Compliance Monitor (12/23/2024)
CHAP is always seeking resources and insights to enhance the knowledge of partners and customers.
Be sure to download CHAP’s compliance calendars for home health and hospice.
Top Items
NOW AVAILABLE- Final OASIS-E1 Time Points Instruments
The final OMB-approved OASIS-E1 time points Instruments, effective 1/1/2025, are now available in a zip file in the Downloads section of the OASIS Data Sets webpage.
CMS posted the final OASIS-E1 data set effective January 1, 2025:
More Information:
- OASIS Data Sets webpage
- OASIS User Manuals webpage
CMS Releases Hospice Special Focus Program List
CMS released the list of the initial cohort of 50 hospices selected for participation in the Hospice Special Focus Program (SFP) in 2025.
The providers on this list have been identified as poor performers based on selected quality indicators. Hospices selected for the SFP will be under additional oversight to enable continuous improvement. CMS has also generated a list of future SFP candidates, but they are not currently publishing the candidate list. Read more about the hospice SFP.
CMS Open Door Forum schedule for 2025
Below is the registration link for the beginning of 2025 for the CMS Open Door Forums. More dates will be added soon. Thank you for your continued support of our CMS programs.
**REMINDER: Dates are subject to change**
The next HHA & DME Open Door Forum is Jan 8th, 2:00 PM – 3:00 PM
Register here
Revised Home Health Change of Care Notice Form Effective February 1, 2025
CMS improved the Home Health Change of Care Notice (HHCCN) form’s readability and design. Starting February 1, 2025, you must use the revised form to notify Medicare Fee-for-Service patients getting home health care benefits of plan of care changes.
The revised HHCCN is now available in Chinese, Vietnamese, and Korean, in addition to English and Spanish.
New Home Health CoP Standard Effective 1/1/2025
CMS finalized changes to add a standard into Condition of Participation §484.105, Acceptance-to-service policy, in the Final Calendar Year (CY) 2025 Home Health Prospective Payment System (HH PPS) Rate Update. This regulatory change is effective on January 1, 2025.
CHAP is revising our Home Health Standards of Excellence to incorporate this regulatory change, and we will also make our updated manual available as soon as possible. Until then, providers are responsible for developing their policy to demonstrate compliance with §484.105(i) as of January 1, 2025.
Congress has extended the pandemic-era telehealth flexibilities through March 14, 2025
Legislators approved a continuing resolution to fund the government and avoid a shutdown. The bill contained language to extend the flexibility, including the ability to perform face-to-face recertification via telehealth. They were originally slated to expire on Dec. 31.
Hospice Update
Federal Register Posts Reinstatement of Hospice Information for Medicare Part D Plans Form
This form would be completed by the prescriber or the beneficiary’s hospice, or if the prescriber or hospice provides the information verbally to the Part D sponsor, the form would be completed by the sponsor. Information provided on the form would be used by the Part D sponsor to establish coverage of the drug under Medicare Part D. Per statute, drugs that are necessary for the palliation and management of the terminal illness and related conditions are not eligible for payment under Part D. The standard form provides a vehicle for the hospice provider, prescriber or sponsor to document that the drug prescribed is “unrelated” to the terminal illness and related conditions. It also gives a hospice organization the option to communicate a beneficiary’s change in hospice status and/care plan to Part D sponsors. Form Number: CMS10538 (OMB control number: 0938-1296); https://public-inspection.federalregister.gov/2024-29458.pdf
Home Health Updates
Read the new posted HHVBP Model Newsletter December 2024 (PDF)
Annual Performance Reports (APR) – Final CY 2024 APRs Available on iQIES
Please check your Internet Quality Improvement and Evaluation System (iQIES) folder to see if your HHA received a Final CY 2024 Annual Performance Report (APR).
The Final CY 2024 APRs include an HHA’s Total Performance Score (TPS) and Adjusted Payment Percentage (APP) for CY 2023 performance and applied to all Medicare Fee-for-Service (FFS) claims with a through date in CY 2025. An HHA receives a CY 2024 APR if the HHA was Medicare-certified prior to January 1, 2022, and had sufficient data for at least five quality measures to calculate a TPS and APP.
