by editor | Nov 26, 2022 | Compliance and Regulatory - Directors, Documentation - Chaplains, Documentation - Nurses, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Nurses, Intake, Medical Records, Metrics and KPIs, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Social Workers
Program for Evaluating Payment Patterns Electronic Reports (PEPPER) is a data analysis report that has been available for hospices since 2012. This report contains claims data statistics based upon UB-04 claims data submissions for a single hospice agency. The statistics are generated for areas that are that are targeted by CMS as at risk for potential of improper Medicare payment. The data is reported in tabular format as well as in graphical format showing a time series of the hospice agency’s performance over time.
What timeframe of data is included in the PEPPER report?
Each PEPPER report summarizes claims data for the most recent three fiscal years (October 1 through September 30).
When is the PEPPER report generated?
The PEPPER report is generated each April. The PEPPER distribution schedule, portal access instructions, and training and resources can be seen here. A PEPPER report is generated for each hospice agency, regardless of whether the agency’s data is concerning or the agency is targeted for additional medical review.
What are PEPPER target areas?
Target areas may change or be added if new areas are identified as target areas for potential risk of improper payment. The report is used by medical reviewers to determine whether a hospice agency should be targeted for additional medical review audits. Hospice PEPPER target areas are the following:
- Live discharges no longer terminally ill: percentage of all hospice patients who were discharged (by death or alive), who were discharged alive excluding patients who were discharged alive due to transfer, revocation, discharge for cause, or patients who moved out of service area
- Live discharges – revocations: percentage of all patients who were discharged (by death or alive) who were discharged alive due to patient revocation
- Live discharges with length of stay between 61-179 days: percentage of all patients who were discharged alive who had a length of stay between 61-179 days
- Long length of stay: percentage of all patients who were discharged (by death or alive) who had a combined length of stay that exceeded 180 days
- Continuous home care provided in assisted living facility: percentage of patients living in assisted living facility for any portion of episode who were discharged (by death or alive) where at least eight hours of continuous care were provided while the patient was in an assisted living facility
- Routing home care provided while patient in assisted living facility: percentage of all routine home care days provided by hospice that were provided while patient was in assisted living facility
- Routing home care provided while patient in nursing facility: percentage of all routine home care days provided by hospice that were provided while patient was in nursing facility
- Routing home care provided while patient in skilled nursing facility: percentage of all routine home care days provided by hospice that were provided while patient was in skilled nursing facility
- Claims with single diagnosis code: percentage of all claims submitted that have a single diagnosis code
- No general inpatient care of continuous home care: percentage of all discharged patients (by death or alive) who had periods of general inpatient care that were longer than five consecutive days
- Average number of Medicare part D claims for beneficiaries residing at home: This metric only includes hospice episodes that are at least three days and that occur at home. For these, the average number of part D claims is computed
- Average number of Medicare part D claims for beneficiaries residing in assisted living facility: This metric only includes hospice episodes that are at least three days and where the patient resides in an assisted living facility. For these, the average number of part D claims is computed
- Average number of Medicare part D claims for beneficiaries residing in a nursing facility: This metric only includes hospice episodes that are at least three days and where the patient resides in a nursing facility. For these, the average number of part D claims is computed
How can a hospice agency use its PEPPER report?
An agency’s PEPPER report contains the agency’s statistics for the target areas as well as comparative statistics: national statistics, state statistics, and MAC jurisdiction statistics. The PEPPER report allows a hospice agency to compare its billing practices to those in its MAC jurisdiction, its state, and across the nation. The PEPPER report also compares the hospice agency’s target values to the national, jurisdictional, and state percentile 80th values for each target area. Agencies that fall above the 80th percentile in any of the target area are considered at risk for improper payment for that risk area. Agencies that score above the 80th percentile in one or multiple target areas will likely be subjects for additional medical review such as TPE, OIG review, or UPIC audit.
- A hospice can use the PEPPER Compare Targets Report to prioritize areas for audit or improvement. The Compare Targets Report reports the hospice agency’s percentile for each target area. A hospice agency can quickly identify if it is at high risk in any target area: if a hospice agency is above the 80th percentile in any target area, the percentile is printed in bold red. Otherwise, all percentiles are printed in black but the agency should check the percentile values. High percentile values (even if below 80) may indicate a potential risk area that the hospice agency should monitor.
