home health & hospice coalition meeting...

Home Health & Hospice Coalition Meeting Minutes

MEETING DETAILS

Date: February 13, 2017Time: 9:30 a.m. ETLocation: Teleconference

ATTENDEES

Coalition Members Kaye Keel (AL), Bobby Lolley (FL), Melinda Gaboury (FL), Patti Heid (FL), Norene Mostkoff (GA), Bonny Kohr (IL), Katharine Eastvold (IL), Sara Ratcliffe (IL), Lisa Collins (IN), Renee Korb (IN), Michelle Stein-Ordonez (IN), Cindi Wessell (IN), Rebecca Cartright (KY), Annette Gervais (KY), Warren Hebert (LA), Richard MacMillan (LA), Becky Knight (MS), Elaine Roark (MS), Cindy Morgan (NC), Sherry Thomas (NC), Kimber Walters (NC), Kim Hall (NC), Teresa Turietta (NM), Steve Telles (NM), Beth Foster (OH), Katie Wehri (OH), Annette Mays (OK), Chasity Fortson (SC)Heather Jones (SC), Rachel Hammons (TX), Marissa Machado (TX), Jason Peterson (TX), Gayla Sasser (TN), Aaron Little

Palmetto GBA Staff

Kim Campbell, Charles Canaan, Krisdee Foster, Dr. Leland Garrett, Dan George, Melissa Henson, Kim Hinson, Marilyn Jeske, Kathy Kardules, Sheryl Lassiter Melinda Martin, Tanesha Norman, Tammy Tucci, Jim Peebles, Susan Pendley, Sheila Pierce, Joe Strickland, Dr. Antonietta (Toni) Sculimbrene, Ashley Toole

AGENDA ITEMS

Standing Items

ITEM # TOPIC DISCUSSION1 Palmetto GBA Staff Changes Palmetto GBA: Melinda Martin was announced as

the new education consultant for the Provider Outreach and Education (POE) team.

2 Palmetto GBA Data:A. Appeals

I. Home healthII. Hospice

Coalition: Questioned the increase in redeterminations for home health?

Palmetto GBA: Automated denials by the Recovery Auditor (RAC) created an increase in the home health appeals over the last quarter.

B. Data Reports – January – December 2016

I. Home Health Medical Review

Palmetto GBA: The reports attached are for January – December 2016. The coalition requested a rolling 12-month data report in the last meeting. This is the first

Palmetto GBAHome Health & Hospice Coalition MeetingFebruary 13, 2017 1


II. Home Health Medical ReviewIII. Area-Specific Data

of those reports, and since quarter 4 ended in December, the report is from January to December. The report for the next meeting will reflect the 12-month period up to the end of the next quarter.

There were no further comments or questions.C. Hospice Cap

I. Update through first part of December?

Palmetto GBA: The 2015 Cap calculations have been completed. The overall amount is down from the 2014 cap. The 2016 self-report cap is due by end of March 2017. Palmetto GBA will be sending the data to the providers so that they can prepare their reports.

3 EDI Updates Palmetto GBA: We want to remind providers that move from FTP to SFTP will be final effective April 1, 2017. Palmetto GBA is working with network service vendors to ensure a smooth transition. In addition, the EDI system status log now includes eServices outages as well as DDE availability. It is time for DDE ID recertifications to begin. Palmetto GBA will be sending out notifications within the next two or three weeks. Emails will be sent to those users for which we have a valid email address. All others will receive a letter. An article will be posted to Palmetto GBA’s website when the process begins.

Coalition: Is the Multi-factor authentication for eServices only or does this include DDE.

Palmetto GBA: The multi-factor authentication is for eServices users only.

4 Organizational Process Improvement Coaching Project (OPICP) Updates

Palmetto GBA: Weeks 1 and 2 are completed with a home health agency (HHA) in IL that is participating in the OPICP; Week 3 will be completed next week. Week 1 is determining what HHA process is and mapping out Palmetto GBA process; week 2 is mapping out the physician process (e.g., F2F) and week 3 is finalizing the mapping process and developing ideas. This is just the first of providers and we will have additional providers;

Coalition: Is there an acronym list?

Palmetto GBA: There is a list on the website, and we will include it in the final minutes.



