CMS Releases Change Request 8358

The Centers for Medicare and Medicaid Services (CMS) released Change Request (CR) 8358, Additional Data Reporting Requirements for Hospice Claims.  The implementation date on the CR is January 6, 2014. There is, however, additional voluntary reporting and mandatory reporting dates which are outlined below. CMS states that the additional claims data supports hospice payment reform as authorized by the ACA.  Last month, NAHC and its affiliate, the Hospice Association of America (HAA), sent comments to CMS on the Proposed Rule:  Medicare Program; FY2014 Hospice Wage Index and Payment Rate Update; Hospice Quality Reporting Requirements; and Updates on Payment Reform (CMS-1449-P). 

In those comments, NAHC and HAA urged CMS to obtain needed data that accurately depicts costs while making informed decisions regarding hospice payment reform.  Both NAHC and HAA are pleased that CMS has taken this step of obtaining additional data prior to implementing reforms to the hospice payment system.

The additional data that will go on hospice claims includes:

· General inpatient (GIP) visit reporting for certain hospice-paid staff
· Facility National Provider Identifier (NPI) number when care provided is not at the hospice facility that is billing the care
· Post mortem (PM) visit reporting
· Reporting of infusion pumps and prescription drugs

Mandatory reporting of these additional items on claims begins with claims with dates of service on or after April 1, 2014 with voluntary reporting beginning January 1, 2014.  The CR provides instructions to the MAC and also revises Section 30.3 of Chapter 11 of the Medicare Claims Processing Manual.

Hospices will begin reporting line-item visit data for hospice-paid nurses, aides, social workers, certain calls made by social workers, physical therapists, occupational therapists, and speech-language pathologists providing care to hospice patients receiving GIP in skilled nursing facilities (Q5004) or in hospitals (Q5005, Q5007, Q5008).  The visit data includes the number of visits and length of visit in 15-minute increments and number of calls and length of calls in 15-minute increments for certain social worker calls.  Again, this is for hospice-paid staff only.  Visit data for non-hospice paid staff are not included.  There are no changes to the existing GIP reporting requirements for GIP services provided in a hospice inpatient unit (Q5006). 

Hospices will also report the name, address, and NPI of any nursing facility, hospital (including long term care hospitals and inpatient psychiatric facilities), or hospice inpatient facility when services are provided at any of these locations that is not the same location as the billing hospice’s location. This applies to all levels of care.  In situations where the patient received care in more than one facility during the billing month, the name, address and NPI of the facility where the patient last received services shall be reported on the claim. The CR requires that claims without the required facility NPI information be returned to provider (RTP’d) by the Medicare administrative contractor (MAC) for claims with dates of service on or after April 1, 2013. 

Hospices will use a PM modifier on the claim for visits that occur on the patient’s date of death after the patient has passed away.  Visits occurring after the date of death will not be reported.  These visits will be reported for all levels of care in all sites of service and shall include the number of visits and length of visit in 15-minute increments for hospice-employed nurses, aides, social workers, and therapists. 

In addition, hospices will begin reporting injectable and non-injectable prescription drugs on their claims on a line-item basis per fill.  Over the counter (OTC) drugs are not reported on the claim.  Hospices also need to report infusion pumps on a line-item basis for each pump order and for each medication refill.  DME other than infusion pumps are not reported on the claim.  Hospices will have to use pharmacy, National Drug Code (NDC) and DME revenue codes (e.g. 0250, 029X and 0636) on the claim in order to include this data.  The NDC data includes the quantity of the drug filled. 

All the additional data added to the claim per this CR will appear on the Medicare Summary Notice (MSN) to consumers in the same manner as hospice visit reporting currently appears.

There is one area of this CR on which we are seeking clarification and that is the terminology “hospice-paid” and “hospice-employed”.  CMS uses hospice paid staff when referring to all visit data to be put on the claim except for the post mortem visits. CMS specifies that the PM visit data be for the specified disciplines employed by the hospice.  The discipline visits that occur post mortem would not typically be from hospice-contracted staff but there are exceptional circumstances where a hospice may have a contracted staff member providing such a visit.  We believe CMS intends for these visits to also be reported, but, as mentioned above, we are seeking clarification on this point.  We will provide you with the answer when it is received.

Hospices should begin working on these changes now by reviewing their data collection systems to be sure they can obtain the necessary level of detail.  Hospice billing personnel and contractors will need to familiarize themselves with the NDC as well as the applicable pharmacy and DME revenue codes.  These revenue codes appear to be limited in number based on the changes made to the Claims Processing Manual instructions but billing personnel and contractors will want to verify this.

At the time this article went to print, the full CR was not posted on the CMS website.  NAHC and HAA expect it to be posted momentarily to the Transmittals page of the website.

Providers should check that page here for the full CR.