- The target area graph shows a bar graph of the hospice agency’s target area value over the three years of data for each of the target areas. The graph also has three trend lines, one for each of the three 80th percentiles for each of the comparison groups. Significant changes in the values over the years should be investigated to be sure that the reason is understood. Is it due to change in staff? Change in management? Change in policies? Or, are there a possibility of improper payments?
- The target area hospice data table contains the various data elements that are used to compute the target area statistic.
- The comparative data table provides the 80th percentile values for the three comparative groups: nation-wide, MAC jurisdiction, and state. The value for any of the comparative groups will be reported as zero if there are fewer than 11 hospices in that group.
How can a hospice agency access its PEPPER report?
PEPPER reports are not sent to hospice agencies. A hospice agency can access its PEPPER report electronically at this website.
Should a hospice access its PEPPER report?
Hospices are encouraged to access their PEPPER reports. The metrics in the PEPPER can support hospice agencies with internal monitoring and auditing. Hospice agencies can use the data to detect trends over time and to compare their performance with that of other agencies – nationally and regionally — to identify outlier behavior and potential anomalies that require further investigation. Reviewing a PEPPER gives a hospice agency the opportunity to improve behaviors or take other corrective actions that can improve the outcome of an audit. It allows a hospice agency to implement self monitoring, self correction, and self improvement which is preferrable to waiting until CMS or a MAC identifies an issue. Additionally, if a hospice is under a large scale audit and has not accessed its PEPPER report, the government may claim that the issues were known or that the agency should have known that it had improper payment practices.
Where can you find more information?
by editor | Nov 26, 2022 | Compliance and Regulatory - Directors, Documentation - Chaplains, Documentation - Nurses, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Nurses, Hospice 101 - Social Workers, Intake, Medical Records, Metrics and KPIs, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Office Team, Rules and Regulations - Social Workers
The PEPPER report target areas focus on statistics that will identify potential for improper Medicare billing. Comparison to national, jurisdictional, and state percentiles can highlight a hospice agency’s potential need for change to its practices to guard against improper billing. Hospice agencies can leverage the information on these reports to prioritize internal audit and efforts to ensure accurate billing.
Why did CMS focus on the target areas in the PEPPER report?
- Concern: Are patients eligible and is the agency providing good quality of care?
- Target Areas: Live discharges – no longer terminally ill or patient revocation
- Discussion: A hospice may discharge a patient alive because the patient is no longer eligible, the patient revoked, the patient moved out of the service area, or for cause. The first two reasons are concerning. These reasons for live discharge may indicate that the hospice is admitting patients who are not hospice eligible. If the patient revoked it may indicate that the quality of care is lacking.
- Concern: Is a hospice agency trying to take advantage of the high routine home care rate?
- Target Area: Live discharge with length of stay between 61-179 days
- Discussion: CMS pays a higher rate for the first 60 days of routine home care; the rate of payment is lower for days 61+. High incidence of live discharge in days 61+ may indicate the hospice agency is driven by financial concerns and wants to discharge patients once the rate drops.
- Concern: Is the hospice agency admitting ineligible patients?
- Target Area: Long length of stay
- Discussion: The hospice may be admitting ineligible patients and therefore have an unusually long length of stay as compared to its peers
- Concern: Is the hospice agency targeting patients in more profitable care settings?
- Target Area: Services provided in assisted living facilities
- Discussion: An OIG study published in January 2015 found that Medicare payments for hospice care to patients in assisted living facilities increased significantly. While the diagnoses of patients in this setting typically involved less complex care, these patients remained on hospice longer and hospices received higher payments than for patients in other settings. There is therefore a need to monitor whether hospices are targeting patients in more profitable care settings including assisted living facilities, skilled nursing facilities, and nursing facilities.
- Concern: Is a hospice agency accurately reporting all diagnoses on the claim?
