Tips and Resources.
By now, most of the hospice community is well versed on the additional data reporting requirement that will be mandatory for dates of hospice service on or after April 1, 2014. In this brief article we hope to offer some tips and resources to assist you and your hospice team as you prepare for compliance with this rule.
Additional Data Reporting – What’s Required?
On July 26, 2013, CMS issued Change Request 8358 detailing the additional information hospices will be required to report when submitting their claims for payment. The requirement is designed to provide additional data to support anticipated hospice payment reform.
Specifically, CR 8358 requires hospices to provide additional information on their hospice claims regarding:
- Location of care when billing General Inpatient Care (GIP) level of care
- The NPI of any SNF, hospital or hospice IPU when the location of care is not the same location as the billing hospice’s location
- Use of a PM modifier when visits occur after death and on the same date of death
- Use of injectable and non-injectable prescription drugs
- The use of infusion pumps
Additional Data Reporting – Moving Toward Compliance
- Identify current systems and workflow regarding the care of hospice patients receiving GIP level of care, post mortem visits and the utilization of hospice provided prescription medications and infusion pumps. Remember that your processes may include involvement from both clinical and non-clinical (or support) staff, so be sure your review is complete.
- Once you’ve identified your current workflow as it relates to the additional reporting requirements of CR 8358, assess your readiness for compliance. Where does your program need to improve its systems, processes and work flow? What gaps have you uncovered?You might want to consider:
- Since you will be required to report the NPI of any nursing facility, hospital and non-owned hospice inpatient facilities, do you have that information readily available? Should you consider amending your contracts with these facilities to insure the collection and verification of this data?
- Are you currently capturing visit time in these facilities? Is it accurate? Does the visit time already flow onto your hospice claims?
- Do you need to talk with your local pharmacy vendor(s) or your pharmacy benefit manager (PBM) to make sure you have information regarding the National Drug Code (NDC) for hospice-provided prescription medications? If your program pays for medications on a per diem basis, how will you collect the NDC and charges for the individual medications? Similarly, if your hospice uses a “comfort kit” do you have the NDCs and charges for the individual medications in the kit available?
- As a part of your readiness assessment, remember to consider the knowledge and education of your staff. Does your staff understand the new compliance requirements? How will you get them up to speed?
- Develop a compliance strategy and action plan. Once you’ve examined your current processes and workflow and assessed for gaps in compliance, it’s time to draw up your compliance plan and put it into action. Most likely you will discover the need to at least partially modify some of your current systems and work flows. As you implement these changes, remember to fully educate your staff on the changes required and why compliance is important.
- Prepare for contingencies, including the need to reevaluate your changed processes and retrain staff.
You may find it helpful to incorporate your preparations for compliance with CR 8358 into your overall existing QAPI program.
HEALTHCAREfirst is working now to address the changes required by CR 8358. Enhancements to our firstHOSPICE product are already in production and are slated for release in the coming weeks to assist our hospice clients with these changes and ensure their ongoing regulatory compliance.