In line with the Centers for Medicare & Medicaid Services’ (CMS) on-going efforts to collect more comprehensive data from hospice providers, CMS recently issued Change Request (CR) 6791 requiring hospices to associate hospice visits to the level of care on claim forms. Effective April 29, 2010, hospices must report a separate line item for the level of care each time the level of care changes in order to associate the visits reported with the level of care being billed.

Consistent with recent recommendations from the Medicare Payment and Advisory Commission (MedPAC), CMS stated that the new visit data reporting requirements would “…better reflect the services provided to Medicare hospice beneficiaries, and may be used in research conducted for possible future payment reform.” In addition, CMS indicated in CR6791 that in the event hospice providers fail to comply with CMS’ new policy, it may consider requiring hospices to report a “separate line for the level of care for each day billed on the claim form” which would undoubtedly create an additional reporting burden on hospices.

The new level of care line item billing requirements apply to Routine Home Care, Inpatient Respite Care and General Inpatient Care, revenue codes 0651, 0655 and 0656 respectively. An example of the new line item requirements cited by CMS is as follows.

If a patient begins the month receiving routine home care followed by a period of general inpatient care and then later returns to routine home care all in the same month, in addition to the one line reporting general inpatient care days, there should be two separate line items for routine home care. Each routine home care line reports a line item date of service to indicate the first date that level of care began for that consecutive period. This will ensure visits and calls reported on the claim will be associated with the level of care being billed. CR6791.

The level of care line item reporting requirements of CR6791 are in addition to the intensity of visit reporting requirements of CR6440 that was issued in May 2009. Effective January 1, 2010, CR6440 requires hospices to report social work phone calls and visits performed by hospice employees, including nurses, hospice aides and social workers, for other than general inpatient care, in 15 minutes increments, excluding travel, interdisciplinary group, and, in some cases, documentation time. Hospices must also report such visits made by physical therapists, occupational therapists and speech-language therapists in 15 minutes increments.

Phone calls made by social workers to the patient or the patient’s family are counted as a visit when the call is necessary for the palliation and management of the terminal illness and related conditions. In addition, CMS recently clarified in an FAQ Update that care coordination phone calls by a social worker to other than family members could be reportable under certain circumstances, such as calls to an alternative care setting to arrange for placement. As is the case with patient visits, it will be important for you to carefully document social work phone calls to demonstrate that the call was “related to providing care and/or coordinating care of the patient for the palliation and management of the terminal illness and related conditions” or counseling of a patient’s family. CMS FAQ ID# 9970, February 19, 2010.

We can expect CMS to continue collecting additional hospice data through claims forms and Medicare cost reports, and improve the quality of all data collected, to facilitate the management of the hospice benefit, including payment reform, as recommended by MedPAC. You can also use the additional data collected internally to help monitor the quality of your services through quality assessment performance improvement audits.

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