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Volume 23.14

Effective today, July 13, 2023, CMS has placed new hospices, defined below, in a provisional period of enhanced oversight.  A new hospice is defined as:

  • A new enrollee in the Medicare program on or after July 13, 2023,
  • A hospice submitting a change of ownership (“CHOW”) that meets the regulatory requirement of 42 CFR 489.18, or
  • A hospice undergoing a 100% ownership changes that doesn’t fall under the provisions of 42 CFR 489.18.

According to CMS, a hospice may be impacted if:

  • The hospice received final approval for Medicare enrollment on or after July 13, 2023,
  • The hospice started the enrollment or certification process before July 13, 2023, but has not received a final approval letter from the Medicare Administrative Contractor (“MAC”), or
  • The hospice received approval on a change of ownership request on or after July 13, 2023.

Hospices subjected to the enhanced oversight will receive a letter noting the:

  • Effective date of the enhanced oversight period,
  • Duration of the enhanced oversight period, and
  • Indicating that a medical review may be conducted for all claims and failure to respond to requests may result in denied claims or revocation of Medicare enrollment.

The period of the enhanced oversight can be for a period of up to one (1) year.

Additional details ar available here.

NAHC REPORTS ON SMRC POST-PAYMENT REVIEWS FOR HOSPICE STAYS IN EXCESS OF NINETY (90) DAYS

The National Association for Home Care and Hospice (“NAHC”) has reported that Noridian, CMS’ Supplemental Medical Review Contractor (SMRC) recently launched a new “Hospice 90 Day Stay” project, in which they will do post-payment review on select hospice claims from January 1, 2021, through December 31, 2021 that are for patients with stays 91 days or longer with specified diagnoses. The codes can be found on Noridian’s webpage.

EARLY REGISTRATION DISCOUNT ENDS JULY 15, 2023, FOR THE HOSPICE FINANCIAL MANAGEMENT AND ADMINISTRATION CONFERENCE

The Health Group, LLC’s 2023 Hospice Financial Management and Administration Conference is rapidly filling up (attendance limited).  The program will be held at the beautiful Lago Mar Beach Resort, Fort Lauderdale, Florida on November 9-10, 2023. Program information, including registration information, is available here.  The program provides for a special session on the financial implications of the many hospice integrity initiatives, both implemented and proposed.

We are encouraging anyone who expects to attend to make room reservations at their earliest opportunity.  Many individuals planning on attending the program have already reserved their rooms.  The Lago Mar Beach Resort will sell out for the days of our conference.  Special rates have been secured with the Lago Mar Beach Resort & Club; however, to secure these rates, call (855) 829-2923 and inform the hotel that you are attending “The Health Group, LLC Hospice Financial Administration Conference” or online at www.lagomar.com.

When making reservations online, go to reservations, click on group code, and enter 2311THEHEA.  Select the dates you will be staying, even if the dates are indicated as not available, select them and your room type.  All attendees are being offered Executive One Bedroom Suites at $235/night.  Resort fees have been waived for our attendees.  If you have a problem, please call the hotel.  The hotel is making the $235/night available for two (2) days prior and two (2) days after the program dates.