On Friday, July 12, the Centers for Medicare & Medicaid Services (CMS) released guidance to states on the steps needed to ensure compliance with rate transparency provisions of the Medicaid Access Rule. The guidance touches upon several items important to NAHC-NHPCO Alliance members and homecare providers, including:

The guidance is online here. 

Some hospice providers have reported erroneous claim rejections associated with the certifying physician enrollment edit. The reason code associated with the edit is 17729 – The attending physician’s National Provider Identifier (NPI) data on the claim does not match the PECOS Enrolled Physicians File, or the dates do not fall within the physicians effective/termination dates. Claims potentially impacted are those with dates of service beginning on June 3, 2024, and later. Claims rejected in error are those where the physician was enrolled/validly opted out on the date of certification/recertification (appearing with a “Y” in the Ordering & Referring Data File (ORDF)) but rejected with reason code 17729. The error is system-wide, so it impacts hospice claims processing for all Medicare Administrative Contractors (MACs).

 

To support our members, the NAHC-NHPCO Alliance has been working with all three HH/H MACs and the Centers for Medicare & Medicaid Services (CMS) to find an immediate solution. In response to our outreach, CMS implemented a fix on Monday, July 15. We have been informed the agency is working with the MACs on a process to correct previously rejected claims. 

Clinical judgement should be used to determine if the patient is able to respond for each of the Social Determinants of Health (SDoH) OASIS items, CMS clarified in the July 2024 quarterly OASIS Q&As – released July 11. 

 

This was in response to a question asking if a clinician is required to ask the questions for the SDoH items, such as A1005 (Ethnicity), A1010 (Race), A1250 (Transportation), B1300 (Health Literacy) and D0700 (Social Isolation), if a patient is confused and consistently does not respond appropriately to questions. 

 

Each OASIS item should be considered individually and coded based on guidance specific to that item, CMS states in their response. 

 

The July Q&As include three questions covering additional topics such as: 

Editor’s note: To view the full CMS July 2024 quarterly OASIS Q&As, visit here. 

The home health industry has its very own boogeyman — the bad actor.

 

However, there’s a difference between providers that have made errors in claims processing or quality of care provisions versus those taking part in purposeful fraudulent activity, according to National Association for Home Care & Hospice (NAHC) President William A. Dombi.

 

“The outright fraud, where it’s very overt and purposeful, is the greatest concern,” he told Home Health Care News. “What makes a bad actor is a party that gets into home health care for purposes of stealing from Medicare, Medicaid and others. Their goal is not to provide care, in contrast to those who may make mistakes, but still have a goal to provide compliant high-quality care.”

 

Put simply, the bad actor is the type of provider that regulators want to drive out of home health care, and the type that industry peers work to avoid being associated with.

The New England Home Care & Hospice Conference and Trade Show is the region’s premier event for home care and hospice agencies. The conference is hosted by the six New England state home care associations, which collectively represent nearly 400 organizations. This coming year, the conference heads to the Holiday Inn By the Bay in Portland, ME from April 15-17, 2025.

 

The conference is designed for senior and mid-level administrative and clinical staff. The conference features multiple keynote sessions, workshops, and intensive programs. Topics are designed to meet the needs of all agencies, including Medicare-certified, private duty, and hospices. The trade show is the largest home health and hospice expo in the Northeast.

 

We are pleased to open the call for speakers up to any and all who are interested. The deadline to submit proposals is Friday, September 6 end of day.

 

For more information on our conference you can go to www.NEHCC.com!