To:        NHPCO Membership
From:    NHPCO Regulatory Team
Re:        April 29, 2009

CMS Announces Next Phase for Additional Data Collection on Hospice Claims

Summary:  CMS released Change Request (CR) 6440 on April 24, 2009 as an expansion of CR5567, where hospices report visits by some disciplines for each patient for each week of care.  This new CMS requirement, described by CMS as   “Phase III Data Collection,”   will require providers to report  additional data on their claims for Medicare payment.  Visits will be reported in 15 minute increments, more disciplines will be added, and some phone calls placed by hospice social workers can be counted if they are necessary for the palliation and management of the terminal illness and related conditions.  This new phase of data collection will also require line-item billing on claims.

Effective Date:  The effective date for systems changes and for OPTIONAL reporting by hospices is October 1, 2009.  Mandatory reporting for all hospice providers begins on January 1, 2010.   

Background:  CMS began collecting additional data on hospice claims in January 2007 with CR 5245, which required reporting of a HCPCS code on the claim to describe the location where services were provided. This CR also required reporting of continuous home care time in 15 minute increments. In April 2008 CMS issued CR 5567, requiring Medicare hospices to provide detail on claims about the number of physician, nurse, aide, and social worker visits provided to beneficiaries. MedPAC and industry representatives communicated to CMS in the past year that the this additional claims information was not comprehensive enough to accurately reflect hospice care, particularly information about hospice visit intensity. MedPAC feels that reporting visit intensity would improve Medicare’s ability to carefully analyze the services provided in this growing benefit.

Summary of requirements of CR 6440:

• Nurses, aides, and social workers:

  Medicare will require hospices to report additional detail for visits on their claims. For all Routine Home Care (RHC), Continuous Home Care (CHC) and Respite care billing, Medicare hospice claims should report each visit performed by nurses, aides, and social workers employed by the hospice.  In addition to the actual number of visits, the time spent during each visit will be reported in 15 minute increments, on a separate line.

        The visits should be reported using revenue codes:

• 055x (nursing services),
• 057x (aide services), or
• 056x (medical social services),

with the time reported using the associated HCPCS G-code in the range G0154 to G0156.

• Physicians:
  Billing of physician visits to hospice patients is not changing, and is unaffected by CR 6440.

• Physical therapists, occupational therapists, and speech-language therapists:

  Providers should begin reporting each RHC, CHC, and Respite visit performed by physical therapists, occupational therapists, and speech-language therapists, and their associated time per visit in the number of 15 minute increments on a separate line.

Providers should use existing revenue codes:

• 042x for physical therapy,
• 043x for occupational therapy, and
• 044x for speech language therapy,

in addition to the appropriate HCPCS G-code for recording of visit length in 15 minute increments. HCPCS G-codes G0151 to G0153 will be used to describe the therapy discipline and visit time reported on a particular line item. Hospices should report in the unit field on the line level the units as a multiplier of the visit time defined in the HCPCS description. If a hospice patient is receiving Respite care in a contract facility, visit and time data by non-hospice staff should not be reported.

• Social worker phone calls:

  Social worker phone calls made to the patient or the patient’s family should be reported using revenue code 0569, and HCPCS G-code G0155 for the length of the call, with each call being a separate line item. Hospices should report in the unit field on the line level the units as a multiplier of the visit time defined in the HCPCS description.

Only phone calls that are necessary for the palliation and management of the terminal illness and related conditions as described in the patient’s plan of care (such as counseling or speaking with a patient’s family or arranging for a placement) should be reported. Report only social worker phone calls related to providing and or coordinating care to the patient and family, and documented as such in the clinical records.

When recording any visit or social worker phone call time, providers should sum the time for each visit or call, rounding up to the nearest 15 minute increment. Providers should not include travel time or documentation time in the time recorded for any visit or call. Additionally, hospices may not include interdisciplinary group time in time and visit reporting.

• General Inpatient level of care:For General Inpatient (GIP) care, CMS is not requiring reporting of visit intensity data at this time. Providers should continue to report the number of GIP visits in accordance with CR 5567. CMS is continuing to exempt visit reporting by non-hospice staff when hospice patients in a contract facility are receiving GIP.

CMS has updated Chapter 11, section 30.3 (Data Required on Claim to FI) with this information.  To access CR 6440 with section 30.3 updates and the MM66440 provider education article, visit the CMS Web site.

Questions may be directed to regulatory@nhpco.org.

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