Even though CMS implemented face-to-face documentation requirement changes for episodes beginning Jan. 1 or later, the federal Medicare agency is still considering delaying those changes.
 
During a home health, hospice and durable medical equipment (DME) open door forum Jan. 14, the federal Medicare agency said it has received many letters and emails asking CMS to delay the revamped policies.
 
A number of people within the home health industry expressed concern about agencies’ and doctors’ preparedness for the changes, said Randy Throndset, CMS’ division director for home health, hospice and Healthcare Common Procedure Coding System (HCPCS).
 
Although CMS removed the face-to-face narrative requirement, which pleased many agencies, it also made clear that it expects to see documentation within a patient’s medical record verifying why the patient is eligible for home health services.
 
During a December forum, CMS delivered several examples of documentation it deems sufficient to justify homebound status and the need for skilled care. The problem, agencies and industry experts told HHL following the forum, is that few doctors include that detail within documentation (HHL 1/12/15).
 
CMS is reviewing the industry’s concerns “carefully” and expects “to provide an answer in the near future,” Throndset said during the Jan. 14 forum.
 
ICD-10 testing update
 
During the call, CMS also reported that 850 end-to-end ICD-10 testers for January were selected, while the deadline to participate in the April testing period was extended to Jan. 21.
 
CMS said it is looking in particular for more DME providers to participate in April and July testing periods.
 
About 2,250 participants, including providers and vendors, will be allowed to volunteer for the ICD-10 end-to-end testing to make sure they can successfully submit claims containing ICD-10 codes, that CMS software changes to support ICD-10 are appropriately adjudicated and that accurate remittance advice is produced, CMS said during the call.
 
CMS says it will release data from the three end-to-end testing periods — Jan. 26-30, April 27-May 1 and July 20-24 — shortly after the periods end.
Each Medicare administrative contractor (MAC) will select 50 submitters for each MAC jurisdiction to participate. Once selected, submitters will turn in 50 claims and also can submit 50 additional claims in future testing periods, CMS says.
 
Agencies and hospices should contact their MAC to apply.
 
Hospice reports
 
Also during the forum, CMS contractor Abt Associates, Cambridge, Mass., discussed comprehensive technical reports it released in April 2013 and May 2014, to help with hospice reform.
 
Abt’s 2013 report looked into geographic variation in hospice utilization and payment; analyzed GIP utilization among hospice beneficiaries; analyzed hospice cost reports from 2004 through 2011 and analyzed the impact the impact of the face-to-face requirement. It also looked into trends in live discharge; analyzed Part D utilization; examined a tiered payment model and looked into rebasing the rural health clinic rate for hospice.
 
Abt’s 2014 report, meanwhile, included several topics including analyses of total Medicare expenditures and beneficiary cost sharing for hospice beneficiaries; concentration of nursing facility usage among hospices; and the impact of hospice utilization on end of life care costs.
 
Related links: View Abt’s reports at http://go.cms.gov/14Xzles and http://go.cms.gov/1IL5t1j. View ICD-10 details from CMS at http://go.cms.gov/1bgZi7Q.