This document provides a summary of billing data for hospice services provided by a specific NPI from 2012. It compares the average number of days billed per beneficiary for routine home care, continuous home care, inpatient respite care, and general inpatient care to regional and national peers. The document finds that for continuous home care, the provider billed significantly more hours per beneficiary than their peers in most settings. For general inpatient care in skilled nursing facilities, the provider billed significantly more days than their peers. The rest of the provider's billing was found to be generally comparable to peers. Tables and figures display the detailed results of these comparisons.
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Comparative Billing Report on Hospice Services per Care Setting
Provided by NPI 1111111111
Introduction
Healthcare providers have a front line role in assisting the Centers for Medicare & Medicaid Services (CMS) in
effectively managing Medicare resources. CMS acknowledges the daily challenges providers face in serving Medicare
beneficiaries and the complexity of accurate billing for those services. The information contained in Comparative
Billing Reports (CBRs) is provided as a collaborative effort between the Medicare provider community and the
Centers for Medicare & Medicaid Services to support best billing practices and effective management of Medicare
program resources. This report is not intended to be punitive or sent as an indication of fraud.
The Medicare hospice benefit allows a beneficiary with terminal illness to forgo curative treatment for the illness and
instead receive palliative care. Hospice services rely on the combined knowledge and skills of an interdisciplinary team
of professionals (e.g.,physicians, nurses, social workers, therapists, counselors, hospice aides, and volunteers). To be
eligible for Medicare hospice care,a beneficiary must be entitled to Part A and be certified as having a terminal illness
with a life expectancy of 6 months or less if the illness runs its normal course. The Medicare beneficiary can receive
hospice care at home, or in a facility such as a nursing facility, a hospice inpatient facility, or a hospital.
This is a follow up CBR on Hospice Services that you received in January 2011. This report uses the same billing
comparisons and is based on January 1, 2012 through December 31, 2012 data. The billing data and references in this
report can assist you in performing a self-audit in assessing your compliance with Medicare guidelines for hospice
services. The report also provides an opportunity for comparing your billing practices to other providers billing for
these services. We encourage you to conduct an audit of your own claims and refund any overpayments to the
appropriate Medicare Administrative Contractor (MAC). To access the contact information for your MAC as well as
CMS’ other review contractors,please access the Provider Compliance Interactive Map at http://go.cms.gov/IMap.
Your MAC can explain how to submit a voluntary refund. We hope you find this information helpful and that it will
provide insights into your current and future billing practices. Listed below are website references pertinent to this
CBR:
IOM, Pub. 100-02,Medicare Benefit Policy Manual, Chapter 9
http://www.cms.hhs.gov/manuals/Downloads/bp102c09.pdf
IOM, Pub. 100-04,Medicare Claims Processing,Chapter 11
http://www.cms.gov/manuals/downloads/clm104c11.pdf
Centers for Medicare & Medicaid
https://www.cms.gov/RegionalOffices/99_RegionalMap.asp#TopOfPage.
Code ofFederal Regulations (CFR) Hospice Care Regulations (42 CFR Section 418)
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div5&view=text&node=42:3.0.1.1.5&idno=42
Office of Inspector General Work Plan Fiscal Year 2010 (page 14)
http://oig.hhs.gov/publications/docs/workplan/2010/Work_Plan_FY_2010.pdf
Hospice Association ofAmerica, Hospice Facts and Statistics, November 2010
http://www.nahc.org/assets/1/7/HospiceStats10.pdf
National Hospice and Palliative Care Organization, NHPCO Facts and Figures: Hospice Care in America, 2012
edition
http://www.nhpco.org/sites/default/files/public/Statistics_Research/2012_Facts_Figures.pdf
Methodology
The analysis for this CBR encompassed all Medicare Part A hospice final claims data with claim dates of service from
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180+ days
10.70%
90-179
days
6.50%
30-89 days
15.20%
8-29 days
25.00%
≤7 days
42.60%
Figure 2. Distribution of Beneficiaries
by the Range of Days Billed per
Beneficiary for Routine Home Care
for Your Regional Peers, 2012
January 1, 2012 through December 31, 2012 that were retrieved from the Integrated Data Repository on March 29,
2013. Four utilization measures will be analyzed within four hospice care sites of service between you and your
regional and national peers. The four hospice care sites of service are based on the HCPCS codes Q5001-Q5008 and
are grouped as follows Home (Q5001, Q5002), Nursing Facility (Q5003, Q5004), Hospice Inpatient Facility (Q5006),
and Hospital (Q5005, Q5007, Q5008). The four utilization measures,based on four revenue codes 0651, 0652, 0655,
and 0656, are 1) the average number of days billed per beneficiary for routine home care (0651), 2) the average
number of hours billed per beneficiary for continuous home care (0652), 3) the average number of days billed per
beneficiary for inpatient respite care (0655), and 4) the average number of days billed per beneficiary for general
inpatient care (0656). These measures will be statistically compared to the average of your Centers for Medicare &
Medicaid Services (CMS) Region and national peers and the results will be displayed in Tables 1-4 for their applicable
sites of service. For each of the revenue codes a pie chart will display the distribution of beneficiaries by the range of
hours or days billed per beneficiary for you and your regional peer group, respectively. CMS Regions are defined on
the CMS website.
