(July 7, 2014): As of July 1, 2014, Medicare-certified hospices must directly submit a Hospice Item Set (HIS) (for Admission and Discharge) records for each patient admission that occurs on or after July 1. These HIS records must be completed on an ongoing basis and submitted electronically the Centers for Medicare & Medicaid Services. Any hospice that fails to collect and report its HIS records for July 1 through December 31, 2014 will incur a 2% reduction in hospice payments for fiscal year 2016.
I. Hospice Quality Reporting Requirements — HIS Records:
On August 7, 2013, CMS published its final rule setting forth changes to the requirements for the hospice quality reporting program (HQRP). The rule discontinued previous reporting measures and implemented a standardized patient-level data collection vehicle known as a Hospice Item Set (HIS). The HIS will then be used to calculate the seven National Quality Forum (NQF) endorsed measures. These NQF-endorsed measures include:
- NQF #1617 Patients Treated with an Opioid who are Given a Bowel Regimen;
- NQF #1634 Pain Screening;
- NQF #1637 Pain Assessment;
- NQF #1638 Dyspnea Treatment;
- NQF #1639 Dyspnea Screening;
- NQF #1641 Treatment Preferences; and
- Modified NQF #1647 Beliefs/Values Addressed (if desired by the patient).
Hospices must begin using the HIS for each patient admission that occurs on or after July 1, 2014. For this process, each hospice must submit two (2) HIS records for each patient admitted. The first record – an HIS Admission record – contains both administrative items for patient identification as well clinical items for calculating the 7 NQF measures. The second record – an HIS-Discharge record – is a limited set of administrative items also used for patient identification; however, it also contains discharge information that will be used primarily to determine patient exclusions for some of the 7 quality measures.
II. HIS Records Must Be Completed and Submitted Electronically:
Each HIS record must be completed on an ongoing basis. Notably, HIS completion timeframes vary depending on the record being submitted.
For HIS-Admission records, hospices will have 14 days from admission to complete HIS-Admission records. However, hospice Providers must be aware that there is a difference between the Completion Date and the Completion Deadline.
The Completion Date (Item Z0500 on the HIS-Admission record) is the actual date on which the hospice completes the HIS record. The Completion Date is defined as the date on which all required information has been collected and recorded in the HIS and completeness of the record has been verified and recorded in Item Z0500. On the other hand, the Completion Deadline is the latest possible date on which a provider should complete the HIS record. For the HIS-Admission record, the Completion Deadline is defined as the Admission Date plus 14 calendar days. Furthermore, CMS stresses that, should a patient’s status with respect to a care process item change between the Completion Date and the Completion Deadline, the hospice should not update the HIS-Admission record to reflect these changes.
For the HIS-Discharge record, hospices will have 7 days from discharge to complete this task. After completing HIS records, hospices must electronically submit its HIS records to CMS. Hospices will have 30 days from a patient admission or discharge to submit the appropriate HIS record for that patient.
In order to submit the HIS-Admission and HIS-Discharge records, hospice providers must register for a CMSNet User ID and a QIES User ID. The CMSNet User ID and the QIES User IDs are essential for the successful submission of HIS data beginning July 1. Providers can obtain the online self-registration application for the CMSNet User ID that is available on the CMSNet Information web page.
III. CMS Provided Training:
In recent weeks, the Centers for Medicare & Medicaid Services (CMS) has released several new and updated materials to assist hospices in their preparations for the coming requirement. On the “Hospice Item Set (HIS)” portion of the website, these resources include:
- UPDATED Version of the HIS Manual (V1.01) and Relevant Change Table. Providers should review V1.01 of the HIS Manual and the relevant change table so that they are aware of changes made in the updated version of the HIS Manual.
- NEW Fact Sheet about Guidelines for HIS Completion. This Fact Sheet replaces previous CMS guidance about updating the HIS and provides important new information.
- NEW Question and Answer (Q&A) Document. This Q&A document contains frequently asked HIS-related questions received on the HelpDesk January – March 2014.
On the “HIS Technical Information” portion of CMS’ website, helpful materials include:
- Registration process for hospice User IDs. Hospices will need 2 user IDs to submit HIS records to the QIES ASAP system.
- Technical training modules covering HIS registration and submission processes including submission of files to QIES ASAP and using the HART software.
CMS also has posted on its website a recording of HIS training that was performed in February 2014. This training covers HIS data collection processes, such as item-specific instructions for each item in the HIS, along with tips and examples for HIS items. The HIS Training follows closely along with the HIS Manual and follows the HIS Training Slides. The Manual is an essential tool in understanding how to complete the HIS; it is recommended that you review the Manual prior to viewing the training.
IV. Final Remarks:
The data submitted to CMS will be published as part of the HQRP. Any provider who fails to collect and submit their HIS records for July 1 through Dec. 31, 2014, will incur a 2 percent reduction in hospice payments for FY2016. The HQRP is currently “pay-for-reporting,” which means that it is the act of submitting data that determines compliance with HQRP requirements. Performance level is not a consideration when determining market basket updates/Annual Payment Updates (APU).
Hospice providers have had ample time to prepare for the implementation of the HIS-Admission and HIS-Discharge requirements. As a result, there should be no reason that any provider incurs this penalty. The links above should assist you with any questions related to the new HIS requirements. However, should you still have questions related to this matter – or any hospice related issue – please feel free to give us a call.
Robert Saltaformaggio, Esq., serves as an Associate at Liles Parker, Attorneys & Counselors at Law. Liles Parker attorneys represent health care providers and suppliers around the country in connection with Medicare audits by ZPICs and other CMS program specialty contractors. The firm also represents health care providers in HIPAA Omnibus Rule risk assessments, privacy breach matters, State Medical Board inquiries and regulatory compliance reviews. For a free consultation, call Robert at: 1 (800) 475-1906.