Home Health and Hospice Coalition Questions and Answers: February 7, 2022

Published 04/07/2022

Home Health and Hospice Coalition Q&A
Palmetto GBA Provider Outreach and Education (POE)
February 7, 2022
Review Choice Demonstration (RCD) Meeting — 9 a.m. ET | Main Meeting — 10 a.m. ET

Attachments

RCD Pre-Meeting

1. RCD Cycle 3 Results — We have had reports from providers that their RCD Cycle 3 results scorecard has not updated in over a month. These are providers that consistently monitor RCD Cycle results as reported by Palmetto weekly to make sure that agree with what is reported. Is there a current issue with this reporting process that is delaying availability of current results? Any updates related to the delay for PCR reviews and rendering decisions? Do they have an anticipated date when things might begin to return to normal?

Answer: The issue causing the delay was resolved a few weeks ago.

2. Palmetto GBA most often offers us data and statistics related to RCD performance, but maybe they could speak to any unique issues or variations in the states?

Answer: From a data perspective, there are not many differences between the states.

Main Meeting 

1. Can you share with us any future focus areas for Hospice TPE?

Answer: General Inpatient care and New Hospice providers continue to be the focus of TPE.

2. Are there any updates on NOA Reason Code 19960 beyond what has been posted on their Claims Payment Issues Log? Could we have an update on the system issues with the Home Health NOA?

OPEN: Home Health Notice of Admission (NOA) Reason Code U537F, Home Health Admission Overlap

  • RC U537F is assigning incorrectly on some NOAs due to the Common Working File (CWF) not correctly recognizing discharges (patient status other than 30 on the last HH period). A system fix to correct this issue is being created, but an implementation date has not been established.
  • RC U537F edits correctly:
    • Duplicate NOAs were submitted
    • There is an open home period on file (Patient Status 30) from a different home health agency

RESOLVED: Home Health: Notice of Admission (NOA) Reason Code 19960, Condition Code Other Than 47

  • Resolved 1/28/2022
  • For most NOAs affected by this issue, Palmetto GBA was able to remove Condition Code 15 and reason code 19960 prior to the NOA returning to the provider (Status/Location TB9900), which will allow the NOA to process without returning to the provider for this issue and affecting the received date
  • NOAs that were returned to providers for reason code 19960 are being entered back into processing, with CC 15 removed, by Palmetto GBA
  • Providers will need to request a late NOA exception on the corresponding claim if it was late due to this issue. In the remarks for these exception requests, provider shall enter “Late due to CC 15 release.”


RESOLVED: Home Health: Notice of Admission (NOA) Reason Code 32114

  • Resolved 1/19/2022
  • Agencies may again submit NOAs via EMC/electronically
  • If an NOA is late due to this issue, request a late NOA exception and indicate the following in the Remarks field of the claim(s) “January 2022 NOA reason code 32114 issue”

3. Please clarify the NOA process when a patient changes from a Medicare advantage plan to Traditional Medicare. We would submit the NOA as soon as we became aware. We would like Medicare to cover the visits that were provided after the payer change to MC. Will we be penalized 1/30th of the payment due to something was out of our control, with the submission of a late NOA. 

Answer: Yes, this covered in Palmetto GBA’s Home Health Notice of Admission (NOA) Frequently Asked Questions (FAQ) (PDF).

26. Is there any guidance about billing for an exception to the late NOA penalty when we find out the beneficiary had switched from a MA plan to Original Medicare after the fact?

Answer: Yes. Since Original Medicare begins as of the first visit after the MA enrollment period ends, the NOA will need to be billed with the date of the first visit under Original Medicare, and all visits from that point are billed to Original Medicare.

In cases where the HHA does not find out the beneficiary had disenrolled from their MA plan until well after the fact, or until the HHA gets a denial from the MA plan, the NOA should be submitted as soon as possible. The corresponding period of care claim is then billed with the KX modifier and the following statement in Remarks: “CR12256 disenroll MA XX/XX/XXXX.” The XX/XX/XXXX date should be the day the MA coverage ended, e.g., “CR12256 disenroll MA 12/31/2021.”
 

4. Can clarification be made on the therapy FA Requirements? Is there a grace period allowed for when it can be completed? Does it have to be every 30 days? What are the Medicare guidelines pertaining to it?

Answer: Medicare Benefit Policy Manual 40.2.1 (PDF) — General Principles Governing Reasonable and Necessary Physical Therapy, Speech-Language Pathology Services, and Occupational Therapy (Rev. 10438, Issued: 11-06-20, Effective: 03-01-20, Implementation: 01-11-21)
Reassessment must be performed at least every 30 days (performed in conjunction with an ordered therapy service); there is no exception or grace period. Non-reassessment visits billed starting on the 30-day reassessment due date and until a valid reassessment is completed will not be paid on an ADR’d claim and should not be billed as covered on any claim.

5. Can a resident that is enrolled in Medicare and licensed to practice medicine in the state where the services are delivered certify patients and order home health services under the Medicare program?