Medicare regulations do not permit continuous home care (CHC) to be provided in an inpatient facility. Medicare
policy allows CHC to be provided in the home (Q5001, Q5002) and to patients residing in long term care nursing
facilities (Q5003). General inpatient care (GIP) can only be provided in a Medicare-participating hospital, SNF, or
hospice inpatient unit. Inpatient respite care can be provided in a Medicare or Medicaid participating hospital, nursing
facility, or hospice inpatient unit.
Results
Figure 1 below displays the distribution of beneficiaries by the range of days billed per beneficiary for routine home
care for you in 2012. Figure 2 displays the distribution of beneficiaries by the range of days billed per beneficiary for
routine home care for your regional peer group in 2012.
Table 1 below shows the results of the statistical comparison of the average number of days you billed per beneficiary
for routine home care to those of your regional and national peer group by care setting. A statistical test was used to
determine if there was significant difference between the average number of days you billed per beneficiary and those
of your regional and national peer group.
Figure 1. Distribution of Beneficaries
by the Range of Days Billed per
Beneficiary for Routine Home Care
for You, 2012
N/A
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Table 1. Statistical Comparison of the Average Number of Days You Billed per Beneficiary for
Routine Home Care to Those of Your Regional and National Peers by Care Setting in 2012
You
2009*
You
2012
CMS Region 1 National
Hospice Care
Site of
Service
Average
Days
Average
Days
Average
Days Difference Significance**
Average
Days Difference Significance**
Home 215.0 N/A 195.0 N/A N/A 180.0 N/A N/A
Nursing Facility 175.0 N/A 154.0 N/A N/A 160.0 N/A N/A
Hospice
Inpatient
Facility
187.0 N/A 170.0
N/A
N/A 150.0
N/A
N/A
Hospital 86.0 N/A 87.0 N/A N/A 90.0 N/A N/A
*2009 data forcomparison only. **A t-test was usedin this analysis; a p value ≤ 0.05indicates that we are at least 95% confident that the differenceis significant.
If a peer group has less than 30providers, a t-test comparison was not performed andyour significance will be listedas “N/A.” Alternately,if your significance is
“N/A” andyour average is also “N/A,” a t-test was not performedbecause youdidnot bill any services andare not part of thepeergroup.
Figure 3 below displays the distribution of beneficiaries by the range of hours billed per beneficiary for continuous
home care for you in 2012. Figure 4 displays the distribution of beneficiaries by the range of hours billed per
beneficiary for continuous home care for your regional peer group in 2012.
Table 2 below shows the results of the statistical comparison of the average number of hours you billed per beneficiary
for continuous home care to those of your regional and national peer group by care setting. A statistical test was used
> 75 hours
7.00%
>50-75
hours
35.00%
>20-50
hours
26.00%
8-20 hours
25.00%
< 8 hours
7.00%
Figure 3. Distribution of Beneficiaries
by the Range of Hours Billed per
Beneficiary for Continuous Home
Care for You, 2012
> 75 hours
7.00%
>50-75
hours
35.00%
>20-50
hours
26.00%
8-20 hours
25.00%
< 8 hours
7.00%
Figure 4. Distribution of Beneficiaries
by the Range of Hours Billed per
Beneficiary for Continuous Home Care
for Your Regional Peers, 2012
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180+ days
12.75%
90-179
days
8.50%
30-89 days
15.20%
8-29 days
21.30%
≤ 7 days
42.25%
Figure 6. Distribution of Beneficiaries
by the Range of Days Billed per
Beneficiary for Inpatient Respite Care
for Your Regional Peers, 2012
to determine if there was significant difference between the average number of hours you billed per beneficiary and
those of your regional and national peer group.
Table 2. Statistical Comparison of the Average Number of Hours You Billed per Beneficiary for
Continuous Home Care to Those of Your Regional and National Peers by Care Setting in 2012
You
2009*
You
2012
CMS Region 1 National
Hospice Care
Site of
Service
Average
Hours
Average
Hours
Average
Hours Difference Significance**
Average
Hours Difference Significance**
Home 125.0 121.0 195.0 36.0 higher 180.0 51.0 higher
Long Term
Care Nursing
Facility
115.0 105.0 154.0 31.0 higher 160.0 25.0 higher
Hospice
Inpatient
Facility
100.0 N/A N/A N/A N/A N/A N/A N/A
Hospital 98.2 N/A N/A N/A N/A N/A N/A N/A
*2009 data forcomparison only. **A t-test was usedin this analysis; a p value ≤ 0.05indicates that we are at least 95% confident that the differenceis significant.
