Hospice potential penalization for failure to comply with updated reporting requirements

Hospice agencies have updated requirements for 2015 and it is imperative that your billing staff is made aware of these changes and the potential revenue loss for your agency, relating to Medicare beneficiaries, if updated requirements aren’t met. The Centers for Medicare and Medicaid Services (CMS) has released an education article to help your hospice agency.

“Depending on the amount of the annual update for a particular year, a reduction of 2 percentage points could result in the annual market basket update being less than 0.0 percent for a FY and may result in payment rates that are less than payment rates for the preceding FY. Any reduction based on failure to comply with the reporting requirements, as required by section 1814(i)(5)(B) of the Act, would apply only for the particular FY involved. Any such reduction would not be cumulative or be taken into account in computing the payment amount for subsequent FYs.
Section 1814(i)(5)(C) of the Act requires that each hospice submit data to the Secretary on quality measures specified by the Secretary. The data must be submitted in a form, manner, and at a time specified by the Secretary.
MACs will inform hospices whether they were identified as not complying with the hospice quality reporting requirements, as well the process to dispute their payment reduction if they disagree with the determination.
Notes:
• If a hospice is non-compliant with regard to Hospice Quality Reporting, MACs will send those hospices an initial notification letter no later than 10 business days from the receipt of information from CMS that provides the list of hospices potentially subject to reductions. The notification letter will also inform the hospice regarding the process to dispute their payment reduction if they disagree with the determination. The reconsideration process will be outlined in this initial notification letter.
• A hospice may request a reconsideration of the finding that they did not comply with the reporting requirements. In these cases, MACs will also send dispute resolution letters to those hospices notifying them of the reconsideration decision of CMS (upheld or reversed) within 10 days of CMS’ notification to the MAC of the final decision. This second letter only goes to those hospices requesting a reconsideration.”

Excert from MLN Matters®Number: MM9091

You can download the full document at http://www.palmettogba.com/palmetto/providers.nsf/ls/Jurisdiction%2011%20Home%20Health%20and%20Hospice~9UHHLW6580?opendocument&utm_source=J11HHHL&utm_campaign=J11HHHLs&utm_medium=email.

You will find the official instruction, CR9091, issued to your MAC regarding this change, is available at http://www.cms.gov/Regulations-and-Guidance/Guidance/Transmittals/Downloads/R39QRI.pdf on the CMS website.

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