The Acronym and Terminology Index can be accessed athttp://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~JM%20Home%20Health%20and%20Hospice~Basics%20for%20Medicare~Information%20for%20New%20Providers~8EELTB6753

5 MAC/RAC/ZPIC/CERT Communication Updates

Palmetto GBA: Performant is the new Recovery Audit Contractor (RAC) for Region 5, Home Health and Hospice providers. Palmetto GBA is partnering with Performant to conduct a live webcast on March 23, 2017. Staff from Performant will be providing information on the RAC requirements.

Coalition: Will this replace the quarterly updates webcast that is scheduled for the same date?

Palmetto GBA: The quarterly updates webcast will have to be rescheduled.

Coalition: Is the new RAC nationwide?

Palmetto GBA: Performant is the RAC for all home health and hospice providers as well as Durable Medical Equipment (DME) suppliers.

6 Identified Training Needs That Associations Can Share with Their Members (Home Health & Hospice)

Palmetto GBA: Nothing new to share. Reminder that DDE user ID’s are unique to each user and cannot be shared.

7 Provider Enrollment Updates Palmetto GBA: Reminder that we are currently in Phase 2 of the enrollment revalidation process. CMS requires Providers to revalidate every 5 years. Providers should ensure that their applications are submitted by the due date. Providers that fail to submit the application on time, or information requested from the enrollment analyst may be subject to a payment hold, which could include deactivation of the provider number.

Coalition: Did we understand correctly that payments to providers would be placed on hold if they do not respond to ADR’s?


http://www.palmettogba.com/palmetto/providers.nsf/DocsCat/Providers~JM%20Home%20Health%20and%20Hospice~Basics%20for%20Medicare~Information%20for%20New%20Providers~8EELTB6753%20




Palmetto GBA: During the processing of an enrollment application, the enrollment analyst may contact the provider for additional information/documentation. If a provider fails to respond to a request for additional information/documentation related to the enrollment process, their payments may be placed on hold, and their provider number may be deactivated.

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Follow-Up Items From Previous Meeting

ACTION ITEMS RESPONSIBLE PARTY TARGET DATE OUTCOME COMPLETION

DATEPalmetto GBA to determine if report can be generated for the following:1. SIA Visits by RN or

Social worker by state2. GIP visits by

discipline by state3. RHC by discipline by

service by state

Palmetto GBA Next meeting Palmetto GBA: No information to share as yet. We are in the process of determining if the reports can be generated as well as a cost analysis.

Coalition: Did the request for the data include all three items? Do you have an estimate as to how long it will be before we know if the reports can be generated, and the cost that will be associated?

Palmetto GBA: The request was made for the report to include all three data sets. We hope to have a response on whether the reports can be generated and the cost analysis by the time

3/9/2017



the final minutes are sent to the coalition.

March 9, 2017: emailed Heather Jones and advised that the reports will be provided at the next coalition meeting.

Notify the coalition when the Hospice Change of Ownership and Key Transfer Points job aids are completed and posted to the website.

Palmetto GBA TBD Update at the meeting on 02/01/16: The job aids are still in development. Palmetto GBA anticipates that they will be completed in the next month or so.

Update from the meeting on 06/13/2015: No additional updates at this time.

Update from the meeting on 10/3/2016: The job aides are still under development and we have no ETA on the completion.

Update at the meeting on 2/13/2017: No additional updates at this time.

Palmetto GBA to determine if MSAD can provide a report that provides the data for the true 56900 denials (back out the claims that were reopened)

Palmetto GBA By the next meeting

Palmetto GBA: We are researching to determine if the data can be provided. We hope to have included a response in the final minutes.

3/10/2017



3/10/2017: emailed Heather Jones a response explaining that there is not a way to filter out claims initially denied with 56900 and subsequently reopened.

Notify the coalition when guide has been posted to assist providers with understanding the appeals processes outlined in MLN article SE1521

Palmetto GBA TBD Update at the 10/3/2016 meeting; The guide is still under development and we do not ETA for completion.

2/13/2017: No additional updates at this time.

Palmetto GBA to update the requirements for documentation on task 5 of the PCR submittal request to include language that reflects that documentation to support medical necessity needs to be included.

Palmetto GBA TBD 2/13/2017: No additional updates at this time.

Palmetto GBA to explore avenues that will enable providers to track PCR requests submitted per patient as opposed to just the DCN.

