Home Health & Hospice Week

Confusion ahead for large organizations.

Your tax identification number may become more important than ever before under the new HIGLAS accounting system.

One of the main aims of HIGLAS is to tie tax ID numbers to all debts related to that employer, so that Medicare can recover debts efficiently, notes Abilene, TX-based reimbursement consultant Bobby Dusek.

The Centers for Medicare & Medicaid Services treats "entities with the same TIN as 'one in the same,'" regional home health intermediary Palmetto GBA says in a May 20 posting to its Web site. "If two or more providers are affiliated and have the same [TIN], payments may be withheld from one provider to collect another provider's overpayments."

The affiliated withholding applies only to settlement overpayments - those related to interim rate reviews, cost report settlements/reopenings, tentative settlements and benefit integrity overpayments - and not to claims adjustments, cancellations or credit balances, Palmetto says in an April 22 letter explaining the new system.

This arrangement should head off fraud and abuse problems, such as when an HHA gets passed around within a family and operates under different provider numbers to duck previous debts, notes Lynn Olson with billing company Astrid Medical Services in Corpus Christi, TX.

About 40 providers are now facing withholdings due to affiliated providers under HIGLAS, a Palmetto official tells Eli.

Update Your Tax ID Numbers

But the change is already causing big problems for innocent providers. A Dallas-area former client of Dusek's has found itself slapped with a withholding for a company it has never heard of before, Dusek relates. The supposedly related agency closed about five years ago owing a big overpayment, and the Dallas HHA is getting stuck with the bill. "It sounds like a nightmare," Dusek says.

Palmetto has heard from only one agency that didn't know its supposedly affiliated provider at all and it resolved that issue very quickly, claims a Palmetto official. In most cases where HHAs protest an affiliated withholding, agencies have failed to report their changed tax ID number to Palmetto when the agency changed ownership, the source says.

HHAs that find themselves in this bind can contact Palmetto to prove that they have indeed changed tax ID numbers, the staffer instructs. "Providers really need to pay attention to their 1099s," the official stresses.

Providers that made a settlement with the Treasury Department to clear up debts also are seeing unwarranted withholdings under HIGLAS, because the Treasury settlement information hasn't yet been entered into the system, the Palmetto official notes. Most providers with Treasury Department settlements are already terminated from Medicare, however, she says.

Withholding Confusion Could Strike Large Organizations

The withholding change could cause head-aches for providers that are affiliated with large organizations with the same TIN, such as hospitals and health systems, suggests consultant Pat Laff with Laff Associates in Hilton Head Island, SC.

The electronic remittance advice will indicate only "OA" for Part A affiliated withholdings and "OB" for Part B affiliated withholdings, and the paper RA won't contain any information distinguishing affiliated withholdings from other withholdings, Palmetto says in the letter.

"You can't tell from the RA what department the withholding comes from," the Palmetto staffer acknowledges. "You'd have to call us for that."

"It could cause some confusion if the home care RA has a withholding due to a hospital issue," acknowledges consultant M. Aaron Little with BKD in Springfield, MO. But such instances probably won't reach significant proportions, he expects.

The intermediary hasn't yet heard from any large organizational providers on the issue, the Palmetto source points out.
 
Editor's Note: For instructions on correcting your tax ID number, go to www.palmettogba.com - click on 'RHHI' then click on 'HIGLAS' in the left-hand column, then click on the May 20 posting.