Please note the following updates from LeadingAge National on home care and hospice:

1. New Home Care Network. Non-certified and other home care providers are welcome to join LeadingAge National's new Home Care Network. Created for all members providing home care outside the traditional Medicare Home Health benefit, the Home Care Network will host discussions on important topics like labor laws, workforce recruitment, staffing models, technology in the home, and more. The first quarterly call is on Tues., Feb. 20^th at 2 p.m. ET. Join the Home Care Network here. Questions? Contact Katy Barnett or Georgia Goodman at LeadingAge National.
2. CMS Temporarily Pauses PEPPERs. The Centers for Medicare and Medicaid Services (CMS) announced a temporary pause in distributing Program for Evaluating Payment Patterns Electronic Reports (PEPPERs) as they work to improve and update the program and reporting system. PEPPER is an electronic report that provides provider-specific Medicare data statistics for discharges/services vulnerable to improper payments. This pause will remain in effect through the fall of 2024. Many home health agencies, hospice programs, and skilled nursing facilities find these reports extremely valuable. Therefore, during this time, CMS will be working diligently to enhance the quality and accessibility of the reports. CMS also stated, in the near future, that they will be releasing a Request for Information (RFI) to obtain information from the provider community about how the program can better serve agencies. LeadingAge National will continue to monitor the redevelopment of PEPPER and engage members on the forthcoming RFI.
3. CMS Shares FAQ from November ODF on Hospice MFT and MHC Use. In November, CMS hosted an Open Door Forum (ODF) that included a discussion of the new provisions allowing Marriage and Family Therapists (MFTs) and Mental Health Counselors (MHCs) to act as members of the interdisciplinary group (IDG). A new Frequently Asked Questions (FAQ) document reviews the questions that were answered on the call. LeadingAge National reached out to CMS regarding question 8, on completing the comprehensive assessment and creating a plan of care. CMS clarified: “The requirement at 418.54(b) states the IDG must complete the comprehensive assessment. Hospices have a choice to place a SW or MFT or MHC on the IDG. The SW, MFT or MHC [is] able to conduct a psychosocial assessment in accordance with their state scope of practice. SW, MFTs, and MHCs each have their own state scope of practice and licensure requirements. While SW, MFT or MHC may be able to conduct a psychosocial assessment, if permissible by their [state], it is the assessed needs of the patient that [drive] the services that patient receives. Lastly, regardless of the official member of the IDG (SW or MFT or MHC), we encourage the other disciplines providing care to the patient, if applicable, to participate in IDG meetings and provide their clinical perspective in the development and update of the comprehensive assessment.” CMS provided two examples:
   • If the MFT or MHC is the member of the IDG, the MFT or MHC is responsible to conduct the psychosocial portion of the assessment, if permissible by their state scope of practice and licensure. If the assessed needs of the patient fall into the scope of practice of the social worker, then it is expected that the social worker would be providing services to the patient to meet the patient's social work needs. This information would be documented and communicated (per the hospice's policy) in the patient's record and shared with the official IDG member – in this case, the MFT or MHC.
   • Similarly, if the social worker is the official member of the IDG, the SW would be responsible for the psychosocial section of the assessment. If the patient has an assessed need for therapy/counseling services, the hospice may choose to utilize an MFT or MHC to meet the therapy/counseling patient's need. It is expected that the MFT or MHC would document and communicate the information (per hospice policy) in the medical record and share with the official IDG member – in this example, the social worker.
4. CMS Updates Hospice Cost Report to Include MFTs and MHCs. CMS updated the hospice cost report to include the addition of MFTs and MHCs as part of the IDG. Specifically, CMS updated Line 36 – Counseling – Other. This cost center includes the cost of counseling services not already identified as spiritual, dietary, or bereavement counseling. Effective for services on or after Jan. 1, 2024, in accordance with the Consolidated Appropriations Act of 2023, §4121, it also includes the cost of MFT and MHC services. Costs for non-reimbursable activities included in this cost center must be reclassified to the appropriate non-reimbursable cost center.
5. CMS Issues January 2024 Quarterly OASIS Q&A. CMS published their January 2024 Quarterly Outcome and Assessment Information Set (OASIS) Questions and Answers (Q&A). The top question in the Q&A was regarding the removal of items from OASIS on Jan. 1, 2025. The following items were proposed and finalized for removal in the Calendar Year (CY) 2024 Home Health Rule: M0110 – Episode Timing, M2200 – Therapy Need, and the GG Discharge goals. CMS does clarify that until these items are removed from OASIS, providers should continue to complete them following the item-specific guidance found in the OASIS-E Guidance Manual. The Q&A also clarifies questions around intravenous (IV) access for item O0110. If there is a current IV access in place at the time of assessment that is used for dialysis or during dialysis for another purpose – for example, a central venous catheter – then home health agencies should check O0110O1 – Special Treatments, Procedures, and Programs: IV Access. However, an arteriovenous (AV) fistula, whether it is being accessed or not, does not meet the definition of IV access for this item.
6. Veterans Affairs Releases CY 2024 Fee Schedule. On Jan. 24^th, the U.S. Department of Veterans Affairs (VA) posted the CY 2024 fee schedule. More information on how the VA calculates their fee schedule and reimburses contracted providers is available here.

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