Lately, home health and hospice providers have had to stay on their toes to stay in compliance. But this isn’t the time to tiptoe around compliance issues that affect the way your agency runs. Industry thought leader Sharon Harder provides in-depth insight about these new issues in her new home health and hospice compliance alert, and here’s a shortlist of the top compliance issues you need to know about:
Home Health Compliance
- CMS has proposed a six-month implementation delay for new Conditions of Participation (CoPs). It is expected that the new CoPs will become effective on January 13, 2018. Agencies will be well served to start thinking about how to work toward implementation of the new CoPs pending the release of additional interpretive guidelines.
- The Pre-Claim Review demonstration project has been indefinitely paused. The postponement of Pre-Claim Review in Florida and the cessation of the process in Illinois have been widely reported. As of April 1, the MACs were instructed to cease the reviews and are not reviewing any PCR requests at this time. CMS will notify providers at least 30 days in advance of any additional changes or reactivation of the demonstration project.
- CMS has now announced that Probe and Educate will be resurrected in Illinois and Florida. While Pre-Claim Review is on hold, Probe and Educate reviews are not. Illinois providers for which Pre-Claim Review decisions are on file will not be selected for Probe and Educate reviews on those claims.
- In 2017, pursuant to 42 CFR 484.210(e), the submission of SOC, ROC or Recertification OASIS has now been effectively raised to a condition of payment. If the OASIS is not found and the receipt of the claim is more than the allowed number of days after the assessment completion date reported on the claim, Medicare will deny the claim.
- Two new regulatory changes that were addressed in the 2017 Home Health Final Rule have now been codified and published as additions to the Medicare Policy Manual, Chapter 7 and the Medicare Claims Processing Manual, Chapter 10. These changes affect payment for negative pressure wound therapy (NPWT) using a disposable device and the methodology used to calculate outlier payment. Details can be found in CR9898 for implementation as of March 27, 2017.
- The Office of Inspector General (OIG) released a new report on hospice notice of election (NOE) statements. CMS reacted by publishing a new NOE form example to help hospices understand what does — and does not — need to be included. You can download an example NOE form here in the Spring 2017 Compliance Alert.
- Notices of election (NOEs) with future dates will be returned, which could potentially delay timely filings that have revenue consequences. As of July, Medicare will prevent notices from being accepted when a future date is present in the admission date field or the from date field on an election notice (8xA), a termination (8xB), transfer (8xC), or a cancellation (8xD) or change of ownership (8xE).
For more detailed information on these regulations and more, download and read Sharon Harder’s Spring 2017 Compliance Alert.