Palmetto GBA TBD Palmetto GBA: eServices is in the process of developing a dashboard in eServices and one of the enhancements that is being considered is the ability to organize items by topic or by patient.

02/13/2017

General Items



ITEM # TOPIC DISCUSSION1 Is Palmetto GBA hearing that any initiative

will be placed on hold by the new administration?

Palmetto GBA: We have not received any directive to place any activity on hold. We are aware that with the new administration there may be changes, but if/when we receive information we will share it with the group.

2 Denial reasons that state documentation not submitteda. Plans to further define denial

narratives?b. Providers are confused when denial

states no documentation submitted but documentation was submitted just not sufficient

Coalition: Providers are receiving denials on claims stating that the documentation was present but not sufficient. Providers are contacting the service center, but are being told “everything is getting labeled that way.” Because these denial reasons are so vague, are there plans to provide a better description for this situation?

Palmetto GBA: As a reminder, providers can view detailed comments regarding the denial on claim page 4 in DDE. To ensure we understand the concerns, does this situation apply to one or multiple reason codes? For example, a code may state that the Plan of Care (POC) was not submitted, but it may be that the POC for the episode being reviewed was not submitted, or was not complete.It would be helpful to know the reason codes to which the coalition was referring. Thus, if you can send the codes in question to [email protected], we will look at them and provide a more definitive response.

3 Update on resolution to eServices system issues. Providers are concerned that adding Florida to PCR process will create more problems with system outages due to an increase in the number of users

Coalition: Are the recent system issues something that we can expect to continue, or have the issues been resolved? Providers are concerned about the outages and how this will impact their ability to submit PCR’s and other documentation once Florida is up and running

Palmetto GBA: The recent system outages were related to the network, not eServices specifically, and have been resolved. Palmetto GBA will also be conducting performance testing before Florida providers go live with PCR. In addition, Palmetto GBA has added servers to the system in anticipation of the increased usage of eServices with the upcoming submission of PCR’s from FL. Palmetto GBA is in a


mailto:[email protected]


ITEM # TOPIC DISCUSSIONposition to handle the increased load.

Coalition: With respect to the Multi-Factor Authentication, providers are experiencing a delay in receiving their code. Some are reporting that it takes a minimum of 15 minutes before they receive the code. Other providers are experiencing difficulty in getting the code, while others have indicated that by the time they receive their code, the system goes down, and they have to start over again.

Palmetto GBA: We are working to decrease the time in which it takes to generate the code for the users. In the meantime, we have identified an issue where providers are not waiting long enough to receive the code and are clicking “button” multiple times to “regenerate” the code. We recommend that providers should wait to get the code, and only click once if they do not receive it.

Coalition: Is it possible that it could be 15 minutes to receive code?

Palmetto GBA: Currently, it could take up to 15 minutes for the user to get the code. We are working to reduce the length of time it takes for a provider to receive the code. System enhancements were recently implemented, which reduced the response time to approximately 5 to 10 minutes. Enhancements will be made as quickly as possible to further reduce the length of time it takes to generate a code.

4 Open Discussion None

New Items – Home Health

ITEM # TOPIC DISCUSSION1 Pre-Claim Review Update Palmetto GBA: We are processing PCR requests for

IL, and continuing education efforts. We do not expect any delays with FL. In addition, we are in the process of expedited probe and educate review for FL providers to ensure they are on track with the



ITEM # TOPIC DISCUSSIONdocumentation requirements. We do not have any updates as to when TX will be implemented. We are also looking for ways to improve the process and providing feedback to CMS on regular basis. CMS providing data on their website.

2 Probe & Educatea. Will reviews be implemented as they

were previously by state?

Palmetto GBA: We ask providers to keep in mind that the process is provider-specific. Edits are set up in system to roll out the ADR’s to providers. We have already begun mailing the ADR letters. As a reminder, all providers that had 2 or more claims denied in Phase 1, regardless of whether or not the denials were reversed in the appeals process, will be subject to review in phase 2. In addition, providers that did not have five claims reviewed during Phase 1 are also subject to review during Phase 2. However, providers in the states of IL and TX will not be included in Phase 2. Providers in FL are currently undergoing an expedited review to ensure they are on track for PCR.

Coalition: What is the rationale for including providers that had denials reversed during the appeals process for Phase 1?

