Home Health & Hospice Week

Whether you participate in the upcoming relaunch of Medicare competitive bidding or not, the program set to take effect in 2010 could give you some extra burdens.

In the Centers for Medicare & Medicaid Services' latest physician fee schedule proposed rule, CMS floats beneficiary notice requirements for all durable medical equipment suppliers in bid areas.

Under the bidding program, a grandfathering clause allows suppliers that are currently serving patients to continue furnishing DME and oxygen equipment. Suppliers should remember there are limitations to the grandfathering clause, including that it lasts only as long as a capped rental item's last month (see Eli's HCW, Vol. XVII, No. 20, p. 156).

Old: Previously, CMS told suppliers they could pick and choose which items to grandfather.

New: Now, CMS wants to require that if a supplier chooses to grandfather for an item, it must also continue furnishing all rented items in the same product category, according to the proposed rule published in the July 13 Federal Register. CMS also proposes a requirement for suppliers to notify beneficiaries whether they choose to grandfather or not. A written notice stating the supplier's intention would have to go to the beneficiary 30 days before bidding's start date.

Plus: Suppliers who choose not to grandfather would have to make two phone calls to the beneficiary before picking up equipment -- one 10 days prior to pick-up and one two days prior to pick-up, CMS says.

In the rule, CMS also proposes a method for suppliers who won Round 1 contracts to recover some of their bidding-related losses. Under the new provision, they could request payment for damages from CMS due to the program's last-minute cancellation of Round 1 bidding.

Caveats: CMS would make the decision on whether damages were warranted and that determination would be un-appealable. Also, subcontractors wouldn't be eligible for such payments.

Suppliers can submit comments on the proposals until Aug. 31.

Resources: Fact sheets about the new proposals are online at www.cms.hhs.gov/DMEPOSCompetitiveBid/02_Federal_Regulations_Notices_and_Manual_Instructions.asp under the "Downloads" section. A link to the physician fee schedule rule is under the "Related Links" section on the same page.

• Proponents of telemedicine funding are facing a setback with a new diabetes study. Two groups of beneficiaries in New York received intensive nurse case management for diabetes via televisits and regular care from 2000 to 2007, say study authors from Mathematica Policy Research and CMS. But costs for those benes over subsequent years were 71 to 116 percent higher than the control group that didn't receive telemedicine, says a new study in the July issue of Diabetes Care journal.

Furthermore, clinical outcome effects were merely "modest," the authors say. "The intervention's costs were excessive (over $8,000 per person per year) compared with programs with similarsized clinical impacts," the study concludes.

• If you had claims hit by the July update payment error in the Medicare claims system, you should see your rightful reimbursement by the end of the month.

Under the error, which was fixed July 11, home health agency claims and adjustments where the original or adjustment amount ended in zeroes were truncated and the zeroes were dropped from the payment calculation, intermediaries explained (see Eli's HCW, Vol. XVIII, No. 25, p. 198).

Watch out: The error could still be affecting some providers, because "claims that were placed in the approved to pay location prior to the installation of the fix will pay at the incorrect amount," CMS notes in an e-mail message to providers.

CMS expects to issue payments for the underpayment errors by about July 31, it says. Remittance advices may be confusing because while the claim detail will be correct, the payment difference will appear in the "Adjust to balance" field. "There is no action required by providers regarding this issue, since CMS will be issuing corrected payments to all impacted providers," the agency adds.

• Rules for sleep apnea testing have hit the books. CMS issued a national coverage decision (NCD) about obstructive sleep apnea testing back in March (see Eli's HCW, Vol. XVIII, No. 11, p. 88), but Medicare won't implement the NCD rules until Aug. 10, CMS says in July 10 Transmittal No. 103 (CR 6534).

However, the rules will be retroactive to the March NCD date, CMS allows in the transmittal online at www.cms.hhs.gov/transmittals/downloads/R103NCD.pdf.

