Compliance Monitor (6/25/2024)

Compliance Monitor (6/25/2024)

CHAP is always seeking resources and insights to enhance the knowledge of partners and customers. 

Be sure to download CHAP’s Compliance calendars for home health and hospice. 

Hospice Updates

CMS Revises Hospice Certifying Physician Enrollment Requirement Implementation Guidance 
In response to concerns raised by NHPCO and NAHC, CMS retracted its guidance indicating that any individual who elects to receive hospice services in a subsequent hospice election would need to be certified as if entering hospice in the initial benefit period. As NHPCO has noted, this guidance, published in a Hospice Certifying Enrollment Questions and Answers (Q & A) Document, contradicted Section 1814(a)(7) of the Social Security Act (SSA) and regulations at 42 C.F.R. § 418.22(c)(2). The SSA and regulations indicate that the attending physician must only certify a patient’s terminal illness for the initial hospice Medicare benefit period; and that only one physician, not both the attending and hospice physician, must provide this certification for subsequent benefit periods. View the updated Q&A Document

To support their members’ efforts to navigate through remaining inconsistencies in certifying physician enrollment regulatory guidance, NHPCO and NAHC developed a Physician Enrollment Requirement FAQ and Guidance tool

Home Health Updates 

Final April 2024 Interim Performance Reports (IPRs) Now Available 

Please note: IPRs are only available to HHAs through iQIES. IPRs are not available to the public. 

The Final April 2024 IPRs are now available on iQIES, in the “HHA Provider Preview Reports” folder, by the CMS Certification Number (CCN) assigned to the HHA. Only iQIES users authorized to view an HHA’s reports can access the expanded HHVBP Model reports. If a provider has more than one (1) CCN, a report will be available for each CCN. The Final IPR reflects any changes resulting from an approved recalculation request.  As a reminder, the Final IPR overrides the Preliminary IPR once the Final IPR is published. 

Please note: Due to recent data system changes and updates in processing of HHVBP claims-based measures, CMS has made revisions to these measures. The revised measure scores are published in this report version (i.e., the Final April 2024 IPR). Please review your HHA’s IPR and direct any questions to the HHVBP Model Help Desk at HHVBPquestions@cms.hhs.gov

If an HHA needs to register a user or experiences trouble locating or downloading reports, please contact the QIES/iQIES Service Center at (800) 339-9313 or by email at iqies@cms.hhs.gov. Or to create a new ticket online, track an existing ticket, or recover your HARP password account, please use the CCSQ Support Central: Self-Service Portal. 

Please note: IPRs are only available to HHAs through iQIES. IPRs are not available to the public. 

For questions, please email the Expanded HHVBP Model Help Desk at HHVBPquestions@cms.hhs.gov

For questions, please email the Expanded HHVBP Model Help Desk at HHVBPquestions@cms.hhs.gov

DME Updates 

Medicare Benefit Policy Manual Update: DMEPOS Benefit Category Determinations 

CMS added DMEPOS items and their national benefit category determinations (PDF)

All Provider Updates 

Medical Records Request Scam: Watch out for Phishing  

CMS identified phishing scams for medical records. This may include scammers faxing you fraudulent medical records requests to get you to send patient records in response; see example (PDF)

When you review any requests, look for signs of a scam, including: 

  • Directing you to send records to an unfamiliar fax number or address 
  • Referencing Medicare.gov or @Medicare (.gov) 
  • Indicating they need records to “update insurance accordingly”  

A scam request may include: 

  • Poor grammar, misspellings, or strange wording 
  • Incorrect phone numbers 
  • Skewed or outdated logos 
  • Graphics that are cut and pasted 

If you think you got a fraudulent or questionable request, work with your Medical Review Contractor to confirm if it’s real. Submit medical documentation through the Electronic Submission of Medical Documentation (esMD) system or CMS medical review contractor secure internet portals, when available.  

Provider & Supplier Enrollment Site Visits: CMS has Authority to Conduct  

CMS conducts authorized enrollment site visits to verify operational status. Site visit inspectors carry a photo ID and CMS-issued letter of authorization that you may review but not retain or copy.  

Enrollment site visits are conducted by our 2 Site Verification Services Contractors: 

  • East: Palmetto GBA and its subcontractors: 
    • Overland Solutions, Inc., an affiliate of EXL 
    • Information Discovery Services 
    • Compliance Review, Inc. 
    • National Creditors Connection, Inc. 
  • West: Deloitte Consulting, LLP and its subcontractors: 
    • Nationwide Management Services, Inc. 
    • CSI Companies, Inc. 
    • Arthur Lawrence Management, LLC 
    • Computer Evidence Specialists, LLC  

More Information: