Home Health & Hospice Week

CMS eases up on RAP recoupments, coming M0175 takebacks.

The 91 home health agencies CMS estimates are affected by Hurricane Katrina soon will gain some reimbursement breathing room.

Normally, home health agencies must submit their final claim either 60 days from the end of the patient's episode or 60 days from the issuance of the request for anticipated payment (RAP). If they don't meet either of those 60-day deadlines, the regional home health intermediary recoups the RAP amount.

Help is coming: But HHAs affected by Katrina will receive a blanket extension of the 60-day timeline for the final claim, the Centers for Medicare & Medicaid Services said in the Sept. 22 Open Door Forum for home care providers. Forthcoming instructions will apply the extension to disaster-affected regions, CMS' Wil Gehne told the forum's more-than-250 callers.

RAP Recoupment Extended Up To 90 Days

"RAPs for HHAs in the disaster affected areas will be assigned cancellation dates of Jan. 3, 2006," Gehne tells Eli. That will allow agencies an additional 60 to 90 days to resume submission of final claims. CMS has sent the instructions to its contractors and should post that information in the Katrina questions and answers soon, Gehne says.

Agencies will also see more limited relief for the M0175 takebacks that are set to begin in November (see Eli's HCW, Vol. XIV, No. 31). The recoupments are for episodes in which HHAs incorrectly marked prior inpatient stays during the first years of the prospective payment system.

Individual providers affected by the disaster can request relief from their RHHIs on the M0175 recoupments, Gehne told the forum.

Unanswered questions: Policy questions about Hurricane Katrina are still outstanding, the National Association for Home Care & Hospice's Mary St. Pierre reminded officials in the forum. Impacted providers need the answers soon, St. Pierre urged.

CMS departments must confer internally to get answers to many of the questions, said CMS' Randy Throndset. "We're about as close as we can be to getting [the answers] out," he promised. CMS will update the Katrina Q&A as soon as possible, it pledged.

All Providers To Use New Disaster Modifier, Code

CMS has instituted a new modifier and condition code to speed the processing of claims impacted by Hurricane Katrina and future disasters, the agency says in Sept. 23 Medlearn Matters Article 4106.

HHAs and hospices can use condition code DR (Disaster Related) when billing for services and items furnished to disaster victims. Suppliers can use modifier CR (Catastrophe/Disaster Related) for such billing, the article instructs.

The new code and modifier are retroactive to Aug. 21, but contractors and the Common Working File don't have to implement them until Oct. 31, according to a Sept. 23 transmittal (Change Request 4106).

And your intermediary or carrier can dictate how exactly they'll use the new items. "Contractors shall use their discretion in how the modifier [and code] can be utilized in their system to facilitate claims processing for disaster related claims," CMS says in the transmittal.

More Medicaid coverage: Mississippi, Alabama and Florida have followed Texas's lead in agreeing to emergency Section 1115 waivers with the Department of Health and Human Services for Medicaid coverage of Katrina victims. The waivers make it easier "for people to get access to the health care they need right now, without the delay and paperwork of setting up new kinds of programs," CMS Administrator Mark McClellan says in a release.

HHS is prepared to offer the waiver to more states if needed in Rita's wake, McClellan notes.

The Senate is considering multiple legislative proposals for Katrina relief, but the initiatives face opposition resulting in no clear path to quick passage. Both members of Congress and the White House are looking at cutting federal benefit programs such as Medicare to fund Katrina relief, putting a possible target on the home care budget (see Eli's HCW, Vol. XIV, No. 34). 

Note: The Medlearn Matters article is at www.cms.hhs.gov/medlearn/matters/mmarticles/2005/MM4106.pdf.

Katrina Q&A are at www.cms.hhs.gov/katrina.