CMS Expands Hospice Enhanced Oversight Potentially to Existing Hospices
On September 5, the Centers for Medicare & Medicaid Services (CMS) announced they will expand prepayment review in four states, California, Nevada, Arizona and Texas. This announcement is an expansion of the existing new provider Provisional Period of Enhanced Oversight (PPEO) to include other providers as well. While the new announcement did not give specifics on which providers would be included beyond those in the original PPEO, specifically new agencies as of July 13, 2023, CMS did indicate in correspondence with LeadingAge that based on the initial PPEO data they are seeing providers not including records or performing behaviors that are not supporting beneficiaries.
As a reminder, in July 2023, CMS placed newly enrolling hospices located in these four states under a PPEO based on reports of hospice waste, fraud, and abuse with the goal of reducing these issues and bringing new hospices into compliance. The period of enhanced oversight can be for 30 days to one year and can include medical review such as prepayment review.
In June 2024, CMS released an updated fact sheet for the provisional period of enhanced oversight (PPEO) for new hospice providers in four states. This new fact sheet clarifies that new hospices include “those reactivating after being in a deactivated status.” Finally, in June 2024, Palmetto, the Medicare Administrative Contractor overseeing PPEO in Texas, released results of their pre-payment review for January to March 2024 which include reasons for denials including documentation not supporting prognosis and missing physician narratives. LeadingAge will continue to keep members updated on the expansion of PPEO.
Updated SNF ABN Now Available, Mandatory for Use Starting October 31
The Centers for Medicare & Medicaid Services (CMS) has updated Form CMS-10055 Skilled Nursing Facility (SNF) Advance Beneficiary Notice of Non-coverage (ABN). This form, used to notify Medicare Fee-for-Service patients of potential financial liability for services such as skilled nursing and rehab therapy, is available now and the updated form must be in use by October 31, 2024. Access the updated form and instructions here.
Medicare Advantage Flex Cards: LeadingAge Seeks to Eliminate Negative Impacts of MA Flex Cards on Beneficiaries
As Medicare beneficiaries are increasingly enrolling in Medicare Advantage and Special Needs Plans, some older adults are unwittingly jeopardizing their eligibility for certain government assistance programs when the MA/SNP plan they select offers flexible benefit cards that are sometimes counted toward their income or asset calculations. LeadingAge is seeking remedies to these negative impacts.
To learn more about the impacts beneficiaries are experiencing and the remedies LeadingAge is seeking, check out this bulletin which includes links to LeadingAge’s issue brief.
Medicare Advantage Flex Cards: LeadingAge Meets with CMS Principal Deputy on MA Flex Benefits
On September 6, LeadingAge met with the Principal Deputy Administrator and COO of the Centers for Medicare and Medicaid Services (CMS), Jonathan Blum, Tim Englehardt, Director of the CMS Medicare-Medicaid Coordination Office, and CMS senior advisor Kristiana Yao. The meeting resulted from a July 25 joint letter co-signed by LeadingAge and the National PACE Association in which LeadingAge outlined concerns about Medicare Advantage (MA) use of flex benefit cards to lure PACE participants from their integrated programs.
LeadingAge urged CMS to take action to curb predatory marketing and provide protections to PACE participants by allowing them to re-enroll in PACE at any time, require completion of a voluntary PACE disenrollment form to authenticate a participant’s informed choice to enroll in an MA plan, and clarify guidance and strengthen oversight of MA marketing brokers.
From the meeting, Mr. Blum agreed, “we are aware of unintended consequences [of these flex cards] on other programs.” CMS was grateful for LeadingAge’s recommendations in the letter and noted that the problem is “multifaceted with no silver bullet.” LeadingAge pressed on concerns about flex benefit cards being counted as income for individuals receiving other government benefits like Medicaid or federal rent subsidies. As they continue to advocate for standardized guidance and stronger beneficiary protections, LeadingAge will keep members up to date. Here is a bulletin with more background.
Weekly Recaps: September 11, 2024
Affordable Housing Weekly Update. Here is your weekly Affordable Housing Update.
Nursing Home Weekly Update. Here is your weekly Nursing Home Update.
Workforce Weekly Update. Here is your weekly Workforce Update.
Medicaid, HCBS, and PACE Weekly Update. Here is your weekly Medicaid, HCBS, and PACE Update.
Life Plan Community Weekly Update. Here is your weekly LPC Update.
Home Health Weekly Update. Here is your weekly Home Health Update.
Hospice Weekly Update. Here is your weekly Hospice Weekly Update.
