Jurisdiction M (JM) Home Health and Hospice (HHH) POE Advisory Group (POE-AG) Minutes: January 23, 2025

Published 02/12/2025

Facilitators: Dan George, Elizabeth Brogdon, Marlene Frierson and Charles Canaan

Attendees: 17

Welcome

Our Goals

  • Establishing and maintaining strong relationships with Palmetto GBA and our provider community 
  • Meeting with Palmetto GBA and the provider community on a quarterly basis 
  • Providing the communication tools to facilitate thorough and prompt transfer of information 
  • Coordinating issues within the provider community to adequately reflect the concerns of the majority

POE-AG Goals and Purpose — HHH POE-AG Charter

Old Business: Prior POE-AG Suggestions/Recommendations — N/A

New Business: POE-AG Training Suggestions and Education Recommendations
Participating members have the opportunity to benefit the provider community by helping to guide Palmetto GBA educational strategy for the upcoming year.

Information to Share

  • Targeted Probe and Educate — Resource for overview of TPE
  • Credit Balance Reporting — Starting December 1, 2024, providers aren’t required to submit Credit Balance Reports (CMS-838) (PDF) on a quarterly basis. You’re still required to report self-identified overpayments, but you should only use a Credit Balance Report when they occur.
  • Beneficiary Eligibility to Be Removed from Interactive Voice Response System on Jan. 31 — To protect beneficiaries from Medicare fraud, Medicare Administrative Contractors (MACs) must disable beneficiary eligibility information from their Interactive Voice Response (IVR) systems by March 31, 2025. Medicare providers will no longer be able to obtain beneficiary eligibility information via Palmetto GBA’s Interactive Voice Response (IVR) telephone system. Palmetto GBA will disable IVR beneficiary eligibility information on January 31, 2025, at 7 p.m. ET.
  • Meet Sage: Your New Chat Assistant for Claim Status Inquiries — Palmetto GBA is happy to announce the introduction of our newest chat self-service tool, Chat Claim Status, for Part A and home health and hospice providers. You will be able to check Part A and home health and hospice claim statuses through our chat application with the help of our automated digital assistant.

Home Health

  • Clinical Corner: Home Health Injections Module — This updated module focuses on vitamin B-12 and insulin injections in a home health setting. You will learn coverage requirements for these injections and how Medicare covers beneficiaries with diabetes.
  • Expanded Home Health Value-Based Purchasing Model
  • Change Request: 13684 (PDF) — Revisions to Home Health Edit Matching Claims to Notices of Admission. The purpose of this Change Request (CR) is to ensure home health claims submitted more than 24 months from the date of admission are not returned in error due to Notice of Admission records being purged from the Fiscal Intermediary Shared System.
  • MM13812 (PDF) — Allowing Home Health Telehealth Services During an Inpatient Stay CMS corrected their systems to allow G0320, G0321, or G0322 dates on an HH PPS claim to overlap inpatient stays. These services are non-payable reporting items, so they don’t create duplicate payment.
  • Home Health Agency Prospective Payment System (PPS) Claims Calculator — Updated for CY 2025.

Hospice

  • Provider Self-Determined Aggregate Cap Limitation Form Due February 28, 2025 — Palmetto GBA would like to remind providers that the Provider Self-Determined Aggregate Cap Limitation form is due February 28, 2025.
    • If the form is not received timely, a past due letter will be issued and payments will be suspended
  • Hospice Physician Certification Module — A hospice physician or medical director must certify that a patient is terminally ill to be eligible for hospice care. This module will provide an overview of the hospice eligibility; initial certification and recertifications; documentation requirements and the physician narrative. 
  • Hospice Performance Scales Module — Hospice performance scales are tools used to assess a patient’s physical abilities and functional status to determine if they qualify for hospice care. These scales are used in conjunction with other assessments in documenting patient function and establishing hospice eligibility.
  • This module provides an overview of the Karnofsky Performance Scale (KPS), Palliative Performance Scale (PPS) and Eastern Cooperative Oncology Group (ECOG) Scale.
  •  Notice of Cancellation TOB 8XD Billing Job Aid — Updated to include directions to cancel a Change of Provider/Transfer Notice (TOB 8XC)
  • Termination of the Hospice Benefit Component of the VBID Model on December 31, 2024 — The Centers for Medicare & Medicaid Services (CMS) has decided to conclude the Hospice Benefit Component of the Value-Based Insurance Design (VBID) Model as of December 31, 2024, at 11:59 p.m. For hospice elections that extend beyond the termination date of the Hospice Benefit Component, hospice providers should not discharge any patient solely because of their coverage in a plan participating in the Hospice Benefit Component prior to CY 2025. For those hospice elections that continue into 2025, no new Notices of Elections (NOEs) will be required. 
  • Hospice Certifying Physician Billing Instructions and Claim Editing — Instructions for all Hospice Claims and Notices Submitted after Nov. 18, 2024
  • The Hospice Face-To-Face Encounter and Telehealth Technology — This extension is applicable for claims with dates of service through March 31, 2025.

