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CMS Issues Hospice Proposed Rule for FY 2017

OASIS Answers - Friday, April 22, 2016

On April 21, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule (CMS-1652-P) that would update fiscal year (FY) 2017 Medicare payment rates and the wage index for hospices serving Medicare beneficiaries.

Proposed Rule Highlights

Highlights of this proposed rule include the following:

  • Payments - Hospices would receive a 2.0% increase in their payments for FY 2017.

  • Hospice CAP - For accounting years that end after September 30, 2016 and before October 1, 2025, the hospice cap is updated by the hospice update percentage rather than using the consumer price index for urban consumers (CPI-U). The hospice cap amount for the 2017 cap year will be $28,377.17, which is equal to the 2016 cap amount ($27,820.75) updated by the FY 2017 hospice payment update percentage of 2.0 percent.

  • Data Analysis Updates - Updated trends are provided including diagnosis reporting, pre-hospice spending, non-hospice spending, and live discharges.

  • Hospice CAHPS® - The Hospice CAHPS (Consumer Assessment of Healthcare Providers and Systems) Survey is a component of the Hospice Quality Reporting Program (QRP) required under the Affordable Care Act. The proposed rule outlines participation requirements for the FY 2017 and FY 2020 annual payment updates. For the FY 2019 Annual Payment Update (APU), hospices must collect survey data on an ongoing basis from January through December of calendar year (CY) 2017. For the FY 2020 APU, hospices must collect survey data on an ongoing basis from January through December of CY 2018. The proposed rule also includes survey data submission deadlines for the FY 2018, FY 2019, and FY 2020 APU periods.

  • 2 NEW Hospice Quality Measures - The Hospice QRP is proposing two new quality measures for FY 2017. The first, Hospice Visits When Death is Imminent, is a measure that will assess hospice staff visits to patients and caregivers in the last week of life. The second, Hospice and Palliative Care Composite Process Measure, will assess the percentage of hospice patients who received care processes consistent with guidelines. This measure will be based on select measures from the seven that are currently being submitted under the Hospice QRP (Pain Screening, Pain Assessment, Dyspnea Treatment, Patients Treated with an Opioid who are given a Bowel Regimen, and Treatment Preferences & Beliefs/Values Addressed if desired by patient).

  • Enhanced Data Collection - CMS is considering enhancing the current Hospice Item Set (HIS) data collection instrument to be more in line with other post-acute Care settings. This revised data collection instrument would be a comprehensive patient assessment instrument, rather than the current chart abstraction tool.

  • Public Reporting - CMS expects to begin public reporting via a Compare Site in CY 2017. In addition, CMS expects to post hospice demographic data on a public use file at in late spring/early summer 2016.

Links to the FY 2017 Hospice Rule

The proposed rule is available at: will be available on 4/28/16 at:

Public Comment on the Proposed Rule

Public comments on the proposal will be accepted until June 20, 2016. Instructions on submitting comments are included at the beginning of the proposed rule. 

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ICD-10 is Old News, Right? WRONG!

OASIS Answers - Thursday, March 17, 2016

Just like any other time a new data system has been implemented, there are hurdles that weren't envisioned prior to the "go live" date. Such is the case with ICD-10.

Last year's educational programs based on guidelines instructed that home health would never use a 7th character for initial episodes of care. We found out that wasn't necessarily true in those cases where we were continuing active treatment established by the referring provider. Even CMS hadn't envisioned this reality and quickly worked to resolve the problem that this created in the Home Health Grouper Software.

Coding guidelines also stated that if we were providing care for a patient who had a heart attack more than 4 weeks ago, that we were to use an aftercare code. However there is no code that says, "Aftercare following a heart attack." What are we supposed to do?

And the ultimate rude awakening is on the horizon for agencies planning to bypass the time & expense of coding training and just use General Equivalence Mappings (GEMs) to simply convert the ICD-9 codes that they were familiar with to the more foreign ICD-10 codes. There are many more codes in ICD-10-CM (70,000 versus 17,000) and some have no counterparts in ICD-9-CM. That math does not work. These are not exact crosswalks. In most cases they do not provide a precise match, but instead offer one accurate translation from many plausible options. As an example, one ICD-9 code may have 47 different possible ICD-10 translations. That means there is only 1 exact match and 46 near misses. Furthermore, the details necessary to identify which ICD-10 code should be selected will come from the patient assessment. If your staff don't understand, assess, and document all the relevant assessment details necessary to identify the appropriate, more-specific ICD-10 code, even the best outsourced coding service will result in inaccurate coding, limited by the clinical information provided by your assessing clinicians.

Annual coding training has always been the recommended way to ensure that your staff are educated and competent to perform necessary assessment and documentation functions, and assign accurate diagnostic codes. Coding errors can be costly, and assuming that a third-party coder will eliminate the need for in-house expertise is risky. Strengthen your accuracy and minimize your risk by investing in updated coding training and arm your staff with authoritative instruction related to this complex skill set. Join us at an upcoming session of The Art of ICD-10 Coding for Home Health!

Sparkle Sparks, PT MPT COS-C
Senior Associate Consultant
OASIS Answers, Inc.

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Home Health Compare and Star Ratings Calendar for 2016 Posted

OASIS Answers - Sunday, January 17, 2016

The Centers for Medicare & Medicaid Services (CMS) has posted the 2016 calendar for Home Health Compare updates.  The calendar also includes the dates for the Quality of Patient Care Star Ratings Preview Reports which are posted in individual home health agency CASPER folders approximately 3 months before this data is updated on the Home Health Compare website. 

In addition to the Quality of Patient Care Star Ratings, the new Patient Survey Star Ratings, derived from the HHCAHPS (Home Health Consumer Assessment of Healthcare Systems and Providers) Surveys will first be publicly available with the January 2016 update of Home Heath Compare.  The new Patient Survey Star Ratings will be updated quarterly with each update of Home Health Compare.

To receive updates from CMS related to updates on Home Health Compare, home health agencies can sign up for the Home Health Open Door Forum listserv.  This listserv provides email updates on the Home Health, Hospice, and DME Open Door Forum as well as additional home health quality updates.  The listserv signup is available at:

2016 Home Health Compare Calendar

 * Home health agencies should follow the directions in the Quality of Patient Care Star Ratings Preview Reports to submit a suppression request.  

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