Expanded HHVBP Model: Final October 2024 Interim Performance Reports (IPRs) are Available on iQIES
The Final October 2024 Interim Performance Reports (IPRs) for the expanded HHVBP Model have been published on the Internet Quality Improvement and Evaluation System (iQIES). The quarterly IPRs provide home health agencies (HHAs) with the cohort assignment, performance year measure data for the 12 most recent months, and the interim Total Performance Score (TPS). Using the IPR, an HHA can assess and track their performance relative to peers in their respective cohort throughout the expanded Model performance year. The October 2024 IPRs also report preliminary Achievement Thresholds (AT) and Benchmarks (BM) by volume-based cohort for the quality measure set applicable to the third performance year, CY 2025, and following performance years, respectively.
An HHA receives an October 2024 IPR if the HHA:
- Was Medicare certified prior to January 1, 2023, and
- Meets the minimum threshold of data for at least one (1) quality measure in the quarterly reporting period for the performance year shown in Exhibit 1.
Exhibit 1: October 2024 IPR quality measure performance scores time periods for each measure category
| Measure Category | Time Period | Minimum Threshold |
| OASIS-based | July 1, 2023 – June 30, 2024 | 20 home health quality episodes |
| Claims-based | April 1, 2023 – March 31, 2024 | 20 home health stays |
| HHCAHPS Survey-based | April 1, 2023 – March 31, 2024 | 40 completed surveys |
Note: IPRs are only available to HHAs through iQIES. IPRs are not available to the public.
IPRs are available via iQIES in the “HHA Provider Preview Reports” folder, by the CMS Certification number (CCN) assigned to the HHA. If your organization has more than one (1) CCN, then a report will be available for each CCN. Only iQIES users authorized to view an HHA’s reports can access expanded HHVBP Model reports. For assistance with downloading your HHA’s IPR, please contact the iQIES Service Center at 1-800-339-9313, Monday through Friday, 8:00 AM-8:00 PM ET, or by email (iqies@cms.hhs.gov). To create a ticket online or track an existing ticket, please go to CCSQ Support Central.
NOW AVAILABLE- Final version of the OASIS-E1 Manual and Change Table
The final version of the OASIS-E1 Manual, and the change table OASIS-E1 Changes from May 2024 Draft to Dec 2024 Final Manual, are now available in the Downloads section of the OASIS User Manuals webpage.
Pharmacy Updates
Medicare Part B Inflation Rebate Guidance: Use of the 340B Modifier — Revised
Learn which modifier (PDF) 340B covered entities should discontinue or use starting January 1, 2025.
New! Medicare Drug Price Negotiation Resources for Pharmacies, Mail Order Services, and Other Dispensing Entities
CMS released a new Medicare Drug Price Negotiation Program resource page for pharmacies, mail order services, and other dispensing entities (“dispensing entities”). This page hosts a new Fact Sheet, Frequently Asked Questions (FAQ) document, and is designed to provide dispensing entities impacted by the Medicare Drug Price Negotiation Program with a one-stop shop for information related to the Medicare Transaction Facilitator (MTF) and the effectuation of negotiated maximum fair prices (MFPs). The MFPs from the first cycle of negotiations will go into effect on January 1, 2026.
Importantly, CMS will use this webpage as an ongoing resource to share up-to-date information on critical pharmacy topics related to the MTF data and payment modules, which are a core component of implementing the Medicare Drug Price Negotiation Program, and, specifically, MFP effectuation. We intend to periodically publish key updates and information for pharmacies and other dispensing entities that will engage with the new MTF system. The webpage will include information such as factsheets, FAQs, timelines, and other resources related to pharmacy and dispensing entity engagement with the MTF. Initial topics include information about MTF pharmacy enrollment, CMS collection of pharmacy information for operating the MTF, draft MTF agreements for pharmacies to sign, and guidance on how to provide questions, input, and feedback to CMS throughout the process of establishing the MTF. This webpage is designed to be a resource to support dispensing entities, including ahead of MTF enrollment, which CMS anticipates beginning in late Spring of 2025. CMS encourages dispensing entities and their third-party support entities to review this webpage frequently for updates.