- Target Area: Claims with a single diagnosis code:
- Discussion: A hospice should report on the hospice claim the principle diagnosis and all diagnoses related to the terminal illness and related conditions. A hospice agency that has an unusually high number of claims with a single diagnosis may indicate that the hospice is not reporting all related diagnoses.
- Concern: Is the hospice agency meeting Medicare CoP and able to offer all four levels of care?
- Target Area: No general inpatient or continuous home care
- Discussion: Medicare Conditions of Participation require hospices to demonstrate they can provide all four levels of care: routine home care, general inpatient care, inpatient respite care, and continuous home care to be a Medicare certified hospice provider. A report published by CMS in 2014, included an analysis of 2012 hospice claims:
- 3% of beneficiaries did not have any general inpatient care in 2012
- 1% of hospice agencies did not provide any general inpatient care to any of their patients
- 4% of all hospice days billed in 2012 were billed as continuous home care
- 7% of hospice agencies billed at least one day of continuous home care but the share of continuous home care days billed varied across hospice agencies that billed any continuous home care days
- Almost 90% of hospice agencies that provided continuous home care had less than 1% of their days billed as continuous home care
- Four hospices billed more than 10% of their days as continuous home care.
This target area aims to monitor that hospice agencies are meeting the hospice Conditions of Participation and are able to provide all four levels of care.
- Concern: Is general inpatient care being used appropriately and are patient symptoms being managed well?
- Target Area: Long general inpatient stays
- Discussion: General inpatient stays are intended to be short term, to treat acute symptoms. If a patient has extended general inpatient stay there this level of care is not being used appropriately or that symptoms are not being properly managed.
- Concern: Is Medicare making prescription drug Part D payments when these should be paid by the hospice agency?
- Target Area: Medicare Part D payments for hospice beneficiaries
- Discussion: Hospice agencies are paid a per diem rate for each day that a patient is in hospice care, irrespective of the services that the hospice agency provides to the patient. Drugs that the hospice agency provides to the patient are included in the hospice rate. In 2019, CMS released a report analyzing 2016 Medicare Part D payments being made for beneficiaries on hospice care. Part D is the Medicare prescription drug plan. The study focused on four categories of drugs that are often prescribed to patients at the end of their lives as well as two disease specific drugs for two diseases. Part D should not pay for drugs if the patient is on hospice and the drug is covered under the hospice benefit. Based upon sample results, CMS estimates that Medicare paid $160.8 million for drugs that hospice agencies should have paid for, constituting and overpayment to hospice.
How can a hospice use this information?
With a better understanding of the underlying motivation for each of these target areas, a hospice agency should carefully look at the data on its PEPPER reports to identify any metrics that indicate a need for further investigation and possible process improvements. These reports are a powerful way to benchmark a hospice agency’s performance relative to itself (over a running three year period) as well as relative to other hospice agencies – across the nation, in its state, and in its MAC jurisdiction.
Where can you get more information?
by editor | Nov 13, 2022 | Compliance and Regulatory - Directors, Documentation - Chaplains, Documentation - Nurses, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Nurses, Hospice 101 - Social Workers, Intake, Medical Records, Metrics and KPIs, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Office Team, Rules and Regulations - Social Workers
HVLDL is an HQRP claims-based measure of the proportion of patients who have received in-person visits from a registered nurse (RN) or a medical social worker (MSW) on at least two of the final three days of life. This metric replaces the HIS-based measure Hospice Visits When Death is Imminent (HVWDII).
CMS selected this metric as an important measure of quality since it is during these final days that patients most likely exhibit extreme symptoms of actively dying. This time period is also when patients most often exhibit signs of onset of clinical signs of dying. Finally, consistent visits in the final days of life are perceived as better level of care by the patient’s family.
How are the final three days of life defined?
For the purposes of HVLDL, the final three days of life are defined as:
- Day 1: day of death
- Day 2: day prior to death
- Day 3: day two days prior to death
How are days counted?
- This metric counts days, not visits
- If an RN and a MSW each visit the patient on the same day, this counts as a single day not as two visits, since the metric counts days not visits
- Telephonic visits do not count toward this metric, only in person visits
- Visits by LPN, chaplains, or other clinical staff do not count toward this metric
Which patients are included in the calculation of HVLDL?
