Compliance Monitor (9/4/2024)

CMS is Taking Action to Address Benefit Integrity Issues Related to Hospice Care 

Effective oversight and enforcement are important to protect the integrity of the Medicare program, especially for vulnerable, seriously ill individuals and their families. The Centers for Medicare & Medicaid Services (CMS) has an important role to play in ensuring that hospices are providing necessary and critical, high-quality care to our Medicare beneficiaries at the end of life. 

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The August 2024 quarterly refresh for the Hospice Quality Reporting Program is now available on Care Compare. 

For additional information, please see the FY2025 Hospice Wage Index Final Rule at https://www.cms.gov/Center/Provider-Type/Hospice-Center. Please visit the Hospice Background and Announcements webpage to review the Claims-Based Measures Questions and Answers downloadable (PDF) for more information on the HCI and HVLDL 

Providers can now access the latest Provider Preview Reports via the Certification and Survey Provider Enhanced Reports (CASPER) application. Once released in CASPER, providers will have 30 days during which to review their quality measure results.  Although the actual “preview period” is 30 days, the reports will continue to be available for another 30 days, or a total of 60 days. The preview period for the latest Provider Preview Report lasts from August 21, 2024 to September 21, 2024. CMS encourages providers to download and save their Hospice Provider Preview Reports for future reference, as they will no longer be available in CASPER after this 60-day period.   

Learn more about the Provider Preview Report (HIS and Claims-based measures)  here and about the CAHPS Preview Report here. Hospice QRP Key Dates for Providers can be found here. The 3^rd Edition HQRP Public Reporting Tip Sheet is available here 

The Centers for Medicare & Medicaid Services (CMS) is offering an updated series of web-based training courses that provide an overview of the assessment and Section GG guidance found in the OASIS E-1 to promote accurate coding of the post-acute care (PAC) cross-setting data elements. 

This resource can be accessed through the Home Health Quality Reporting Training page. 

See the instruction to your Medicare Administrative Contractor (PDF) to learn about CY 2025 changes to HCPCS codes used for home health consolidated billing. CMS updated the non-routine supply code list to: 

• Add 71 new codes 

• Update the description for 3 codes from the previous list 

Get the October 2024 release (Version 05.1.24 (ZIP)). See Home Health Prospective Payment System Grouper Software for a summary of changes. 

More Information: 

• Section 80 Claims Processing Manual, Chapter 10 (PDF) 

• Instruction to your Medicare Administrative Contractor (PDF) 

The Centers for Medicare & Medicaid Services (CMS) is offering an updated series of web-based training courses that provide an overview of the assessment and guidance to promote accurate coding of the post-acute care (PAC) cross-setting Section GG data elements. Each course contains interactive exercises to test your understanding. To access the courses, click on the links below: 

• Course 1: Section GG Data Accuracy and Quality Measures. 

• Course 2: Prior Functioning and Prior Device Use Items. 

• Course 3: Accurate Coding for GG0130 and GG0170 Items. 

• Course 4: Understanding Admission and Discharge Performance for GG0130: Self-Care Items. 

• Course 5: Understanding Admission and Discharge Performance for GG0170: Mobility Items. 

The Preview CY 2024 Annual Performance Reports (CY 2024 APRs) for the expanded HHVBP Model have been published on the Internet Quality Improvement and Evaluation System (iQIES). 

The CY 2024 APRs provide the HHA’s Annual Payment Percentage (APP) based on performance in CY 2023, the performance year, which will be applied to Medicare Fee-for-Service (FFS) claims with through dates in the payment year, CY 2025. In addition, the CY 2024 APRs provide information related to HHA performance on key metrics that feed into the HHA’s APP, including performance measure scores, Improvement Points, Achievement Points, Care Points, and the Total Performance Score (TPS). 

An HHA receives a CY 2024 APR if the HHA: 

• Was Medicare-certified prior to January 1, 2022, and 

• Had sufficient data for at least five quality measures to calculate a TPS and APP. 

Below is a list of the calendar years that are relevant to the “CY 2024 APR”, namely the baseline year, performance year, publication year, and payment year. 

