Home health and hospice agencies are facing heightened audit scrutiny from various entities, including the Centers for Medicare & Medicaid Services (CMS), Office of Inspector General (OIG), Unified Program Integrity Contractors (UPICs), Medicare Administrative Contractors (MACs), and state health departments. These audits focus on ensuring accurate billing and reimbursement, compliance with federal and state regulations,…
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Home Health Proposed Rule Seeking Comment on Assessments by Therapists (PT, SLP, OT)
CMS seeks public comments regarding whether CMS should shift its longstanding policy and permit all classes of rehabilitative therapists (PTs, SLPs, and OTs) to conduct the initial assessment and comprehensive assessment for cases that have both therapy and nursing services ordered as part of the plan of care. They are asking the public for data,…
Hospice CARE Act Set To Reform Hospice
Rep. Earl Blumenauer (D-Oregon) announced draft legislation, the Hospice Care Accountability, Reform, and Enforcement (Hospice CARE) Act, on June 13, 2024, aiming for transformative reforms to hospice payment systems and regulatory oversight. The hope is to be introduce the bill in Congress later in 2024. A key element of the Hospice CARE Act is the…
CMS issued Change Request (CR) 13543 on 04/11/24 with Subject Line: Additional Enforcement of Required County Codes on Home Health Claims
While the stated purpose noted on this CR was to create an edit in the original Medicare systems to ensure required county codes are reported on all home health claims, other interesting tidbits were included. This CR was stated to also make makes clarifications to home health billing instructions regarding Notice of Admission timeliness exceptions,…
Substance Use Disorder Confidentiality Regulation
The U.S. Department of Health & Human Services (HHS) has announced a final rule, effective February 8, 2024, modifying the confidentiality regulations for Substance Use Disorder (SUD) patient records under 42 CFR Part 2. This aligns Part 2 with HIPAA and HITECH as mandated by the CARES Act of March 27, 2020. Key Changes:
Did the rules change regarding wound care as reasonable and necessary?
The rules did not change, but there has been a recent increase in Pre-Claim Review (PCR) non-affirmations when wound measurements and other clinical documentation is not submitted. In order for the wound care to be considered reasonable and necessary, the Medicare Benefit Policy Manual Chapter 7 – 40.1.2.8 Wound Care states, “the size, depth, nature…
Hospice Claim Edit
Beginning on May 1, 2024 a new claim edit will be implemented for hospice. This edit is associated with the condition of payment that was finalized in the FY 2024 Hospice Wage Index final rule that requires hospice certifying physician(s) to be enrolled in Medicare or have a valid opt-out on file. There are still…
Hospice Proposed Rule
The Centers for Medicare & Medicaid Services (CMS) posted the Proposed Fiscal Year (FY) 2025 Hospice Payment Rate Update (CMS-1810-P) on March 28, 2024. The proposed hospice payment rate update includes an increase in the per diem rate of 2.6%. This update is derived from the proposed inpatient hospital market basket update of 3.0%, with…
Occupational Therapy Month
April is Occupational Therapy Month and The American Occupational Therapy Association’s 2024 theme is Occupational Therapy: Advancing Health, Wellbeing and Quality of Life. What is Occupational Therapy? Simply put, occupational therapy enables people of all ages to participate in daily living. Our lives are made up of occupations-meaningful everyday activities. These occupations can include many…
Challenges In Providing Continuous Home Care To Hospice Patients
The Medicare Hospice Benefit affords patients four levels of care to meet their needs: routine home care, respite care, general inpatient care (GIP), and continuous home care (CHC). For hospice providers, the majority of Medicare days of care were at the routine home care level of care for both percent of payments made and percent…