RCD News

Upcoming Education Events

  • 2025 HHH Workshop series, titled "Thrive with Medicare in 2025"

eServices

  • We've Made it Easier to Keep Your eServices Account Active — This enhancement is ideal for providers that don’t utilize the eServices portal on a regular basis. This new change no longer requires the need to login. Users will receive an email that contains a link to keep your account active.
  • HETS2025-1_Release_Summary_BESST_HETS (PDF) — Effective with this release, the 271 response for these individuals may also return an MSG segment stating why the individual was ineligible for Medicare coverage. The reasons an individual would be ineligible are:
    • Incarcerated
    • Deported
    • Not lawfully present

Note: eServices production date is scheduled for March 22, 2025

Open Discussion

Question: Hospices in Texas are being selected for a ‘High Risk’ review of claims. Do you know how these hospices are being selected? 

Answer: The High Risk Hospices in Texas prepayment review is the MLN7215293 — Expanded Prepayment Review of Existing Hospices in Arizona, California, Nevada, & Texas (PDF). CMS determines the hospices who selected for this prepayment review. To help reduce burden on compliant providers, CMS is keeping the initial review volumes low and adjusting them based on the results. If you’re noncompliant, CMS may continue to review or take additional administrative actions. 

This is not a TPE audit and does not follow all the same processes. For example, if a hospice is found compliant in the initial review, they will be removed from the review and not be offered education. Additionally, the initial reviews would likely be fewer than the 20–40 claims selected for a round of TPE. An additional round of reviews could exceed the amount of TPE reviews per round. Hospices participating in this review would be not selected for TPE or would be removed from TPE if selected for this review.

If a hospice is selected for the High Risk Hospices in Texas prepayment review, they will be notified by letter. Claims selected will be suspended in location S B6001 with reason code 51HRH. The narrative for 51HRH provides additional details about the review. 

Question: What is the timeframe for Palmetto GBA to review the medical records once received?

Answer: The MACs shall give each new medical record received an independent 30 day review period. The MACs shall count day one as the date each new medical record is received in the mailroom. This does not mean the selected claim will be processed by the MAC within 30 days, just the records will be reviewed, and a coverage determination would be made within 30 days. The claim would still be required to go through all processing edits, including eligibility validations, duplicate services, etc. 

Although providers have 45 days to respond to the medical record request, the earlier the response, the earlier our review will be completed.

Question: For the Home Health Review Choice Demonstration (RCD), if a HHA selects Choice 3: Selective Postpayment Review, can they change that selection at the end of a cycle period?

Answer: No. Under this choice the HHA will render services and submit claims according to their normal process. Every 6 months, the MAC will select for postpayment review a statistically valid random sample of claims. The HHA will remain in this choice for the remainder of the demonstration and will not have an opportunity to select a different choice.

Resource: Page 24 of the RCD-Operational-Guide.pdf (PDF).

Question: I have a hospice that cannot access the Provider Statistical & Reimbursement System (PS&R) to get the reports needed for their Self-Determined Hospice Cap (SDHC) Report submission. Is there another option to get the report?

Answer: For Provider Statistical and Reimbursement (PSR) requests, a hospice may email STAR@palmettogba.com to request the report. 

Question: If a hospice is terminated from the Medicare program, will they be required to repay hospice cap overpayments?

Answer: Yes, payments more than the cap are overpayments and must be refunded to the Medicare program. Each year Palmetto GBA performs a review of the hospice cap and incorporates any SDHC overpayment. This review also evaluates prior years to determine if there have been material changes, such as a change in the beneficiary count.

After completing the review, a notice of “Inpatient Day Limitation and Hospice Cap Amount” is issued. If material changes are noted in prior year reviews, the prior year determination(s) is reopened and revised. CMS requires contractors to review the three prior years as part of the current year review. Of note, if a hospice initially exceeded (or was close to exceeding) the aggregate cap, a revised determinations for that year may result in an additional overpayment.

Resource: Hospice Caps.

Next Meeting: April 17, 2025. The 2025 HHH POE-AG meeting dates are posted on the Provider Outreach and Education Advisory Group (POE-AG) website when available.


Was this article helpful?

mln