DME Update
CY 2025 Update: DMEPOS Fee Schedule
All Provider Updates
MBI Lookup Tools: CMS Seeks Input by February 17, 2024
CMS solicits comments to inform future decision-making regarding how we can best protect MBIs and Medicare beneficiaries. MBIs have been targeted by individuals seeking to commit Medicare fraud, including the use of MBI lookup tools to commit MBI theft. We want your input on these MBI lookup tool topic areas:
- How organizations operate externally-controlled MBI lookup tools
- How individuals or organizations use both CMS-operated and externally-controlled MBI lookup tools
- Potential benefit or impact of prohibiting or restricting externally-controlled MBI lookup tools
- Safeguards or best practices from inside or outside health care that we should consider for preventing MBI theft and misuse
We want to hear from you. Visit the MBI Lookup Tools webpage for more information and the full list of questions. Fill out the survey to provide comments by Monday, February 17, 2025.
Quarterly Credit Balance Reports No Longer Required
Starting December 1, 2024, providers aren’t required to submit Credit Balance Reports (PDF) (CMS-838) on a quarterly basis. You’re still required to report self-identified overpayments, but you should only use a Credit Balance Report when they occur.
FY 2024 Medicare Fee-for-Service Improper Payment Rate
CMS reported the national Medicare Fee-for-Service (FFS) improper payment rate in the FY 2024 HHS Agency Financial Report. See the Other Information section under Payment Integrity Report.
The 2024 national Medicare FFS improper payment rate is 7.66%, or $31.7 billion in improper payments. Most of these improper payments fall into 2 categories:
- Insufficient documentation
- The documentation provided didn’t sufficiently demonstrate medical necessity
More Information:
Health Care Fraud and Abuse Control Program Fiscal Year 2023 Report
Today, OIG, the Department of Health and Human Services, and the Department of Justice released the Health Care Fraud and Abuse Control Program Annual Report for Fiscal Year 2023, which details the latest interagency efforts to decrease health care fraud and recover over $1.8 billion.
Read the Fiscal Year 2023 Report
CMS Announces “Optimizing Care Delivery: A Framework for Improving the Healthcare Experience”
Optimizing Care Delivery: A Framework for Improving the Healthcare Experience is the Center for Medicare & Medicaid Services’ (CMS) five-year strategy for improving healthcare delivery and the care experience by addressing administrative burdens and other frictions in the programs it oversees as well as the health system more broadly.
The Framework establishes a set of seven strategic priorities to guide CMS’ work to improve the care experience in healthcare over the next five years:
- Priority 1: Integrate the voice of the patient and caregiver into opportunities to increase equity in care access and delivery.
- Priority 2: Improve patient safety and reduce administrative burden in care transitions.
- Priority 3: Address well-being and experience for healthcare workers across the healthcare enterprise.
- Priority 4: Improve care approval processes to increase access to care and reduce care delays.
- Priority 5: Reduce redundant or outdated data collection, documentation, and reporting requirements.
- Priority 6: Leverage technology to accelerate innovation and the adoption of best practices.
- Priority 7: Convene and support public-private partnerships to advance the healthcare experience and burden reduction efforts.
The Framework was informed by evidence-based research and public feedback received through CMS outreach including but not limited to the 2023 CMS Conference on Optimizing Healthcare Delivery, with more than 2,500 registrants; the 2022 Make Your Voice Heard Request for Information, which received over 4,000 comments; public roundtables with patients and providers; and twelve human-centered design (HCD) customer experience-focused engagements on topics, such as Clinician Well-being, Prior Authorization, Mental Health, Chronic Pain, and more. These HCD engagements included interviews with 1,741 participants, 15 site visits, and over 25,000 individual data points generated.