All Medicare fee for service hospice patients are included in this metric with the following exceptions:
- Patients who did not die in hospice care
- Patients who received continuous care, respite care, or general inpatient care in the final three days of life
- Patients who were enrolled in hospice care for fewer than three days
Since HVLDL measures visits over the final three days of life, a patient must have been enrolled in hospice for at last three days to be included in the metric.
What are the data sources for this metric?
Data for HVLDL is calculated from Medicare claims data. Only data for Medicare fee for service patients who died while in hospice and who do not meet any of the exceptions listed above are included in the HVLDL calculation.
CMS calculates HVLDL using eight consecutive quarters of data. Hospice agencies with fewer than 20 “eligible patients” in the reporting period (where an “eligible patient” is defined as a patient who has died while under hospice care and does not fall under any of the exceptions listed above) are not assigned an HVLDL value. By including eight quarters of data, CMS is expanding the set of hospice agencies for which an HVLDL value will be reported. CMS will update the HVLDL value once each year.
How is the HVLDL metric calculated?
- The denominator is the count of all “eligible patients” during the reporting period
- The numerator is the count of all “eligible patients” who received an RN or MSW visit on at least two of the three final days of life
When was HVLDL introduced and where can patients and their families view the HVLDL value?
HVLDL was added to the HQRP in 2021 and began public reporting in 2022. The metric provides insight into care provided by the hospice agency in the days immediately leading up to patient death. HVLDL can be seen under the Quality of Patient Care section on the Care Compare website.
How can a hospice see its HVLDL value?
To support a hospice agency’s quality improvement efforts, CMS shares the agency’s HVLDL value in the Hospice Agency Level QM Report in CASPER. CASPER reports separately the numerator and denominator of HVLDL as well as the hospice observed percent – the agency’s HVLDL score. CASPER also reports on the national average HVLDL score and the agency’s percentile. Percentile rank indicates what percentage of agencies nationwide had a HVLDL score that was equal to or lower than the agency’s score. A hospice agency can benchmark its HVLDL score with the national average and the percentile rank. It can also trend its performance against its own HVLDL value over time.
Why did CMS replace the HIS HVWDII?
CMS implemented HVWDII in 2017. This metric measured hospice visits by non-clinical team members including LPN, chaplain, MSW, and hospice aides during the final seven days of a patient’s life. Analyzing the data collected by this metric, CMS found that HVWDII was unable to distinguish between high quality and low quality hospice agencies (i.e., it failed the CMS validity testing criteria). Consequently, CMS sought a replacement metric. The revised metric is also aligned with the Service Intensity Add-On (SIA) payment initiative (which incentivizes visits by RN and MSW near patient’s death). HVLDL has an added benefit that it is calculated based on claims data so it does not add a reporting burden for hospice agencies.
Where can you learn more?
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by editor | Nov 13, 2022 | Compliance and Regulatory - Directors, Documentation - Chaplains, Documentation - Nurses, Hospice 101 - Aides, Hospice 101 - Chaplain, Hospice 101 - Nurses, Hospice 101 - Social Workers, Intake, Medical Records, Metrics and KPIs, Rules and Regulations - Chaplains, Rules and Regulations - Nurses, Rules and Regulations - Office Team, Rules and Regulations - Social Workers
HCI is a single comprehensive metric reflecting ten indicators of care delivered during a hospice stay — from admission to discharge. This metric, which is included in the patient Care Compare portal, is intended to provide patients, families, and caregivers with an added metric to support informed healthcare choices.
What are the data sources for this metric?
HCI is calculated from Medicare claims data. A hospice agency does not need to submit any additional data to CMS for the calculation of this metric. The HCI metric captures care processes throughout the duration of a patient’s hospice care – from admission through discharge. Only data for Medicare fee for service patients who have been discharged from hospice is included in the HCI metric. CMS calculates HCI using eight consecutive quarters of data. Hospice agencies with fewer than 20 discharges in the reporting period are not assigned an HCI value. By including eight quarters of data, CMS is expanding the set of hospice agencies for which an HCI value will be reported. CMS will update the HCI metrics once each year.
