Federal Home Health and Hospice Updates
(May 6, 2025) Please see the following home health and hospice updates from LeadingAge National:
Home Health Updates
CMS Corrects Data Error in July 2025 Home Health Preview Reports. The Centers for Medicare and Medicaid Services (CMS) identified an error in the Discharge Function quality measure scores that were included in the April 2, 2025 release of Home Health July 2025 Preview Reports. The inaccurate scoring affected approximately 16 percent of home health providers and was caused by a technical error, which has now been resolved. Agencies can now retrieve their updated Provider Preview Reports on the Internet Quality Improvement and Evaluation System (iQIES). These reports contain provider performance scores for quality measures, which will be published on the compare tool on Medicare.gov and the Provider Data Catalog (PDC) during the July 2025 refresh. CMS has extended the current preview period until May 21, 2025 to allow a full 30-day review period.
NGS Home Health Agency Claims Processing Issues. The Medicare Administrative Contractor (MAC) for Jurisdiction 6 and K, National Government Services (NGS), released notifications that home health providers may experience claims rejections issues due to a Common Working File (CWF) capacity limitation. The CWF can only hold the 36 most recent periods of care for any beneficiary. It also contains the indicator of when the home health notice of admission (NOA) was processed. This indicator allows the CWF to determine whether a home health admission period is on file with which claims can be associated. When home health care is continuous for more than 36 periods, the oldest period which is purged may have contained the NOA indicator. When this occurs, subsequent claims will be returned to provider (RTP) with reason code U537I, “The FROM and THROUGH dates on the HH claim fall outside of an HH Admission period for the same provider.” NGS installed a correction in their system, but providers should resubmit any claims that were incorrectly RTP for the U537I reason code.
HHVBP Preliminary April 2025 IPRs Available. The Preliminary April 2025 Interim Performance Reports (IPRs) for the Expanded Home Health Value-Based Purchasing (HHVBP) Model have been published on iQIES. Instructions on how to access the reports are available here. In this report, the Calendar Year (CY) 2024 Measure Report Card will reflect Outcome and Assessment Information Set (OASIS)-based measure performance based on 12 months of data through Dec. 31, 2024, and claims-based and Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey-based measures will be based on 12 months of data through Sept. 30, 2024. In July 2025, the IPRs will include data for two OASIS measures (dyspnea and oral medication management) for the first quarter of 2025. The October IPR will include the first achievement points, improvement points, care points, and total performance score for the CY 2025 measure set.
LeadingAge National Expresses Concerns on Medicare Home Health Benefit and HHVBP to OMB, CMS. On April 25th, the Office of Management and Budget (OMB) received the CY 2026 Home Health Proposed Rule from CMS, the final step in the review process before publication. In response to the rule’s receipt, LeadingAge National sent a letter to OMB and CMS regarding the future of the Medicare Home Health Benefit, with specific concerns focused on the payment of services and the Expanded HHVBP Model. Specifically, LeadingAge National noted their concerns that the previous administration’s application of the permanent and temporary adjustments to provider payments was incorrect and asked the current administration to use its legislated authority not to implement the adjustments in CY 2026. LeadingAge National also laid out multiple concerns with the current structure of the HHVBP Model, including cohort sizes, agencies failing to meet basic quality reporting requirements, and the lack of overall risk adjustment.
Hospice Updates
CMS Releases HOPE Manual Version 1.01. CMS released an updated Hospice Outcomes and Patient Evaluation (HOPE) Guidance Manual and accompanying Change Table. There are a number of clarifications on HOPE Update Visits (HUV) and Symptom Follow-up Visits (SFV) which are not conducted within the expected timelines. One item was replaced, A0800 Gender item for A0810 Sex item, which is consistent with other post-acute settings. LeadingAge National will have a detailed article on the changes in the coming weeks.
Hospice Quality Reporting Program Quarterly Updates Available. CMS contractor Swingtech released their first quarterly informational messages to hospices related to the Quality Reporting Program (QRP) since the transition in administrations. If you want to receive Swingtech’s quarterly emails, add or update the email addresses to which these messages are sent by sending an email to QRPHelp@swingtech.com. Be sure to include the name of your facility and the CMS Certification Number (CCN) along with any requested updates.
CMS Gets Tougher on Terminated Hospice Billing. In an effort to crack down on inappropriate billing in the hospice benefit, CMS released a new Change Request (CR 14027) on April 24, 2025 that provides new instructions for MACs to return correctly billed claims submitted 30 days after a hospice was terminated. CMS states that it was brought to their attention that claims are being processed and paid with dates of service after the termination date of certain hospices. However, regulations (42 Code of Federal Regulations (CFR) 489.55) allow payment for hospice services for up to 30 days after a hospice terminates their Medicare provider agreement. This payment may be made if the hospice services are furnished under a plan of care established before the effective date of the termination. Medicare will continue to make payments for claims which extend beyond a provider's termination date if the hospice services are provided under a plan of care established prior to that date and if the hospice care ends within the 30-day period. The CR also adds a new section, Section 110, to Chapter 11 of the Claims Processing Manual to reflect this guidance. This change in billing will be implemented Oct. 6, 2025.
CMS Issues Guidance to Hospital Outpatient Services on Hospice Enrollees. CMS issued reminders to acute care hospital outpatient services regarding expectations for services rendered to hospice enrollees. This follows up on a report from the Office of Inspector General (OIG) which found that Medicare improperly paid acute care hospitals for outpatient services provided to hospice enrollees. CMS emphasizes in their latest Medicare Learning Network (MLN) Newsletter that, to avoid improper payments, acute care hospital outpatient services should request and analyze hospice election statement addendums for enrollees they are providing services to. CMS urges providers to review the Acute Care Hospital Inpatient Prospective Payment System educational tool for more information. CMS goes further to outline two important points: (1) CMS does not pay for services given to palliate or manage a terminal illness and related conditions. Services should be provided under arrangements with the hospice provider; and (2) CMS only pays for Part B outpatient services that are unrelated to the terminal illness and related conditions. This is part of an ongoing effort from CMS to curb spending outside of the hospice benefit including recent updates on the responsibility and liability for providers who do not submit billing with the correct hospice modifiers for services unrelated to the terminal condition.
New SMRC Audit Active on Hospital Outpatient Services for Hospice Patients. CMS approved a new audit in April 2025 with their Supplemental Medical Review Contractor (SMRC), Noridian, after OIG released a report last year which found that Medicare Part B improperly paid acute care hospitals for outpatient services provided to hospice enrollees. This post-payment review will look at a sample of claims billed for hospital outpatient services provided to hospice enrollees with condition code 07. This code indicates the patient has elected hospice care, but the provider is not treating the terminal condition and is, therefore, requesting regular Medicare payment. The dates for additional documentation request include dates of service Jan. 1, 2022 through Dec. 31, 2023.
Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871