CMS continues to find opportunities to relieve administrative burden and welcomes collaboration within public and private partnerships to achieve this aim. You can view the full framework as well as provide feedback, ideas, and suggestions by visiting https://www.cms.gov/priorities/key-initiatives/burden-reduction/optimizing-care-delivery-framework.
You are also invited to register for the 2024 CMS Optimizing Healthcare Delivery to Improve Patient Lives Conference taking place on December 12, 2024, from 11:00 AM to 4:00 PM ET. You can find a full list of all confirmed speakers and topics, as well as register, here.
Enhancing safe medication use in home care: insights from informal caregivers.
December 11, 2024
Gil-Hernández E, Ballester P, Guilabert M, et al. Front Med (Lausanne). 2024;11:1494771.
View more articles from the same authors.
Informal or family caregivers are tasked with increasingly complex care regimens as many care recipients prefer to stay in their homes rather than move to a residential facility. This study aimed to estimate the frequency of medication administration errors made by informal caregivers in the home and contributing factors. On average, 13.5 medication errors per caregiver per year were self-reported, with more than half of caregivers reporting making at least one error in the past year. Caregivers who received at least 20 hours of training made fewer errors. Caregivers who cared for multiple recipients reported more errors than caregivers who reported sharing caregiving responsibilities (e.g., two children caring for one parent).
Special Fraud Alert: Suspect Payments in Marketing Arrangements Related to Medicare Advantage and Providers
OIG’s Special Fraud Alert warns about certain marketing schemes involving the Medicare Advantage program. These schemes involve questionable payments and referrals between Medicare Advantage plans, health care professionals, and third-party marketers such as agents and brokers. These schemes can mislead Medicare enrollees into choosing specific health plans or health care providers that may not meet the enrollees’ needs.
CMS Innovation Center releases seventh Report to Congress
Today, the Centers for Medicare & Medicaid Services published the Center for Medicare and Medicaid Innovation’s (the CMS Innovation Center) 2024 Report to Congress (RTC) (PDF). During the period of report, more than 192,000 providers and/or plans participated in CMS Innovation Center models and initiatives, serving more than 57 million beneficiaries.
This seventh report features strategic accomplishments, updates on 37 models and initiatives (including 9 newly announced models), 52 evaluations, and more activities from October 1, 2022 through September 30, 2024. Also, new to this year’s streamlined, reader-friendly report, is an introduction from Center Director Dr. Liz Fowler and an infographic of Center highlights.
Read more about the goals and lessons learned from this work.
HHS Finalizes HTI-2 Rule Advancing Interoperability through TEFCA
On December 11, the HHS Assistant Secretary for Technology Policy (ASTP) released the Health Data, Technology, and Interoperability: Trusted Exchange Framework and Common Agreement (HTI-2) Final Rule. The final rule is effective January 15, 2025.
Educational Opportunities
PAC Training Links Updated
CMS has updated the host server for its PAC training. If you access training from CMS webpages, you will see no changes. If you have bookmarked any training, be sure to update your bookmarks per your web browser’s instructions.
Save the date: 2025 CMS Health Equity Conference: Building a Healthier America
The Centers for Medicare & Medicaid Services (CMS) is excited to announce the 2025 CMS Health Equity Conference: Building a Healthier America on April 23-24, 2025. The free, hybrid conference will be held at the Hyatt Regency hotel in Bethesda, Maryland, and available virtually.
CMS looks forward to convening leaders from federal and local agencies, health provider organizations, academia, community-based organizations, and others to discuss strategies and best practices for building healthier communities and a healthier nation – together. Conference attendees will have the opportunity to hear from CMS leadership on recent developments and updates to CMS programs; explore the latest research; and collaborate on community engagement strategies.
The Call for Proposals will open later this week, and conference registration will open in early 2025. Please note our conference website has changed—for more information, please visit https://cmshealthequitycon.com/.
CMS looks forward to hosting the 2025 CMS Health Equity Conference, and we welcome your attendance and participation as we work together to build a healthier America.