What does the HCI metric measure?
HCI is a single comprehensive metric comprised of the following ten individual indicators of care.
- CHC/GIP provided
- Gaps in skilled nursing visits
- Early live discharges
- Late live discharges
- Burdensome transitions (Type 1)
- Burdensome Transitions (Type 2)
- Per-beneficiary Medicare spending
- Nurse care minutes per routine home care days
- Skilled nursing minutes on weekends
- Visits near death
Each indicator measures a different aspect of hospice care. A set of the HCI indicators measure the agency’s provision of higher level of care as needed and more frequent visits closer to the time of death, as measured by indicators
- Gaps in skilled nursing visits
- Nurse care minutes per routine home care day
- Skilled nursing minutes on weekends
- Visits near death
A set of HCI indicators measure patterns of live discharges and transitions, as measured by indicators
- Discharges from hospice followed by hospitalization and hospice readmission
- Discharge from hospice followed by patient dying in the hospital
- Early live discharges
- Late live discharges
Finally, an HCI indicator is used to measure appropriateness of use of the hospice benefit
- Per beneficiary Medicare spending
Medicare’s overall objectives of the HCI metric are twofold: (i) to ensure that all hospice patients are receiving the care that they need and (ii) to identify indicators of fraud.
How is the HCI metric calculated?
The HCI metric simultaneously monitors all ten indicators of care. The ten indicators are then combined into a single value between zero and ten, where ten is the highest value. Each indicator equally affects the HCI value, reflecting how each aspect of care delivered, from admission to discharge, shares the same level of importance.
Specifically, the hospice agency is awarded one point for each of the ten indicator criteria the agency meets. A hospice receives a point for an indicator if its value exceeds a prescribed threshold. The threshold is determined as a function of the overall values for that indicator across all hospice agencies. The more indicators a hospice agency meets, the higher the agency’s HCI value. The sum of the points earned from meeting the criterion for each indicator yields the agency’s aggregated single HCI value.
When was HCI introduced and where can the metric be viewed?
The HCI metric was added to the HQRP and began public reporting in 2022.
The single aggregate HCI metric can be seen under the Quality of Patient Care section on the Care Compare website.
The details of the HCI metric – including the values for each of the ten individual HCI indicators – can be found in the Provider Data Catalog.
How can a hospice see details about its HCI value?
To support a hospice agency’s quality improvement efforts, CMS shares the details of an agency’s HCI indicator scores in the Hospice Agency Level QM Report in CASPER. An agency can benchmark its indicator values with state and national averages. It can also trend its performance in each indicator over time.
Where can you learn more?
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by editor | Nov 7, 2022 | Compliance and Regulatory - Directors, Documentation - Nurses, Hospice 101 - Nurses, Metrics and KPIs, Rules and Regulations - Nurses
What is the CAHPS hospice survey?
The CAHPS hospice survey is administered to eligible caregivers after a patient’s death to measure the quality of care and communication provided by the hospice. A hospice agency must participate in the CAHPS Hospice Survey to be eligible for its full annual payment update (APU). Failure to participate will result in a 2% reduction in APU. For example, compliance with the 2022 CAHPS Hospice Survey affects fiscal year 2024 APU.
Are all hospices required to administer the CAHPS hospice survey?
All Medicare certified hospice agencies should participate in the CAHPS hospice survey with two exceptions:
- Size Exemption: The exemption is based upon the number of decedents the hospice served in the prior calendar year. If the hospice served fewer than 50 survey eligible decedents or caregivers in the prior calendar year, the hospice is exempt from the CAHPS hospice survey
- Age Exemption: The exemption for age of hospice is based upon the date that the hospice received its CCN. The hospice is exempt for the remainder of the calendar year in which it receives its CCN.
CMS identifies hospices that are exempt due to age. A hospice agency is not required to file a form to request Age Exemption.
CMS does not identify hospices that are exempt for due to size. A hospice agency must apply for a Size Exemption and must apply for the Size Exemption each year that it wishes to be eligible for this exemption.
How does a hospice apply for a Size Exemption?
