CAP Reporting for the 2022 CAP Year

The Health Group 

The 2022 CAP Year ended on September 30, 2022.  All hospices must file their self-determined CAP (“CAP Report”) for the 2022 CAP Year between January 1, 2023, and February 28, 2023.  Tips relating to CAP reporting include the following:

• Secure beneficiary counts and payments for the 2022 CAP Year as soon as possible on or after January 1, 2023.  This will ensure that the hospice reports the lowest CAP liability, if one exists, at the time of self-filing.

• Even though the hospice secures data at or near January 1, 2023, the CAP Report does not need to be filed until February 28, 2023.

• If the CAP Report indicates a liability due to the Medicare program, early preparation of the CAP Report will better prepare the hospice for any liability which needs to be paid based on the self-filing.

• If the hospice will be reporting a CAP liability and needs to secure an Extended Repayment Schedule (“ERS”) to repay the liability, the hospice will need to begin accumulating the information needed to apply for an ERS.  This includes up-to-date financial information through December 31, 2022.

• Terminated providers should file their final CAP Report on or before February 28, 2023, if they terminated Medicare participation and the termination has been processed.

• Visit the respective website of the servicing Medicare Administrative Contractor (“MAC”) regarding calculated overpayments and making repayments.  The instructions issued by the MACs are not consistent.

• Remember, the MAC will recalculate the CAP liability or potential CAP liability annually for at least three (3) years.  Even if you do not report a liability at the time of self-filing, the hospice may experience a liability for the 2022 CAP Year later.  If you will be self-reporting a CAP liability, or if the margin between the calculated CAP and Medicare payments for services rendered during the CAP Year is insignificant, the hospice may need to make estimates of the ultimate CAP liability for financial statement, PRF reporting, or other purposes.

• Retain a copy of all submissions and correspondence between the hospice and the MAC relating to the CAP.

Telehealth Home Health Services: New G-Codes

In the CY 2019 HH Prospective Payment System (HH PPS) final rule with comment (83 FR 56406), we finalized the definition of remote patient monitoring in regulations at 42 CFR 409.46(e) as the collection of physiologic data (electrocardiogram, blood pressure, glucose monitoring) digitally stored or transmitted by the patient or caregiver to the HHA.

The first COVID–19 Public Health Emergency (PHE) interim final rule with comment period (IFC) (85 FR 19230) implemented additional policies under the HH PPS to make providing and receiving services via telecommunications technology easier.

The plan of care must describe how such technology is tied to the patient-specific needs in the comprehensive assessment.

The amended plan of care requirements in 42 CFR 409.43(a) also state that these services can’t substitute for a home visit ordered as part of the plan of care. Also, they can’t be considered a home visit for the purposes of patient eligibility or payment, per section 1895(e)(1)(A) and (B) of the Social Security Act. The CY 2021 HH PPS final rule with comment period (85 FR 70298) finalized these changes on a permanent basis. It also amended 42 CFR 409.46(e) to include not only remote patient monitoring, but other communication or monitoring services consistent with the plan of care for the individual, on the HH cost report as allowable administrative costs.

Today, data collection on telecommunications technology use is limited to overall cost data on a broad category of telecommunications services as a part of an HHA’s administrative costs on line 5 of the HHA Medicare cost reports. Data on telecommunications technology use during a 30-day period of care at the patient level isn’t currently collected on the HH claim. While the provision of services provided via a telecommunications system must be in the patient’s plan of care, CMS doesn’t routinely review plans of care to determine the extent these services are actually provided.

Collecting data on telecommunications technology use on HH claims will allow us to:

• Analyze the characteristics of patients using services provided remotely
• Have a broader understanding of the social determinants that affect who benefits most from these services, including what barriers may potentially exist for certain subsets of patients

Starting on or after January 1, 2023, you may voluntarily report the use of telecommunications technology in providing HH services on HH payment claims. We’ll require this information on HH claims starting on July 1, 2023. You’ll submit the use of telecommunications technology on the HH claim using the following 3 G-codes:

• G0320: Home health services furnished using synchronous telemedicine rendered via a real-time two-way audio and video telecommunications system
• G0321: Home health services furnished using synchronous telemedicine rendered via telephone or other real-time interactive audio-only telecommunications system
• G0322: The collection of physiologic data digitally stored and/or transmitted by the patient to the home health agency (for example, remote patient monitoring)

Report the use of remote patient monitoring that spans a number of days as a single line item showing the start date of monitoring and the number of days of monitoring in the units field. You’ll submit services provided via telecommunications technology in line-item detail. Report each service as a separate dated line under the appropriate revenue code for each discipline providing the service. You must document the medical record to show how the telecommunications technology helps to achieve the goals outlined on the plan of care.

