A Deep Dive into the Medicare 2015 Final Payment Rule for Hospice
Posted On: July 9th, 2015
Regulatory Product Manager, McKesson
During a recent round table discussion that we facilitated with our customers, three managers from BlackTree Healthcare Consulting discussed six highlights of the Centers for Medicare & Medicaid Services’ 2015 Final Rule for hospice:
- Increase of 2.1% in market basket
- Notice of Elections (NOEs) must be filed within five days of election
- Notice of Termination/Revocation (NOTRs) must be filed within five days of discharge/revocation
- Election statement to include attending physician identifying information
- Self-reporting of the aggregate cap
- Claims containing inappropriate principal or secondary diagnosis codes, including “debility” or “adult failure to thrive” as the primary diagnosis, will be returned for correction
Our hospice software customers expressed great concern over the NOE deadline, which they saw as a major constraint, especially since hospices are ineligible for payment on services prior to the day the NOE is received. BlackTree pointed out that the deadline in the proposed rule was three days, so five days is certainly an improvement.
Nevertheless, several customers noted that the change greatly affected their operations, forcing them to generate and submit NOEs daily and even twice daily and to have serious concerns about Friday night admissions.
The NOTR rule change appeared to be less worrisome, in part because there are no consequences for late filing at this time. Similarly, attendees aren’t finding the inclusion of attending physician identifying information on the election statement overly burdensome, although there were some instances of difficulty obtaining a physician’s National Provider Identifier.
Customers expressed relief that the final rule does not require hospices to calculate their inpatient caps (as did the proposed rule), although it does require them to calculate and file their aggregate cap determinations within five months of the close of the cap year, along with any overpayment due.
Their reactions to the inclusion of “debility” and “adult failure to thrive” as diagnoses that must be corrected seemed to vary according to the participant’s current coding practices. However, many agreed that additional coding and clinician education is in order to mitigate the effect of this rule and prepare for the ICD-10 transition.
Some customers are now turning their attention to the 2016 Proposed Rule, which was released on April 30, 2015, and is expected to be finalized this summer.
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