Federal News and Information
The Billing Hospice Physician, Nurse Practitioner (NP) and Physician Assistant (PA) Services job aid assists hospices, physicians, NPs and PAs in how to properly bill these services. It was developed in collaboration between HHH MACs CGS, NGS and Palmetto GBA. Go to: https://palmettogba.com/Palmetto/Providers.Nsf/files/Billing_Hospice_Physician_NP_PA_Services_Job_Aid.pdf/$File/Billing_Hospice_Physician_NP_PA_Services_Job_Aid.pdf.
Value-Based Insurance Design Model Hospice Benefit Component Overview
Beginning on January 1, 2021, CMS is testing the inclusion of the Part A Hospice Benefit within the Medicare Advantage (MA) benefits package through the Hospice Benefit Component of the Value-Based Insurance Design (VBID) Model. This test allows CMS to assess the impact on care delivery and quality of care, especially for palliative and hospice care, when participating MA plans are financially responsible for all Parts A and B benefits.
Currently, when an enrollee in an MA plan elects hospice, fee-for-service (FFS) Medicare becomes financially responsible for most services, while the MAO (MA Organization) retains responsibility for certain services (e.g., supplemental benefits). Under the Hospice Benefit Component of the VBID Model, participating MAOs retain responsibility for all Original Medicare services, including hospice care.
Key Policies and Requirements for CY 2022 (continued from CY 2021)
- Participating MAOs must continue to cover hospice care for enrollees who choose to elect hospice through an in-network or out-of-network hospice provider
- Participating MAOs continue to be prohibited from applying any prior authorization to hospice care related to the enrollee’s terminal condition
- Participating MAOs must continue to pay for out-of-network hospice care at 100% of Original Medicare rates, including physician services and the service intensity add-on (SIA) payments
- Participating MAOs must continue to pay for any unrelated services and/or post-hospice live discharge costs, as long as they are deemed to be appropriate and medically necessary
Billing and Claims Under the Hospice Benefit
- For questions about enrollment, billing, claims, and contracting related to enrollees of participating plans, hospice providers should contact the participating MAO
- Hospice providers must continue (as they have in CY 2021) to send all notices and claims to both the participating MAO and the relevant MAC on a timely basis
- The MAO will process payment, and the Medicare Administrative Contractor (MAC) will process the claims for informational and operational purposes and for CMS to monitor the Model
- If you contract to provide hospice services with the plan, be sure to confirm billing and processing steps before the calendar year begins, as they may be different
Hospice providers should keep in mind that a patient may travel for their hospice care so they may see a patient enrolled in one of the participating plans offering coverage not in their service area.
- Example: A patient with coverage from a participating plan whose service area is in Ohio may travel to receive hospice care from a hospice provider in Florida. The provider should submit all notices and claims to the plan in Ohio.
- The hospice continues to bill claims for informational and operational purposes to their current MAC
Reimbursement for “Unrelated Care”
- Any unrelated care associated with an enrollee’s hospice stay which is covered by a plan participating in the Hospice Benefit Component is now the financial responsibility of the participating plan
- FFS Medicare should not process any claims for unrelated care for an enrollee which is covered by a plan participating in the Hospice Benefit Component
Calculation of the Aggregate Cap and the Inpatient Cap
- All billing related to care provided to an enrollee who have coverage through a plan participating in the Hospice Benefit Component shall not be included in calculating a hospice’s progress towards the aggregate and inpatient cap
Contacting the VBID Model Team: [email protected].
New Mexico News and Information
Public Health Order – reminder
Amended Public Health Emergency Order Requiring All Schools Workers Comply with Certain Health Requirements and Requiring Congregate Care Facility Workers, Hospital Workers, an Employee of the Office of the Governor be Fully Vaccinated and Receive Booster Vaccines was released in December 2021. This continues to be effective. You can review it at:
Texas News and Information
Over the years, I have been advised that some hospice staff have held a credential for a nursing facility administrator. The below information is for those who do. This may or may not affect them.
HHSC Offers Help with TULIP for Initial NFA Applicants
HHSC is implementing a new credentialing system for nursing facility administrators in the Texas Unified Licensure Information Portal.
HHSC requests all initial applicants having issues with the application process in TULIP email the NFA Licensing Program to request help from HHSC staff to navigate through the system. This is due to limited functionality in TULIP. It will allow applicants to continue to work through the process without having to wait until the system is fully functional.
HHSC is providing a grace period of 60 days for certain renewals. All nursing facility administrator licenses active on February 11, 2022, are considered active until 60-days following full implementation of the new system. HHSC will send out a notice once the system is fully implemented. This will allow all NFAs to submit renewals and associated documents through the new credentialing system.
Refer to Provider Letter 2022-20 as documentation of the grace period: https://www.hhs.texas.gov/sites/default/files/documents/pl2022-20.pdf.
Texas Medicaid Healthcare Partnership (TMHP)
The below bulletin is especially important to new Medicaid hospice providers!
Long Term Care Provider Bulletin
The LTC Provider bulletin was released on April 29, 2022. Topics covered are:
- Preadmission Screening and Resident Review (PASRR) (all hospices regardless of payor source must comply with program requirements) PL1 form action items
- Provider information validation on claims
- NF admission of persons on preadmission PL1 forms with a negative PE.
- Enhancements to PASRR forms
- Eligibility information
- Claims identified for potential recoupment
- Handling of Medicaid overpayments
- Training – advanced certified nurse aide, learn billing and payment, hospice
- List of provider relations representatives
Health and Human Services Commission (HHSC)
Save the Date: Quality in Long-Term Care Conference
HHS, along with The University of Texas Steve Hicks School of Social Work, will host the 2022 Quality in Long-Term Care Conference in-person.
Renaissance Austin Hotel
The conference is free to attend. Online registration opens Wednesday, June 15.
This year’s theme, “Resilient, Responsive and Ready,” was selected due to Texan’s:
- Ability to recover quickly from the challenges of the pandemic.
- Responsiveness to the ever-changing ways of working in the new normal in their professions and being ready for whatever comes next.
Continuing education credit for multiple disciplines will be provided for this event.
Supportive Palliative Care (SPC) Legislative Update
As you know, hospice providers are required to seek a Licensed Home Health Category in order to provide SPC. Many of you have expressed your concern about this change and want a hospice to be able to provide SPC under the hospice category.
The SPC AdHoc Committee formed a subcommittee to address possible language and approaches to seeking legislative changes during the 2023 Texas Legislative Session. While associations can visit senators and representatives are your behalf, we need you to reach out to those that represent you! They need to hear why you feel you are the most appropriate group to provide this care, why you should be allowed to provide SPC. If you don’t know who represents you, go to this link: https://wrm.capitol.texas.gov/home.
Disclaimer: The Texas and New Mexico Hospice Organization publishes the Regulatory Update as an information only item. TNMHO has no attorneys nor does it represent the state and federal governments. All legal questions or concerns should be directed to your attorney or the governments involved.