You can only report the above 3 G-codes on Type of Bill 032x. You should only report these codes with revenue codes 042x, 043x, 044x, 055x, 056x, and 057x.

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COVID, Flu, & RSV

Cases of COVID, the flu, and respiratory syncytial virus (RSV) are expected to rise this winter, potentially creating a ‘tripledemic.’ Scientists say the pandemic ‘immunity gap’ is probably behind the surge in viruses. Experts advise Americans to get vaccinated against COVID and the flu to prevent their local hospitals from overflowing. RSV vaccines are currently in development and Pfizer has begun studying a combination vaccine for COVID and the flu.

• COVID-19: Coronavirus-related hospitalizations are rising and at least half a dozen Omicron subvariants are competing to be the next dominant strain in the US. New data from Pfizer suggests that the updated booster provides four times stronger protection against more recent Omicron variants than the original vaccine. 

• The Flu: So far, this flu season has been earlier and more severe than it has been in 13 years, according to data from the Centers for Disease Control and Prevention (CDC). Inequities have been found in flu vaccine uptake. Black, Hispanic, and Indigenous adults are more likely to be hospitalized with the flu and less likely to be vaccinated against it.

• RSV: RSV is a common respiratory virus that can be serious for young children and older adults. Children’s hospitals are being overwhelmed by the nationwide surge in RSV cases. The unusually early and drastic spike in RSV cases has increased wait times and is straining health care resources.

Expanded HHVBP Model: PIPR and New Resources Available

Available in iQIES: Expanded HHVBP Model Pre-Implementation Performance Reports

As the expanded HHVBP Model prepares to start the first performance year on January 1, 2023, the Centers for Medicare & Medicaid Services (CMS) issued the November 2022 Pre-Implementation Performance Report (PIPR) to all active home health agencies (HHAs). The PIPRs provide HHAs with data on their quality measure performance used in the expanded HHVBP Model, with comparison to HHAs nationally within peer cohorts. Additionally, the CY 2023 Home Health (HH) Prospective Payment System (PPS) final rule amended the Model baseline year from CY 2019 to CY 2022 starting in the CY 2023 performance year to enable CMS to measure competing HHAs performance on benchmarks and achievement thresholds that are more current. The PIPRs provide a preview of where your agency’s performance falls in regard to the new baseline year, in advance of the release of the first Interim Performance Reports (IPRs) in July 2023.

The November 2022 PIPR is available to download from the Internet Quality Improvement Evaluation System (iQIES). Instructions on how to access the PIPRs are available on the Expanded HHVBP Model webpage, under Model Reports.

To assist HHAs in understanding the purpose, content, and use of the PIPRs, the HHVBP Technical Assistance (TA) team created an on-demand video and downloadable resource, “Introduction to the Pre-Implementation Performance Report (PIPR)”, available on the Expanded HHVBP Model webpage under Model Reports. The video is also available on the Expanded HHVBP Model YouTube channel.

There will also be a live streaming event introducing the PIPRs at 11:00 AM ET on November 17, 2022. Attendees will have the opportunity to submit questions during the webinar. Click here to register for the event: https://us06web.zoom.us/webinar/register/WN_bz6_WZm2RFm1YgRTerQi6g.

For questions, please email the HHVBP Model Help Desk at [email protected]. 

New Resource Available – Quality Improvement Self-Assessment for Your HHA

The HHVBP TA Team is pleased to announce the availability a new organizational self-assessment resource, Quality Measure Category-Focused Performance Improvement. This resource provides a brief, self-guided, performance improvement exercise designed for HHA teams, based on structured review of expanded HHVBP Model performance data by measure category. Included in this resource is a template that will help teams create data visualizations that will highlight patterns in measure performance by category. Teams can use results for planning performance improvement activities.

This resource is available on the Expanded HHVBP Model webpage under the “Quality Improvement” section.