Palmetto GBA: Instructions from CMS were written such that appeals cannot be backed out. The purpose of the probe and educate is to get a measure on getting it right the first time.

Coalition: A provider in NC received a denial during Phase 1 for missing F2F, but Palmetto GBA denied the claim in error. However, the provider had to appeal instead of claim being reopened. Can you explain why this happened?

Palmetto GBA: We work closely with the MR area to get claims reopened in a case where a denial was made in error, but there may have been some that we missed. If claim was reopened by the MR staff, then we would back it out that denial from the total count.

Coalition: In this scenario, we believe the appeal had already been sent. So in this case, we assume the claim could not have been reopened.



ITEM # TOPIC DISCUSSION

Palmetto GBA: That would be correct. Once the appeal is filed, the MR staff cannot intervene.

We also want to remind providers that when registering for education through Palmetto GBA’s Event Registration Portal that they need to ensure their systems are set to the correct time zone. The times posted on the portal are Eastern Time.

In addition, providers should note that the MR staff will continue to send out the “per claim” education letters, but at the end of the review, the provider will receive the final results information with information on how to request education and registration, if applicable.

Please also remind providers that time requirement to appeal a denial does not change with the probe and educate. Providers have 120 days from the date of the remittance advice to request a redetermination of the claim.

3 ADR Update: What probe, complex, or targeted reviews are planned other than probe and educate?a. Update on reviews for BG** and

CH** HIPPS codes

Coalition: What is the method by which providers will receive ADR’s for the “BG” and “CH” denials? Can Palmetto GBA provide some clarity on how the number of claims will be selected for ADR.

Palmetto GBA: Yes, we can provide more clarity on the reviews and the number of claims. The system is set to pull 100 per edit.

Coalition: There are multiple codes that would have “BG” as part of the HIPPS, so does that mean that there will be 100 per code for each state?

Palmetto GBA: Yes, that is correct.

Coalition: Would 1 provider expect to receive 100 ADRs?

Palmetto GBA: No. We would not send 100 letters to a single provider. Providers may receive multiple ADRs for multiple edits, but not 100 per edit. There is



ITEM # TOPIC DISCUSSIONa cap to the number of claims that would be selected for a single provider.

The quarterly results of the *CH** reviews have been posted to Palmetto GBA’s website at www.palmettogba.com/palmetto/providers.nsf/Docscat/Providers~JM%20Home%20Health%20and%20Hospice~Medical%20Review~Results. The results of the *BG** reviews are forthcoming in the next several weeks.

4 Clarification on CR 9585/MLN Matters MM9585 denials related to the date the OASIS was submitted

Coalition: Will the claim be denied if the OASIS is not received prior to the bill or if it exceeds greater than 30 days but prior to the bill?

Palmetto GBA: It is our understanding that if the OASIS is submitted after the 30 day requirement, the claim will be denied. In addition, we understand the CR to state that the system will initially be set to allow a 40-day grace period but it does not state how long this will be allowed.

Coalition: On the CMS Open Door Forum, we understood CMS to state that so long as the OASIS is in the repository before the claim is billed, the claim will not be denied.

Palmetto GBA: We also heard that on the Open Door Forum, but will need to research further.

Coalition: A member of the coalition stated that she has studied the CR and cannot find any indication that the system will determine if the OASIS was submitted timely. In addition, we are also unclear as to when the counting of 30 days to have the OASIS submitted begins?

Palmetto GBA: The MO090 date is what the system reads to determine the 30 days.

Coalition: We have noticed where providers have problems with OASIS transmission, which causes denials if Palmetto GBA cannot find the OASIS when



ITEM # TOPIC DISCUSSIONthey are reviewing the claim.

Palmetto GBA: For appeals, if there is a noted problem with the vendor or history with a provider, we will go back and double check to assure the OASIS was transmitted correctly.

Coalition: So should the provider appeal if it’s a technical error?

Palmetto GBA: If a vendor was hired by the agency they are an extension of the provider, and the provider is expected to ensure that the OASIS is transmitted on time.

Coalition: CMS provides a list of approved vendors. Should agencies report when they have a problem with an approved vendor?

Palmetto GBA: If you are referring to issues to vendor hired by provider, they need to resolve it between themselves. Palmetto GBA would not be able to intervene in that process.