The NCD "may result in more OSA testing by home health agencies since it eliminates limitations on testing in the home that were imposed by some contractors," the National Association for Home Care & Hospice noted when it was released. Three of the four covered tests that physicians can use to diagnose sleep apnea can be done in the home, NAHC pointed out.

• You should have one less claims processing hassle to deal with. The temporary change in the function of the "HOME" key in Direct Data Entry (DDE) is over, bringing your ability to use the HOME key to switch claim pages and delete revenue code lines back to normal.

Tip: The "Page" field now displays in the upper left-hand corner of the screen, regional home health intermediary Cahaba GBA says in an e-mail to providers.

Information on how to delete revenue codes is in the RHHI's Fiscal Intermediary Shared System (FISS) Reference Guide at www.cahabagba.com/rhhi/education/materials/fiss_correct.pdf.

• If you furnish hospice services under Medicare and Medicaid, expect to see stepped-up scrutiny from the new Zone Program Integrity Contractors (ZPICs).

CMS's so-called "Medi-Medi" project examines claims from both Medicare and Medicaid for the same patients. "This project allows vulnerabilities in both programs to be identified, and where appropriate, actions can be taken to protect the federal share of Medicaid and Medicare dollars," RHHI Palmetto GBA says in its July newsletter for providers.

For example: This program can detect "time bandit" providers that bill for more than 24 hours of services in a day, Palmetto notes. A recent project in Florida examining hospice claims found more than $1.8 million in duplicate payments for 262 dually eligible recipients, Palmetto reports. "The State overpaid hospice providers who submitted the duplicate claims and is recovering the over $1.8 million in overpayments." Florida's ZPIC, SafeGuard Services, operates the state's Medi-Medi program in conjunction with the HHS Office of Inspector General, the newsletter points out.

• Looking for more information on Medicare's new 5010 standards? Check out CMS's new Web site about the HIPAA standards update at www.cms.hhs.gov/Versions5010andD0.

For example: CMS expects "Level I compliance" with the new HIPAA standards starting in April with a deadline of December 2010, it says on the site. Full provider compliance is expected by January 2012.

• Medicare's redesigned Provider Statistical and Reimbursement system could make your life harder. CMS unveiled the new Internet-based PS&R program last month (see Eli's HCW, Vol. XVIII, No. 24, p. 191).

Using the new system requires an Individuals Authorized Access to CMS Computer Systems (IACS) login and password, and that can take two to four weeks to get, points out Tom Boyd with Rohnert Park, Calif.- based Boyd & Nicholas. "This process may delay the obtaining of the PS&R reports as needed for the filing of the Medicare cost report," Boyd tells Eli.

The question-and-answer set CMS furnishes on the PS&R site at www.cms.hhs.gov/PSRR doesn't indicate what will happen if a provider does not have the information when it's time to file, Boyd points out.

• You won't get far if you're not using the newest form to resolve an HHA transfer dispute, warns RHHI Cahaba GBA. Cahaba updated its transfer dispute assistance form in May, it notes in its July newsletter for providers. "Recently, we have received many transfer dispute requests from home health agencies using incorrect or outdated forms," the intermediary says. "Discard any old forms you have and ensure you are using the updated form."

Plus: Make sure "all agency responsibilities and documentation requirements have been met" before requesting assistance, Cahaba instructs. More information on those requirements is online at

www.cahabagba.com/rhhi/claims/home_health/transfer_dispute.htm.

• As the dog days of summer hit, your elderly patients are at increased risk of heat-related illnesses, warns the National Institutes of Health. Heart, lung, and kidney disorders and taking multiple medications are just a few of the risk factors your patients are likely to have. For tips on how to help elderly individuals avoid hyperthermia, go to the NIH National Institute on Aging's Web site at www.niapublications.org/agepages/hyperther.asp.

For example: Avoiding caffeine and applying cold, wet cloths to certain body parts can help avoid heat illnesses, the NIA says.