If a peer group has less than 30providers, a t-test comparison was not performed andyour significance will be listedas “N/A.” Alternately,if your significance is
“N/A” andyour average is also “N/A,” a t-test was not performedbecause youdidnot bill any services andare not part of thepeergroup.
Figure 5 below displays the distribution of beneficiaries by the range of days billed per beneficiary for inpatient respite
care for you in 2012. Figure 6 displays the distribution of beneficiaries by the range of days billed per beneficiary for
inpatient respite care for your regional peer group in 2012.
Figure 5. Distribution of Beneficiaries
by the Range of Days Billed per
Beneficiary for Inpatient Respite
Care for You , 2012
N/A
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180+ days
12.25%
90-179
days
9.25%
30-89 days
13.50%
8-29 days
23.20%
≤ 7 days
41.80%
Figure 7. Distribution of Beneficiaries
by the Range of Days Billed per
Beneficiary for General Inpatient Care
for You, 2012
180+ days
12.75%
90-179
days
10.25%
30-89 days
12.75%
8-29 days
21.00%
≤ 7 days
43.25%
Figure 8. Distribution of Beneficiaries
by the Range of Days Billed per
Beneficiary for General Inpatient Care
for Your Regional Peers, 2012
Table 3 below shows the results of the statistical comparison of the average number of days you billed per beneficiary
for inpatient respite care to those of your regional and national peer group by care setting. A statistical test was used to
determine if there was significant difference between the average number of days you billed per beneficiary and those
of your regional and national peer group.
Table 3. Statistical Comparison of the Average Number of Days You Billed per Beneficiary for
Inpatient Respite Care to Those of Your Regional and National Peers by Care Setting in 2012
You
2009*
You
2012
CMS Region 1 National
Hospice Care
Site of
Service
Average
Days
Average
Days
Average
Days Difference Significance**
Average
Days Difference Significance**
Home 10.0 N/A N/A N/A N/A N/A N/A N/A
Nursing Facility 15.2 N/A 10.5 N/A N/A 11.0 N/A N/A
Hospice
Inpatient
Facility
11.5
N/A
11.0
N/A N/A
9.0
N/A N/A
Hospital 16.5 N/A 12.5 N/A N/A 13.0 N/A N/A
*2009 data forcomparison only. **A t-test was usedin this analysis; a p value ≤ 0.05indicates that we are at least 95% confident that the differenceis significant.
If a peer group has less than 30providers, a t-test comparison was not performed andyour significance will be listedas “N/A.” Alternately,if your significance is
“N/A” andyour average is also “N/A,” a t-test was not performedbecause youdidnot bill any services andare not part of thepeergroup.
Figure 7 below displays the distribution of beneficiaries by the range of days billed per beneficiary for general
inpatient care for you in 2012. Figure 8 displays the distribution of beneficiaries by the range of days billed per
beneficiary for general inpatient care for your regional peer group in 2012.
Table 4 below shows the results of the statistical comparison of the average number of days you billed per beneficiary
for general inpatient care to those of your regional and national peer group by care setting. A statistical test was used
to determine if there was significant difference between the average number of days you billed per beneficiary and
those of your regional and national peer group.
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Table 4. Statistical Comparison of the Average Number of Days You Billed per Beneficiary for
General Inpatient Care to Those of Your Regional and National Peers by Care Setting in 2012
You
2009*
You
2012
CMS Region 1 National
Hospice Care
Site of
Service
Average
Days
Average
Days
Average
Days Difference Significance**
Average
Days Difference Significance**
Home 37.0 N/A N/A N/A N/A N/A N/A N/A
Skilled Nursing
Facility***
62.5 60.0 55.0 5.0 higher 50.0 10.0 higher
Hospice
Inpatient
Facility
45.0 41.0 40.0 1.0 within the norm 43.0 -2.0 within the norm
Hospital 56.5 54.0 49.0 5.0 higher 45.0 9.0 higher
*2009 data forcomparison only. **A t-test was usedin this analysis; a p value ≤ 0.05indicates that we are at least 95% confident that the differenceis significant.
If a peer group has less than 30providers, a t-test comparison was not performed andyour significance will be listedas “N/A.” Alternately,if your significance is
“N/A” andyour average is also “N/A,” a t-test was not performedbecause youdidnot bill any services andare not part of thepeergroup. ***Inthe 2009 study,
this number includedall nursingfacilities includingskillednursingfacilities.
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