Open Door Forum Provides Critical Home Health & Hospice Updates

WASHINGTON, D.C. (November 13, 2019)—On Nov.6, 2019 the Centers for Medicare & Medicaid Services (CMS) held an Open Door Forum (ODF) for home health, hospice and durable medical equipment (DME) providers. During the ODF, CMS provided the following updates for home health and hospice. Key topics include Review Choice Demonstration, PDGM billing, Transition to IQUIES, the CY2020 Home Health Final Rule, quality reporting for both home health and hospice, and more.

HOME HEALTH

REVIEW CHOICE DEMONSTRATION

As previously reported, the implementation of the Review Choice Demonstration (RCD) in Texas, North Carolina and Florida has been delayed to allow home health agencies to transition to PDGM which goes into effect on Jan. 1, 2020. The RCD was originally scheduled to begin in Texas in December 2019 and has been delayed to March 2, 2020. The demonstration is expected to begin in North Carolina and Florida in May 2020.

TRANSITION TO IQIES

The Quality Improvement and Evaluation System (QIES), which providers and vendors use to submit assessment data, is being upgraded to make the system more reliable, scalable, secure and accessible. The enhancements will occur in phases (by provider type) and began with Long- Term Care Hospitals (LTCHs) in March 2019, followed by Inpatient Rehabilitation Facilities (IRFs) in October 2019 and Home Health Agencies (HHAs) in January 2020. The enhanced system is referred to as the Internet Quality Improvement and Evaluation System (iQIES).

The rollout of iQIES will not require providers or vendors to change current processes related to submission of data. However, iQIES will require a new user management system because virtual private network (VPN) and CMSNet are no longer needed to access this system. All users will have to create an account and establish credentials in the Healthcare Quality Information System (HCQIS) Access, Roles and Profile system (HARP). HARP is a secure identity management portal that the Centers for Medicare & Medicaid Services (CMS) provides.

For instructions on obtaining access to iQIES, descriptions of the iQIES roles applicable to HHAs and important iQIES information, click here.

Please note that failure of home health agencies to obtain access to iQIES prior to Dec. 23, 2019, will impact your ability to submit assessment data needed for payment purposes, as the system will have a scheduled downtime so that the data migration can occur in preparation for the Jan.1, 2020 release. Claims that cannot be matched to assessments will be returned to the HHA, preventing Medicare payment.

CY2020 HOME HEALTH FINAL RULE

CMS provided a summary of the final rule. Immediately following the ODF, the National Association for Home Care & Hospice (NAHC) held a webinar explaining details of the final rule and has also published a summary article. A summary of the webinar is found here, and a link may be found here for NAHC members.

HOME HEALTH QUALITY REPORTING PROGRAM

There will be a Home Health CAHPS vendor training session on Friday, Jan. 31, 2020 from Noon – 2 PM Eastern. Vendors are required to participate in this training. Home health agencies may participate if they’d like. Agencies and vendors can mark their calendars for this training, but registration will not open until December 2019. Stay tuned to NAHC Report and the Home Health CAHPS webpage for further notifications.

CMS has completed the process of notifying home health agencies not compliant with the home health quality reporting program requirements. Notifications were placed in home health agency’s CASPER folders and the home health agency’s Medicare Administrative Contractor (MAC) also provided notification. Agencies not compliant with the requirements are subject to the 2% annual payment update penalty for CY2020.

HH PDGM BILLING UPDATE

CMS released a Change Request (CR) on Friday, Nov. 8, 2019, that addresses episodes where there are no visits made in the first 30-day payment period. Home health agencies have been awaiting further information about these situations and will have further guidance soon.

Throughout October CMS has been doing testing in preparation for PDGM.  End-to-end testing will begin shortly, and testing will continue through Jan. 1, 2020, when PDGM is implemented.

HOSPICE

HOSPICE QUALITY REPORTING PROGRAM

CMS reminded hospices of the quality reporting program requirements

• 90% of all HIS records must be submitted and accepted within the 30-day submission timeline.
• CAHPS Hospice Survey data must be submitted and accepted by the hospice’s survey vendor before each quarter’s deadline, and the hospice must supply its vendor with monthly survey data.

Hospices not meeting these requirements receive a 2% annual payment update penalty. A list of all hospices meeting the requirements can be found here.  Any hospices not on this list is subject to the 2% penalty.

Hospices that did not serve 50 CAHPS Hospice Survey-eligible patients in calendar year 2018 can apply for a size exemption. The deadline to apply for the exemption is Dec.31, 2019, and the exemption is for the FY2021 annual payment update. More information can be found here.  Hospices are responsible for verifying that their vendor has submitted survey data on their behalf and it has been accepted by CMS. This can be verified through the CAHPS Hospice Survey Data Warehouse.

Jan. 1, 2020 marks the beginning of a new calendar year of data for both the HIS and the CAHPS Hospice Survey. Data collection in this year impacts the FY2022 annual payment update.

There is a new technical assistance email address for the CAHPS Hospice Survey.  It is [email protected]  Please  take note of this new address for assistance.

—Via NAHC, edited for clarity and style