Members should be aware of the following updates from LeadingAge National on home health and hospice issues.

HHCAHPS DNR Template Update. A new Discrepancy Notification Report (DNR) template, covering the sample months of January 2022 through March 2023, is now available for use by survey vendors. This report is available to correct any discrepancies in data reported for the January 2022 through March 2023 period only. On occasion, a survey vendor may identify discrepancies from Home Health Care Consumer Assessment of Healthcare Providers and Systems (HHCAHPS) Survey protocols that require corrections to procedures and/or electronic processing to realign the activity to comply with HHCAHPS Survey protocols. Survey vendors are required to notify the Centers for Medicare and Medicaid Services (CMS) of these discrepancies immediately upon discovery. Once submitted, the CAHPS team will assess the actual or potential impact of the discrepancy on reported HHCAHPS Survey results. Email notification will be sent to the organization submitting the DNR once the outcome of the review has been determined. Agencies can submit questions about this process to the HHCAHPS Survey Coordination Team via email at hhcahps@rti.org, or call toll-free at 866-354-0985.

Home Health and Hospice Open Door Recap. A summary of CMS's latest Open Door Forum for Home Health, Hospice, and Durable Medical Equipment (DME) providers from LeadingAge National is available here.

Hospice Member Network Calls. LeadingAge National will be hosting two calls to gather feedback from hospice members on the Fiscal Year (FY) 2023 Hospice Wage Index proposed rule. The first was held on Mon., April 25^th with hospice agency finance staff to gather input on the proposed 2.7 percent increase and the proposed 5 percent wage index cap. The second call will be held on Wed., April 27^th at 2 p.m. ET with hospice quality, HR, and business/community development staff to discuss CMS's proposed health equity measurement, which includes recruitment of diverse staff and boards of directors, as well as current efforts to engage diverse communities. Registration is available here.

To sign up for the Hospice Member Network and participate in the next call on Tues., May 10^th, please contact LeadingAge National's Katy Barnett at KBarnett@LeadingAge.org.

OIG Adds EVV to Work Plan. In April, the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) announced plans to conduct additional audits on Electronic Visit Verifications (EVV), along with a number of other Medicaid-specific audits, evaluations, and inspections. As part of the 21^st Century Cures Act, all states had until Jan. 1, 2020 to implement EVV for personal care services (PCS). States have until Jan. 1, 2023 to implement EVV for home health care services (HHCS). In January 2021, CMS granted a one-year extension for most states to meet the EVV requirements for PCS. There is concern that once implemented, EVV could increase the risk that Medicaid beneficiaries' needs are not being met, potentially compromising their health and safety. OIG’s objectives in auditing EVV will be to determine if a state (1) has implemented an EVV system in accordance with federal and state requirements; and (2) has developed policies and procedures when using EVV to ensure that Medicaid beneficiaries receive their required in-home services. 

CMS Corrects Home Health Claims Processing Policy and 60-Day Calculation Inconsistency. CMS issued Change Request (CR) 12657 earlier this month modifying two claims processing processes.

• Removing the requirement to submit a Notice of Admission (NOA) before billing for home health denial notices. Before the implementation of NOA on Jan. 1, 2022, every claim for a home health period of care required the submission of a Request for Anticipated Payment (RAP), except billings for denial notice (Type of Bill (TOB) 320 reporting condition code 21). Due to a CMS oversight in the implementation of NOA, billings for denial were not excluded from the requirement to submit an NOA. The CR submitted this month will correct this error, and providers will no longer be required to submit an NOA with billings for denial.
• Revising home health edit criteria to ensure that Medicare systems calculate 60-day gaps in service consistently. Medicare Administrative Contractors identified a variance in how the 60-day gap in home health services is used to calculate coding for early and later home health periods and identifying early periods that should pay as a Low Utilization Payment Adjustment (LUPA) add-on. The CR changes the counting method used to identify a LUPA add-on. 

Updated Quarterly OASIS Q&As. CMS recently released April 2022 Outcome and Assessment Information Set (OASIS) Questions and Answers (Q&As). This document is updated on a quarterly basis and is intended to provide guidance on OASIS questions that were received by CMS help desks. As a reminder, responses may be time-limited and may be superseded by future CMS guidance. This quarterly guidance includes clarifications on the following items:

• RFA 8 – Death at Home: submitting OASIS when death occurs at home after one visit in a recertification period and completing RFA 8 OASIS after patient discharged from hospital observation stay.
• M2020/M2030 – Management of Oral Medications/Management of Injectable Medications: accounting for transportation required to get medications into the home when responding to M2020/2030 and accurately coding for assisted living facility (ALF) residents when ALF staff must unlock medications.
• GG0130A – Eating: coding when patient needs encouragement for adequate food and fluid intake.

Home Health OASIS and Star Rating Preview Reports Now Available. Preview reports are now available on the Internet Quality Improvement and Evaluation System (iQIES) for the July 2022 Home Health Care Compare refresh. OASIS measure reporting will be based on the standard number of quarters. The July 2022 refresh is the first refresh that will resume reporting on all claims-based measures for the Home Health Quality Reporting Program (HH QRP). Due to the COVID-19 reporting exceptions, the claims-based measures are calculated excluding Q1 and Q2 2020 data. For additional information, please see the HH QRP COVID-19 Public Reporting Tip Sheet and the Home Health Data Submission Deadlines webpage.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871