• The baseline year is CY 2022 and is used to calculate quality measure-specific achievement thresholds, benchmarks, and improvement thresholds. 

• CY 2023 is the performance year, and HHA performance in this calendar year is measured against 12 quality measures relative to performance of HHAs in each cohort. 

• The publication year of the “CY 2024 APR” is CY 2024. 

• CY 2025, which is the payment year. That means that the HHA’s APP ranging from minus 5% to plus 5% is applied to Medicare Fee-for-Service (FFS) claims with through dates in CY 2025. 

Locating the APR in iQIES 

1. Log into iQIES at https://iqies.cms.gov/. 

2. Select the My Reports option from the Reports menu. 

3. From the My Reports page, select the HHA Provider Preview Reports. 

4. Select the HHVBP file to view the desired report. To quickly locate the most recently published report, select the down arrow adjacent to the Created Date label at the top of the table. This will order the reports in the folder from newest to oldest. 

5. Select the file name link and the contents of the file will display. 

1. Once the “Preview APRs” are published, HHAs have 15 calendar days to submit a recalculation request if they find evidence of an error in their report. 

• The deadline for submitting a recalculation request for the CY 2024 APRs is September 7, 2024. Please note, recalculation requests do not apply to errors in data submission since submission requirements for the expanded Model align with current Code of Federal Regulations (CFRs). 

2. Once the “Preliminary APRs” are published on September 27, 2024, HHAs have 15 calendar days to submit a reconsideration request if they submitted a recalculation request and are not in agreement with the recalculation request decision. 

• The deadline for submitting a reconsideration request for the CY 2024 APRs is October 12, 2024. 

• HHAs also have 7 calendar days to submit a request for administrator review if they submitted a reconsideration request and are not in agreement with the reconsideration request decision. 

• The deadline for submitting a request for Administrator review for the CY 2024 APRs is November 1, 2024. 

3. CMS makes the “Final APRs” available after all recalculation requests, reconsideration requests, and requests for Administrator review are processed, and no later than 30 calendar days before the payment adjustment takes effect on January 1, 2025. 

HHAs may submit requests for recalculation by emailing hhvbp_recalculation_requests@abtassoc.com. Recalculation requests must contain the following information, as cited in the CY 2022 HH PPS final rule (p. 62331) and CFR §484.375:  

• The provider’s name, address associated with the services delivered, and CCN. 

• The basis for requesting recalculation, to include the specific data that the HHA believes is inaccurate or the calculation the HHA believes is incorrect. 

• Contact information for a person at the HHA with whom CMS or its agent can communicate about this request, including name, email address, telephone number, and mailing address (must include physical address, not just a post office box). 

• A copy of any supporting documentation, not containing PHI, the HHA wishes to submit in electronic form. 

These instructions are also available on the Expanded HHVBP Model webpage, under “Model Reports.” 

Get payment allowances and effective dates for the 2024–2025 season. 

More Information: 

• Flu Shot webpage: frequency, coverage, billing, codes, and resources 

• Instruction to your Medicare Administrative Contractor (PDF) 

The CMS Office of Minority Health has updated the CMS Disparities Impact Statement, a quality improvement tool that can be used to improve population health.  

Click here to download the most recent version. 

The CMS Disparities Impact Statement is a tool that can be used by health care stakeholders to promote efforts to eliminate health disparities while improving the health of people from all populations that experience disparities, including people from racial and ethnic minorities; people with disabilities; members of the lesbian, gay, bisexual, and transgender communities; sexual and gender minorities, individuals with limited English proficiency; and rural, tribal, and geographically isolated communities. 

CMS completed this update as part of our regular cycle of review of available resources in order to provide the most up to date information available.  This newer version is clearer about the purpose for the resource and offers more examples of potential use. Organizations looking to reduce health disparities and further their health equity improvement goals can review and use this tool to further their planned work.  

While organizations and individuals may consider a variety of factors in using this tool such as health status, health needs, health-related social needs, income, geographic location, and other social determinants of health, organizations must ensure any interventions are available to individuals without regard to a person’s race, ethnicity, color, national origin, sex, age, or disability.