Answer: All work performed by the resident must be under the supervision of the teaching physician. (Teaching Physicians)

  • A Resident is an individual who participates in an approved graduate medical education (GME) program or a physician who is not in an approved GME program but who is authorized to practice only in a hospital setting
  • The term includes interns and fellows in GME programs recognized as approved for purposes of direct GME payments made by the Part A Medicare Administrative Contractor (MAC)
  • Receiving a staff or faculty appointment or participating in a fellowship does not by itself alter the status of "resident"
  • Additionally, this status remains unaffected regardless of whether a hospital includes the physician in its full-time equivalency count of residents
  • Teaching Physician is a physician (other than another resident) who involves residents in the care of his or her patients
  • Home Health Face-to-Face Encounter Question & Answers — Revised May 9, 2014 
    • Question 1: Will requirements be met if a community physician certifies a patient and completes a plan of care when a face-to-face encounter was conducted and documented appropriately on a discharge summary or referral that is conducted by a resident who is not enrolled in Medicare? 

      Answer 1: Yes, a resident who is not Medicare-enrolled can perform the face-to-face encounter, but only under the supervision of a teaching physician who has privileges at the acute or post-acute facility. Because the physician performing the face-to-face encounter in an acute or post-acute facility must have admitting privileges, it is only acceptable for a resident to perform the face-to-face encounter in an acute or post-acute facility and inform the certifying physician through their supervising teaching physician who has such privileges. However, it is the certifying physician who must document the face-to-face encounter. The certifying physician has the discretion of whether or not to sign that discharge summary or communication documentation, indicating that it is to serve as the certifying physician’s face-to-face documentation. It is allowable for the certifying physician to use the discharge summary or referral as documentation of the face-to-face encounter if: 
      • The discharge summary or referral meets all the documentation requirements for face-to-face documentation; and
      • The discharge summary or referral, which is serving as the face-to-face documentation, is dated and clearly titled as such; and
      • The certifying physician signs the discharge summary or referral, demonstrating that the certifying physician received that information from the teaching physician supervising the resident who performed the face-to-face encounter, and that the certifying physician is using that discharge summary or referral as his or her documentation of the face-to-face encounter

Home Health Face-to-Face Encounter Question and Answers (PDF)

Question 36: Can a resident conduct the face-to-face encounter? 

Answer 36: The certifying physician, allowed NPPs, or, for patients admitted to home health immediately after an acute or post-acute stay, the physician who cared for the patient in the acute or post-acute facility and who has privileges at the facility, can perform the face-to-face encounter. Because residents do not have privileges, if a resident is not the certifying physician and is performing the face-to-face encounter, the resident must inform the certifying physician of the encounter through the supervising teaching physician who must have such privileges. Only Medicare-enrolled physicians can certify home health eligibility, per the Affordable Care Act.
 

6. Medicare Compare Website — We have had reports from providers that their data is coming back incorrect following updates to the Medicare Compare Website. For example, the report from one provider stated, “Our service list now shows that we only provide SN services and that we do not provide PT, OT, ST, MSW or Home Health Aide services. I looked at three other HHAs in our market and they all show varying levels of services when I know that they all provide all of the services listed like we do. In short, this appears to be a global issue and not just related to our agency.” Is there a known reason why this is happening? Is there a fix for this in the works? If so, is there a timeline? 

Answer: 
How to Update Home Health Demographic Data.

Historically provider demographic data have been maintained in the Automated Survey Processing Environment or ASPEN software; however, CMS will be transitioning to use the demographic information from Provider Enrollment, Chain and Ownership System (PECOS). While this transition is underway, a final date when all demographic data will be obtained from PECOS has not been identified. During this transition, all Post-Acute Care (PAC) providers will be responsible to ensure their latest demographic data are updated and available in both the ASPEN and PECOS systems.

A referencing document that outlines the steps each PAC provider should follow can be accessed here. Should you have questions regarding this updated process, please contact the iQIES help desk by email at iQIES@cms.hhs.gov or by phone at 800–339–9313.

The download in this article states to both check your Medicare enrollment with your MAC and contact your state automation or state OASIS Education Coordinator (OEC) and request an update of your demographic data in ASPEN.

Please note: updates to home health provider demographic information do not happen in real time and can take up to six months to appear on Care Compare.
 

7. What are the surveyor instructions on how to survey for the COVID-19 vaccine mandate where religious exemptions are granted? Specifically, documentation requirements expected from the agency?

Answer: 

  • MACs are not involved with oversite of this policy. HHA and Hospice guidance downloads for this subject are available at Guidance for the Interim Final Rule — Medicare and Medicaid Programs; Omnibus COVID-19 Health Care Staff Vaccination.
    • This is state agency enforced
    • This does not apply to 11 of the 16 HHH states
    • The regulations and guidance described in this attachment do not apply to the following states at this time: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Texas, Utah, West Virginia and Wyoming. Surveyors in these states should not undertake any efforts to implement or enforce the regulation.
  • Non-medical exemptions, including religious exemptions:
    •  Requests for non-medical exemptions, such as a religious exemption in accordance with Title VII, must be documented and evaluated in accordance with each hospice’s policies and procedures. We direct hospices to the Equal Employment Opportunity Commission (EEOC) Compliance Manual on Religious Discrimination for information on evaluating and responding to such requests.
    • Note: Surveyors will not evaluate the details of the request for a religious exemption, nor the rationale for the hospice’s acceptance or denial of the request. Rather, surveyors will review to ensure the hospice has an effective process for staff to request a religious exemption for a sincerely held religious belief.
       

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