Clarified CMS Rules Mean It’s Time to Review Coding
Posted On: August 27th, 2013
Regulatory Advisor, McKesson
With the Hospice FY2014 Payment and Wage Index Final Rule issued August 6, 2013 by CMS, now is the perfect time to review hospice billing and coding practices. The more your agency understands the current requirements and what data should be included (or not) in the medical record, the better prepared you’ll be to move forward with clinical documentation improvement processes.
The FY 2014 hospice payment rates and wage index will increase rates by a net of 1% and take effect Oct. 1, 2013. A market basket increase of 2.5% is offset by an 0.8% mandated decrease and a 0.7% decrease due to the continued phase-out of the budget neutrality adjustment factor to arrive at the 1% index hike. CMS has indicated that it will issue a Change Request with the finalized FY2014 payment rates, the final FY2014 wage index, the FY2014 PRICER, and the hospice cap amount for the year ending October 31, 2013 in the near future.
When issuing the final rule, CMS also revealed plans to reject claims that contain either Debility or Adult Failure to Thrive (AFTT) when listed as the principal diagnosis in billing codes. CMS will delay the rejection of claims until Oct. 1, 2014. CMS expects hospices to resubmit the claims with a more appropriate principal diagnosis.
Hospices also face a 2% reduction to their market basket update in FY2014 for failing to meet the reporting deadlines of January 1, 2013 for the structural measures and April 1, 2013 for the pain measure. The final rule confirms removal of the structure measure requirement and the NQF #0209 pain measure beyond data submission for the FY2015 payment determination.
CMS has finalized the Hospice Item Set (HIS), which is a standardized, patient-level data collection vehicle, not an assessment tool. This new documentation will be completed at admission and discharge for all hospice patients, regardless of payer, effective with admissions on or after July 1, 2014. The HIS contains seven proposed quality measures. This data is required to be submitted to CMS, and failure to do so will affect payment determination in FY 2016.
Finally, CMS finalized a Hospice Experience of Care Survey for informal caregivers of hospice patients. It is expected to begin in 2015. Participation in the survey will be a quality reporting requirement that affects hospice payments in FY2017.