Courtesy of the National Association for Home Care & Hospice (NAHC)

During the Centers for Medicare & Medicaid Services (CMS) recent Home Health, Hospice, and DME (Durable Medicare Equipment) Open Door Forum (ODF) held on Thursday, February 24, the following information and updates were provided for Medicare-certified home health agencies.

Home Health Claims Processing Issues

Notice of Admission (NOA)

CMS officials reported on a claims processing issue where the NOA is returning to providers in error with reason code U357F. The Medicare claim processing system is not recognizing previous discharges from the home health agency. A system fix is planned for Monday, February 28, 2022. Providers will be eligible for an exemption to the timely NOA penalty related to erroneous rejections related to reason code U357F.

Lines 0023 and First Visit Date Match

CMS reported that it turned off an edit which ensures claims for subsequent periods report on the 0023 revenue code line the date of the first visit provided during the period. The edit was inactivated in 2021 to accommodate the no-pay Request for Anticipated Payment (RAP) policy. However, CMS instructed providers to ensure all subsequent periods in 2022 have a date match for revenue code line 0023 and the first visit date. CMS will reinstate the edit beginning on January 1, 2023, to enforce the CMS’ long-standing policy that the date on the 0023 line matches the first visit date.

Home Health Grouper

The April 2022 release of the Home Health Prospective Payment System Grouper software (v03.2.22) is now available in the “Downloads” section of the Grouper webpage.

Web-Based Pricer

CMS also announced the release of a new Web Pricer for home health and hospice providers. The web-based application will allow users to work with the Web Pricer without having to download it and will include automatic updates. CMS expects the Web Pricer to be available within the next two weeks. Providers should check the Web Pricer webpage for updates.

Home Health Quality Reporting Program (HHQRP)

Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) 

An HHCHAPS survey training webcast was conducted in January. A recording of the presentation is available through the CMS contractor for the HHCAHPS, RTI, at HHCAHPS@RTI.org.

CMS reminded providers that all Medicare-certified home health agencies seeking an exemption from participating in the HHCAHPS Survey for the CY 2023 APU to submit a Participation Exemption Request (PER) Form on the HHCAHPS website. The deadline for submitting the CY 2023 annual payment update exemption request is 11:59 PM ET on Thursday, March 31, 2022.

The next filing deadline for HHCAHPS surveys is April 30, 2022. CMS reminded providers of their responsibility to ensure the vendor has submitted all the required data by the deadline.

CMS also instructed participants to contact RTI whenever they change their HHCAHPS vendor. RTI can be contacted via email at HHCAHPS@RTI.org, or by phone at (866) 354-0985. RTI is the CMS contractor for the HHCAHPS and can be contacted with any questions or technical issues related to the HHCAHPS.

Outcome and Assessment Information Set (OASIS)

CMS announced the Office of Management and Budget's (OMB) continued approval of the OASIS-D through 2024. Providers are to use the OASIS-D through December 31, 2022. Beginning on January 1, 2023, the OASIS-E becomes effective.

CMS released a revised draft of the OASIS-E on February 1, 2022. The Paperwork Reduction Act (PRA) packet for the OASIS-E was issued in the Federal Register on February 9, 2022. The notice is open for a 60-day public comment period with comments due on April 11, 2022.

Points Score for M1860, Quality Assessment Only (QAO), and Care Compare Website

CMS clarified that the point totals listed for responses #2 and #3 for item M1860 in table 2 of the 2022 HHPPS rate update rule are correct. These point values will be used for M1860 beginning in calendar year 2022. There may be times in which the resource use for certain OASIS items associated with functional impairment will result in a seemingly inverse relationship to the response reported. However, this is the result of the direct association between the responses reported on the OASIS items and actual resource use.

CMS announced that the interim QAO reports are available in the IQES for providers to access. Also, errors on the Care Compare website for providers related to services offered by agencies have been corrected

Preview Reports

CMS announced the release of the Preview Reports and Star Rating Preview Reports for the April 2022 Refresh. The April 2022 refresh will add new OASIS-based measures for public reporting in alignment with the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014:

• Percent of Residents Experiencing One or More Falls with Major Injury; and
• Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function.

The claims-based quality measures within this preview report remain frozen. CMS decided to delay the resumption of public reporting for these measures. This delay allows time to analyze the impact of the required comprehensive exclusion of Q1-2020 and Q2-2020 claims data on risk adjustment and reporting.