remember to include all of the upcoming quality reporting, coding and cost reporting changes, and the impact on your hospice's compliance activities. This is an important area for hospice operations in preparing for the changes.
  6. Develop a work plan within your organization to address operational issues necessary to meet the new requirements. These are sweeping changes, so it is imperative that departments and staff across your entire organization be included in the work plan. Note that the work plan will need to be flexible and evolve as additional information is received from CMS.

Simione has a team of experts who can assist with all aspects of hospice operations and service delivery.  We are well-prepared to provide operational reviews and education to help your organization in successfully navigating these new requirements facing the hospice industry.

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