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NAHC Summary of Hospice FY2022 Payment Rule, Quality Changes and HH HQRP Proposal

Beth Noyce

Are you ready for some changes in the hospice quality reporting program? Ready or not, the FY 2022 Hospice Proposed Rule addresses just that, along with a lot of other stuff that's important for hospice providers. There's even something in it for home health. And CMS is seeking your comment for myriad topics. Now is the time to be heard. Attached is the summary of the proposed rule by the National Association of Home Health and Hospice (NAHC). Please take the time to comment by June 7, 2021. Remember, you are the expert as a hospice provider. CMS needs your input. Click...


V3 of the HIS Manual

Beth Noyce

You may be wondering, like so many others, when V3.00 of the HIS manual and new discharge HIS become final. And once section O's removal from the discharge HIS is final and the publicly reported Hospice Visits when Death is Imminent (HVWDII) measure pair is replaced by the claims-based Hospice Visits in the Last Days of Life (HVLDL), do hospice agencies still have to file the discharge HIS? Furthermore, what's the status of the Hospice Outcomes and Patient Evaluation (HOPE) and the new, future Hospice Care Index (HCI) you may (or may not) have heard about? I must admit, I was having a...


OIG Adds 2 Home Health Items to Work Plan

Beth Noyce

The office of Inspector General is looking into how home health deals with pandemic issues. I wanted you to know about this. The Office of Inspector General (OIG) has announced two new items of interest to NAHC home health members. One is an audit of home health telehealth services during the COVID-19 public health emergency (PHE) and the second is a report on the challenges faced by home health agencies in responding to the PHE and the strategies used to respond. Audit of Home Health Services Provided as Telehealth During the COVID-19 Public Health Emergency The declaration of a public...


CMS Finalizes Definition of “Reasonable and Necessary”

Beth Noyce

The phrase "reasonable and necessary" has long been embedded in coverage descriptions in the Medicare Benefit Policy Manual and the Medicare Program Integrity Manual as guidance for providers. But it  wasn't codified as law until January 14 when the Federal Register posted the final rule Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of ‘‘Reasonable and Necessary.’’  NAHC unpacks this in the article below. CMS Finalizes Definition of “Reasonable and Necessary” A definition of “reasonable and necessary” is part of the recently finalized rule,  Medicare Program; Medicare Coverage of Innovative Technology (MCIT) and Definition of ‘‘Reasonable and Necessary’’.   As previously reported this rule...


New Court Decision on Recoupments Before ALJ Hearings

Beth Noyce

Awaiting a hearing before an Administrative Law Judge just got potentially much more expensive. "Now . . . providers have a much tougher “roe to hoe” in order to stop recoupments before ALJ hearings," says Elizabeth E. Hogue, Esq.  in her article below.  The Court reversed its previous decision in Adams EMS, Inc. v. Azar [No. H-18-1443 (S.D. Tex. July 11, 2018)] and decided that Adams EMS was not entitled to a hearing before an ALJ before recoupment of an overpayment by the Centers for Medicare and Medicaid Services (CMS) Adams EMS, Inc. v. Azar [Civil Action No. H-18-1443, United States District Court, S.D. Texas,...