5 Open Discussion Coalition: We have heard from providers that they are having issues with claims outside of that of the V8031. Has Palmetto GBA received any reports of issues with claims for anything other than V8031?

Palmetto GBA: We are not aware of any other issues at this time.

Coalition: CGS has a more expansive list on their website. CGS’ website states that providers are having issues with E0419, V8029, V8030, and V8031.

Palmetto GBA: We will verify whether or not there are other issues. At this time, we do not know of any.

Note: Subsequent to the meeting, the coalition was notified that the only other issue Palmetto GBA has identified is E0419, but the volume is very low.



ITEM # TOPIC DISCUSSION

Palmetto GBA: Appeals – effective March 6, 2017, we will be transitioning to the Medicare Appeals System. This should be seamless to the provider community except that the decision letters will look a little different.

Also, providers should note that effective February 14, 2017, there is a new Qualified Independent Contractor (QIC). This impacts providers in KY, OH, IN and IL. The new QIC is C2C. The QIC handles the reconsideration, which is the second step in the appeals process.

Coalition: A provider in Texas has received a letter from an agency that appears to be a collection agency regarding an overpayment.

Palmetto GBA: If a provider has an outstanding overpayment that is referred to the US Treasurer, a collection agency may be sending letters to the provider. However, to ensure that the letter is legitimate, we need to see a copy of the letter.

Note: subsequent to the meeting, Palmetto GBA received a copy of the letter and confirmed that it was legitimate. The provider had an outstanding overpayment that was referred to the US Treasurer.

New Items – Hospice

ITEM # TOPIC DISCUSSION1 Update on hospice payment issues related

to SIA and RHCPalmetto GBA: The SIA Payment issue was fixed in the January system release. We are awaiting final instructions from CMS as to whether or not we are to adjust the claims. With respect to the RHC payments,, we are still seeing payment issues. However, an additional fix will be implemented in April quarterly system release.

2 Update on “new” process for NOEs Palmetto GBA: The three MACs are currently collaborating to complete an instructional document. We do not have an estimate as to when the document



will be completed.

Coalition: Has there been any further communication from CMS as to when NOEs can be submitted via the electronic claims format?

Palmetto GBA: We have not received any updates from CMS.

3 Audit plans for GIP Palmetto GBA: A Provider-specific audit is ongoing for GIP. We will be looking at reviewing GIP when provided in place of service Q5004. A priority list is in development and will be submitted to CMS for approval.

Coalition: Is there additional information that can be provided?

Palmetto GBA: There is no additional information to provide at this time. We will provide the information when it becomes available.

4 ADR Update: What probe, complex, or targeted reviews are planned?

Palmetto GBA: Reviews are planned for revenue codes 0651, 0656 and 652 in place of service Q5001, – patient’s home, Q5002 – services provided in an assisted living facility, and Q5003 – services provided in nursing facility with non-skilled care. Edits have not yet been initiated, and we do not plan to do so during the next few months. A notification will be made via the website when we are ready to begin the reviews.

5 Open Discussion

Follow-Up Items From This Meeting

ACTION ITEMS RESPONSIBLE PARTY TARGET DATE OUTCOME COMPLETION

DATENotify the coalition when the Hospice Change of Ownership and Key Transfer Points job aids are completed and posted to the website.

Palmetto GBA TBD Update at the meeting on 02/01/16: The job aids are still in development. Palmetto GBA anticipates that they will be completed in



the next month or so.

Update from the meeting on 06/13/2015: No additional updates at this time.

Update from the meeting on 10/3/2016: The job aides are still under development and we have no ETA on the completion.

Update at the meeting on 2/13/2017: No additional updates at this time.

Notify the coalition when guide has been posted to assist providers with understanding the appeals processes outlined in MLN article SE1521

Palmetto GBA TBD Update at the 10/3/2016 meeting; The guide is still under development and we do not ETA for completion.

2/13/2017: No additional updates at this time.

Palmetto GBA to update the requirements for documentation on task 5 of the PCR submittal request to include language that reflects that documentation to support medical necessity needs to be included.

Palmetto GBA TBD 2/13/2017: No additional updates at this time.

Coalition to send Marilyn examples of reason codes for which the group is

Coalition As soon as possible.



requesting further clarification.

NEXT MEETING

The next coalition meeting will be:

Monday, June 5, 2017, in Charlotte


home health & hospice coalition meeting...

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