The hospice must complete a Participation Exemption for Size Form. The form, deadlines for submission, and details for completion can be found here.
The form requires not only a count of total patients who died while in hospice care, but certain details about these patients to determine the count of survey eligible patients and caregivers. For example, the hospice will need to submit counts of the number of patients
- who were under 18 when they died
- where there is no caregiver on record
- who died within 48 hours of final admission to hospice care
and several other categories. Care must be taken that patients are only counted in one of the categories even if they fall into multiple categories, to eliminate double counting.
What happens once a hospice submits a size exemption form?
Immediately upon submission of the form, the CAHPS Hospice Survey Project team will confirm receipt of the form. This confirmation, however, is not equivalent to Size Exemption approval. CMS will review the data to determine if the exemption is met. If CMS determines that the exemption is not met, the hospice is responsible for survey administration. Hospice agencies must accurately complete the Participation Exemption for Size Form so that they are not faced with a rejection by CMS. If the Size Exemption is not met and the hospice agency has missed administering and submitting surveys, the hospice agency will face an APU reduction.
Where can you find more information?
by editor | Nov 7, 2022 | Compliance and Regulatory - Directors, Documentation - Nurses, Hospice 101 - Nurses, Metrics and KPIs, Rules and Regulations - Nurses
Why should a hospice agency use a CAHPS Hospice Survey vendor?
A hospice agency is not permitted to administer its own CAHPS Hospice Surveys. Instead, every hospice agency is required to contract with an approved CAHPS Hospice Survey vendor. The vendor will administer the CAHPS Hospice Survey on an ongoing monthly basis and submit the data.
How can a hospice agency find an approved CAHPS Hospice Survey vendor?
CMS provides a list of approved vendors, which can be found here
Tips for selecting a survey vendor
The results of the CAHPS survey are publicly reported on Care Compare. Further, failure to submit the data timely can result in penalties from CMS. Given the significance of this survey, it is important to choose a reliable and experienced vendor that understands the hospice industry and can ensure both the quality and compliance of the data that will be submitted to CMS.
Some factors to explore when evaluating vendors include:
- Maturity of the vendor’s business and its processes. When was the business formed, number of clients, number of surveys, technologies used, operational failures, and growth in staff/changes in operations in support of growth in client base.
- Conducting the Surveys. What are survey response rates, languages supported, and mediums supported.
- Data sharing. How will patient files be shared with the vendor, does the vendor work with your EMR, is there a secure way to transmit data.
- Data Security. Has the vendor ever had a data breach, what steps are taken to ensure data protection, what steps are taken to ensure no data loss, how is data backed up, in the event of a failure how quickly will data be restored.
- Data Insights. Finally, with respect to insights, what analysis is performed on the data, what reports or dashboards does the vendor provide, does the vendor help the agency understand the results.
- Fees and Billing. Models for fees for CAHPS surveys vary by vendors. Examples may be flat price billing, fee per completed survey, fee per caregiver. Additional fees may be charged for follow ups, detailed reporting to the hospice agency, analysis shared with the agency, or access to survey data, for example.
Notifying CMS of the selected vendor
A hospice agency is required to complete a form that authorizes the CAHPS Hospice Survey vendor to collect and submit survey data to CMS. If the hospice agency does not notify CMS of this authorization, the vendor may not submit the data on behalf of the agency.
The CAHPS Hospice Survey Vendor Authorization Form is used to notify CMS of vendor authorization. The form and instructions for submission can be found here
The Vendor Authorization Form must be signed and notarized. The individual who signs the form is considered the CAHPS Hospice Survey Administrator for the hospice agency. An additional individual in the agency may be designated on the form as the primary point of contact for the survey.
Timelines
The Vendor Authorization Form must be submitted three months before data is required to be submitted.
For example, patients who die between January 2023 and March 2023 will be contacted for survey between April 2023 and June 2023. Their data will be due for submission to the CAHPS Hospice Survey Data Warehouse on August 9, 2023.
If an agency is first contracting with a vendor to begin service in January 2023, the Vendor Authorization Form would need to be submitted by May 9, 2023.
Where can you find more information?
